2021 (6) TMI 318

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....wal, Member (A) 1. Aforesaid appeal by revenue for Assessment year [AY in short] 2010-11 contest the order of Ld. Commissioner of Income Tax (Appeals)-36, Mumbai [in short CIT(A) ] dated 26/08/2019 which has provided certain relief to the assessee on account of alleged bogus purchases. 2. Though none appeared for assessee, however, material on record was sufficient for disposal of the appeal....

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....the assessee furnished copies of purchase bills, monthly details of sale & purchase along with bank statements evidencing payment through banking channels. However, notices issued u/s. 133(6) did not elicit satisfactory response. The assessee could not produce any of the suppliers for confirmation of transactions. The Ld. AO, after considering entire factual matrix as well as in the background of ....

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.... we find that the Sales Turnover was not in doubt and the assessee was in possession of primary purchase documents. The payment to the suppliers was through banking channels. There could be no sale without actual purchase of material keeping in view the assessee's nature of business. The facts of the case made it a fit case to estimate the profit element embedded in these transactions. The Ld.....