2017 (3) TMI 1646

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....of Rs. 23 lacs. To that extent, the assessee felt aggrieved and preferred an appeal, which was allowed and relief in respect of the remaining amount was also granted. It appears that the authorities of the State came in possession of material to suspect the aforesaid transactions and, therefore, proceedings for reassessment, after 4 years, were sought to be initiated. The authority, who gave permission to initiate assessment proceedings, vide order dated 9.1.2009, provided that the assessing authority may verify the books of account of M/s Bhawani Brick Field, Daurala, who had denied having sold these bricks to the revisionist, which apparently had formed the basis for initiating reassessment proceedings. The authority called for the record....

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....led far. It transpires from the record that the assessee had claimed purchases of bricks in 3 lots i.e. on 10.5.2002, 23.7.2002 and 18.10.2002. The claim of the assessee was accepted in its entirety by the first appellate authority in assessment proceedings. However, the seller M/s Bhawani Brick Field, Daurala, in its statement made before the authority, denied having sold any bricks after 1.10.2002 and it was contended that whatever bricks were made till 30.9.2002 alone were sold till 30.9.2002 and thereafter no bricks were sold. It was for this reason that the transaction of purchase of bricks, by the assessee, on 18.10.2002, was doubted leading to the reassessment proceedings. This disclosure by the seller apparently was the sole basis ....