2026 (7) TMI 1030

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.... purchased from various companies. The assessee filed his return of income on 15/02/2022. The case of the assessee was selected for scrutiny since the purchases are from non-filers or filed non-business ITR or shown a lower turnover in the ITR. Notices u/s. 143(2) as well as u/s. 142(1) were issued. The assessee also filed the details and documents of the sellers. The AO through the verification unit verified the three sellers of the assessee who have denied any such transactions with the assessee. The report of the verification unit states that the alleged two sellers are aged and not doing any business and one seller is working as a labourer. The verification unit physically verified the sellers since they have not responded to the notice....

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....ortunity to the assessee to rebut the same. The Ld.AR also submitted that the assessee was not provided an opportunity to cross examine the sellers. Alternatively, the Ld.AR submitted that the AO had erred in denying the purchase expenditure when the corresponding sales are accepted. The Ld.AR filed two paper books enclosing the ledger extract of the parties and also the stock register by way of additional evidences and also filed an application to accept the additional evidence and prayed to allow the appeal.; 6. The Ld.DR on the other hand submitted that the AO had done proper enquiries and based on that arrived a conclusion that the purchases are bogus and prayed to dismiss the appeal. 7. We have heard the arguments of both sides a....