2019 (7) TMI 1662

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.... Respondent by: Shri S. Sridhar, Advocate  ORDER N.R.S. Ganesan, This appeal of the Revenue is directed against the order of the Commissioner of Income Tax (Appeals)-3, Chennai dated 28.04.2017 and pertains to the assessment year 2006-07.      2.  Shri N. Gopinath, the Ld. Departmental Representative submitted that this is the second round of litigation b....

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....fficer for reconsideration.     3. On the contrary, Shri S. Sridhar, the Ld. Counsel for the assessee submitted that there is no additional material filed before the Ld.CIT(A).  All the materials were filed before the Assessing Officer.  Referring to the order of this Tribunal in the first round of litigation, the Ld.Counsel for the assessee submitted that this Tribu....

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....n the first round of litigation, this Tribunal remitted back the matter to the file of the Assessing Officer.  Admittedly, the assessee engaged itself in the business of export of cotton garments, fabrics, etc.  The assessee filed the details of purchase invoices and the lorry details by which the same was transported.  Export of goods is not in dispute.  The Assessing Officer ....

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.... available before the Assessing Officer as well as Ld.CIT(A).  Having furnished the details of the purchase invoice and the details of lorry before the Assessing Officer, this Tribunal is of the considered opinion the assessee has discharged its onus.  Therefore the burden of proof shifts on the shoulders of the Revenue.  The material available on record clearly establishes that the....