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2022 (4) TMI 578 - AT - Income TaxDisallowance u/s. 69C on account of purchase of raw material and stores - two purchases transactions could not be substantiated by it in the course of proceedings before the lower authorities - HELD THAT:- Now when it was claimed by the assessee that it had purchased goods prior to the date of survey on 29.03.2011 and had though entered the same in the stock register, but inadvertently omitted to record the same in the purchase account, then, the onus was cast upon it to substantiate its aforesaid claim on the basis of irrefutable documentary evidence. As observed by us herein above, the assessee despite specific directions by the AO to produce the stock register wherein the receipt of goods in question were entered by him, had however, failed to do the needful. We concur with the view taken by the lower authorities that the assessee in the grab of its claim of having made purchases had in fact tried to neutralize the amount of undisclosed income that was surrendered by it in the course of the survey proceedings - we find no infirmity in the view taken by the CIT(Appeals) who had on the basis of well-reasoned order sustained the addition made by the Assessing Officer. We, thus, in terms of our aforesaid observations uphold the order of the CIT(Appeals) qua sustaining of the addition made by the Assessing Officer. - Decided against assessee.
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