2020 (12) TMI 767

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....s.143(3) r.w.s. 147 of the Income Tax Act, 1961 (hereinafter referred to as Act) dated 29/03/2014 by the ld. Dy.CIT-Rg.13(1), Mumbai (hereinafter referred to as ld. AO). 1.1. As identical issues are involved in both the appeals, they are taken up together and disposed off by this common order for the sake of convenience. 1.2. None appeared on behalf of the assessee. With the consent of the ld. DR, the appeal of the revenue for A.Y.2007-08 is taken up as the lead case and the decision rendered thereon would apply with equal force for A.Y.2008-09 in view of the identical facts except with variance in figures. 2. The only effective issue to be decided in this appeal is as to whether the ld. CIT(A) was justified in restricting the disa....

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....ent of the assessee was sought to be reopened. By issuance of notice u/s.148 of the Act, the assessee filed a reply to the ld. AO that the return already filed may be treated as the return in response to the notice u/s.148 of the Act and sought for reasons recorded for reopening which was duly supplied to the assessee. 3.2. We find that the assessee had furnished the names and address of the aforesaid suppliers, details of products purchased, VAT registration, addresses of suppliers, purchase bills and copies of bank statements, evidencing the payments being made by account payee cheques to those suppliers before the ld. AO. However, the ld. AO observed that assessee was not able to produce any evidence to prove the actual movement of go....