2021 (5) TMI 422

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....ainst order dated 31-05-2019 of learned Commissioner of Income-tax (Appeals)-28, Mumbai for the assessment year 2010-11. 2. When the appeal was called for hearing, no one was present on behalf of the assessee to represent the case. Considering the nature of dispute, I proceed to dispose of the appeal ex parte qua the assessee, after hearing the learned Departmental Representative and on the bas....

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....sessing officer reopened the assessment under section 147 of the Act. In course of assessment proceedings, the assessing officer called upon the assessee to prove the genuineness of such purchases. In response to query raised, the assessee furnished copies of ledger account of the selling dealer, purchase bills, bank statement evidencing payments made through cheques, purchase register, etc. The a....

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....ative and perused the material available on record. Though, the assessing officer has held the disputed purchases to be non genuine; however, he was convinced that not only the assessee had purchased the goods from some other sources, but has also effected corresponding sales. Therefore, he has restricted the disallowance to profit element embedded in such purchases by estimating it at 12.5%. Cons....