2019 (11) TMI 323

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.....M. Captioned appeal by the assessee is against the order dated 4th June 2018, passed by the learned Commissioner of Income Tax (Appeals)-2, Pune, for the assessment year 2009-10. 2. Ground no.1.2, is not pressed, hence dismissed. 3. Ground no.1.7, being general in nature does not require adjudication. 4. The rest of the grounds are on the issue of addition of Rs. 11,66,082, made on ac....

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....r section 147 of the Act. In the course of assessment proceedings, the Assessing Officer called upon the assessee to prove the genuineness of purchases made by furnishing corroborating evidences. Further, to verify the genuineness of such purchases, the Assessing Officer conducted independent enquiry by issuing notices under section 133(6) of the Act to the concerned parties. However, as alleged b....

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....lso sustained by learned first appellate authority. 6. The learned Authorised Representative submitted, in the course of assessment proceedings, the assessee had furnished purchase bills, payment details, quantitative tally of purchases, consumption and sales with party wise details. He submitted, the Assessing Officer has not disputed the consumption of raw materials and sale of finished produ....

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....tails relating to purchase, consumption and sale of goods cannot be completely overlooked. Thus, a reasonable presumption can be drawn that the assessee may not have purchased the goods from the declared source but has purchased them from third parties and for regularizing such purchases has obtained accommodation bills. In such circumstances, the entire purchases made by the assessee cannot be di....