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2021 (5) TMI 340 - AT - Income TaxUnexplained purchases - disallowance on account of difference in the purchases (Imports) and on account of difference in the custom duty - CIT(A) observed that the assessee had not been able to reconcile the difference in the import value as declared in its ITR and the data available on the CBEC tab and that the onus to reconcile the difference in figure of purchase through import remained woefully un-discharged - HELD THAT:- In the present case, it appears that the additional evidence furnished by the assessee particularly this facts that the goods dispatched by the Chinese Firm were not according to the specification, the same were not received, therefore, there was no question of making the payment had not been considered in right perspective - not clear as to whether the assessee furnished the reconciliation statement either before the A.O. or before the Ld. CIT(A) and explained satisfactorily the difference in the purchase found entered in the books of account and as mentioned in the CBEC Export Import Summary tab. We deem it appropriate to set aside this issue back to the file of the A.O. to be adjudicated afresh in accordance with law after providing due and reasonable opportunity of being heard to the assessee. Appeal of the assessee is allowed for statistical purposes.
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