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2020 (3) TMI 1073 - AT - Income TaxDisallowance u/s 14A r.w.r 8D - CIT-A deleted the addition - AR submitted that the assessee has not received any exempt income during the year under consideration - HELD THAT:- CIT (A) has given a categorical finding that there is no exempt income received by the assessee during the year under consideration. This fact was not disputed by the Revenue. Therefore, the CIT(A) has rightly deleted this disallowance in view of the Cheminvestment Ltd. [2015 (9) TMI 238 - DELHI HIGH COURT] . Thus, Ground No. 1 of the Revenue’s appeal is dismissed. Addition u/s 69C - Bogus purchases - purchases were not genuine and all the notices u/s 133(6) issued to parties were returned undelivered - AR submitted that all the export receipts are credited in the bank accounts where from the withdrawals were made for the disbursement of purchase and other expenses - CIT-A deleted the addition - HELD THAT:- ale of the assessee was never doubted by the Assessing Officer. As regards the purchase from the records as mentioned in the Assessment Order itself, was found that quantitative tally of purchases of meat and exports and the same was reflected in the credit column of the bank account of the assessee. It is not a case of the Assessing Officer that payments against purchases have been made by the assessee out of books of accounts. The contention of the Ld. DR are also not tenable as the assessee filed the details of the parties from whom purchases were made and the same is mentioned in the Assessment Order itself. The CIT(A) has also given categorical finding that only 20% of the purchases where disallowed on account of cash payment which was duly reflected in the books of account of the assessee - there is no need to interfere with the findings of the CIT(A). The appeal of the Revenue is dismissed.
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