2003 (9) TMI 326

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....ods purchased from unregistered dealers are completely unvouched. (ii) Not a single purchases was made from registered dealer. (iii) That normally payment is required to be made to the unregistered dealer immediately but in the case of the assessee the payments are made after intervals. (iv) The assessee failed to prove genuineness of purchases and also failed to produce the persons before AO for examination. (v) The genuineness of expense for purchase of blocks and slabs not established." 3. After having considered the plea of the assessee, the learned CIT(A) opined that the AO had accepted the sales against these purchases. If at all, the AO could only make addition for the bogus sales because no cor....

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.... and not to disallow entire claim as without use of raw material sales of finished goods was not possible. (iii) The second allegation of the AO that the assessee sold the goods which were the accumulated stock of earlier years is also incorrect. If it is so then the AO ought to have treated the entire sales of Rs. 8,29,646 as income or increase the value of opening stock as the income is to be assessed of the relevant year and accumulated stock of earlier years cannot be taxed in the year under appeal. Further the wild allegation made by AO is not supported from any evidence. Particularly when purchases made are supported from internal vouchers. Further it is wrong to say that URD demand price at the time of sales. The sales are m....