2021 (3) TMI 1125

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.... 2,04,36,269/- made by the Assessing Officer on account of bogus purchases without appreciating the facts that the physical verification of the address of the referred three creditors has revealed that their addresses were locked and uninhabited for previous many years. 2. On the facts and circumstances of the case, the Ld.CIT(A) has erred in law and on facts by overlooking the fact that the above three parties have purchased the raw materials from the same parties who also do not exist on their declared business premise. 3. On the facts and circumstances of the case, the Ld.CIT(A) has erred in law and on facts by overlooking the fact that the referred three creditors having trade turnover in crores have employed only one ....

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....he Assessing Officer disallowed the purchases made on the following grounds:- (i) "All the three parties are running their business from D-193, Gali No.8, Laxmi Nagar, Delhi-110092. However, the premise is closed for a long time as is evident from the ITI report as well as statement recorded on oath of Smt. Heeramani Jain and Shri Pankaj Jain. (ii) All the three parties are related to each other. Ms. Pooja Jain, Proprietor of M/s. Pooja Fashions and Shri Pankaj Jain, Director of M/s Expo Fabs Pvt.ltd. are children of Smt. Heeramani Jain. All family members are running their business with different entities from the same place. (iii) All are running their business from residential premises i.e. 73, Vijay Laxmi Apar....

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.... Counsel for the assessee opposed these submissions and supported the order of the Ld. CIT(A). Ld. Counsel for the assessee further took us through the assessment order as well as impugned order to buttress the contention that assessee had furnished every details to the Assessing Officer. Further he submitted that the Assessing Officer has not brought any material on record that these purchases were bogus. Merely a bald observation has been made regarding the purchases. He further submitted that the Assessing Officer has not doubted the veracity of the accounts and the accounts have not been rejected. The Assessing Officer has also not doubted about the sales. The figures of sales made by the assessee is not disturbed. Under these facts and....