TaxTMI 
TaxTMI 
2026 (3) TMI 787
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....Income Tax Act, 1961 (hereinafter referred to as the "Act") and relates to Assessment Year (A.Y.) 2018-19. 2. The grounds of appeal raised by the assessee read as under: "1. In his order dated 21/03/2024, the Ld. AO has erred in law by making an addition of Rs. 76,34,197/- u/s 69C rws 115BBE without identifying the facts of the case and real nature of transactions involved. The CIT A has erred in law by confirming the same. 2. Any other grounds of appeal shall be submitted at the time of hearing." 3. The solitary issue in the present appeal relates to disallowance made of purchases amounting to Rs. 76,34,197/- u/s.69C of the Act, treating them to bogus in nature. The orders of the authorities below reveal that the as....
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....gs, the appellant has filed the written submission and the same is perused by the undersigned. The appellant has argued that purchases made from M/s. Uttam Steel is genuine in the instant case, the appellant had never proved the movement of goods with solid documentary evidences either during the course of assessment proceedings or during the appellate proceedings. However, the onus vests with the appellant to prove the movement of goods by submitting the relevant documents such as delivery challan/packing list along with the inward/outward entry, goods received note or delivery challan (GRN) . . . 7.5 In the written submission filed before the CIT(A), the appellant has not furnished any records which to ....
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....egister were also filed as follows: i. Purchase Invoice from M/s. Uttam Metals ii. Weigh receipt at the time of outward of goods from M/s. Uttam Metals iii. Weight receipt of the lorry at the time of inward at assessee's place iv. sale invoice of the same goods v. Delivery challan for sale of goods 7.1 All these documents filed along with reply filed by the assessee to the AO dated 16.12.2023 were placed before us at paper book page nos. 31 & 34. The assessee also filed before us screenshot of the Income Tax Portal reflecting the filing of impugned documents during the course of assessment proceedings at paper book Page No.31. 7.2 It is clear from the above that the Ld. CIT(A)'s finding of ....
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.... Metals confirming sales made to the assessee during the impugned year, iv. Copy of bank statement of the assessee reflecting payment made to M/s. Uttam Metals for the purchase made v. stock register showing inward and outward movement of materials from M/s. Uttam Metals. vi. Complete set of documents substantiating the inward and outward method stock received from M/s. Uttam Metals being (a) purchase invoice of M/s. Uttam Metals, (b) weight receipt at the time of upward from goods for M/s. Uttam Metals, (c) weight receipt of the lorry at the time of inward at assessee's place, (d) sale invoice of the same goods & (e) delivery challan for sale of goods. 9. Further we find that though the case of the assessee wa....