2014 (6) TMI 741

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....peal by the Revenue for the assessment year 2007-2008 is directed against the order of the CIT(A). 2. The grounds of the appeal of the Revenue are as under: "1. On the facts and circumstances of the case, the CIT(A) has erred in deleting the entire addition made by the AO on account unverifiable purchases of Rs.90,04,927/-. 2. Whether, on the facts and circumstances of the case, the CIT(A) was ....

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....R submitted that the assessee could not prove the genuineness of purchases amounting to Rs.90.04 lakhs pertain to items of purchase of diamond claimed to have been purchased from M/s.Sanjay Enterprise, Surat and M/s.Vishal Overseas, Surat during the year. He submitted that merely because the payment of purchases was made per account payee cheque by the assessee, it could not be said that the asses....

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....ment during the year and all outstanding amounts in subsequent years, confirmations from the transacting parties and relevant extracts of the bank statements of transacting parties, books of accounts and stock statement etc. The learned counsel for the assessee submitted that the CIT(A) has recorded that the AO also did not deem it fit to verify the records of the transacting parties, which were a....

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....vidences in support of its claims of purchase in the form of purchase invoices, evidences of payment through banking channels during the year and outstanding amounts in subsequent year, confirmations from the transacting parties and relevant extracts of the bank statements of the transacting parties, books of accounts and stock statements. In the immediately preceding assessment year, the purchase....