2021 (8) TMI 1079

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....sessment years 2009-10 and 2010-11. 2. Briefly the facts are, the assessee, a resident company, is stated to be a stockiest of resins and chemicals purchased from various manufacturer, traders, brokers of local market and dispatches such goods to its warehousing at Bhiwandi. The assessee is also stated to be conducing exclusive trading activity. For the assessment years under dispute, the assessee had filed its returns of income under section 139(1) of the Act. Subsequently, having reason to believe that certain purchases claimed to have been made by the assessee during the relevant years are non genuine, the Assessing Officer (AO) reopened the assessment under section 147 of the Act. In course of assessment proceedings, the AO called up....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... 3. At the very outset, the learned Counsel for the assessee submitted that the appeals filed by the revenue are not maintainable due to low tax effect. As regards the merits, he strongly relied upon the observations of learned Commissioner (Appeals). 4. As regards the non-maintainability of the appeals due to low tax effect, learned Departmental Representative drew our attention to ground no. 3 and exceptions provided in paragraph 10(e) of CBDT Circular No. 2/2018 dated 11.07.2018. As far as merit of the issue is concerned, learned Departmental Representative relied upon the observations of the AO. 5. We have considered rival submissions and perused the material on record. As could be seen from record, based on certain information ....