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2022 (2) TMI 914 - AT - Income TaxBogus/unaccounted purchases - HELD THAT:- Apart from that Bll No. 1511 dated 06.07.2011 along with above said annexures were filed before the lower authorities bank payments details were falso filed by the assessee. In our considered opinion that assessee has discharged its onus merely on the information received from the Investigation Wing, addition cannot be made as assessee has filed all the relevant details which proved case of the assessee beyond any reasonable doubt that assessee has purchased the paddy after completing the formality and making the payment through banking channel and all relevant details were filed before the lower authorities. However, no unaccounted purchase has been made by the assessee. Addition on the basis of trade GP @ of 5% - assessee has sold paddy for which the assessee firm had received cash payment in lieu of that sales - A.R. filed an application under Rule 46A along with a certificate issued by the Punjab State Civil Supplies Corporation Ltd. dated 09.09.2021 wherein it is mentioned that as per record of this office rice mill named M/s. Tata Rice Mills, Zira was allotted to PUNSUP for custom milling during Crop year 2008-09 to 2020-21 and nothing is recoverable from said firm till date as per instruction/guidelines issued by Government and directions given by Honourable Courts - HELD THAT:- There is no dispute between PUNSUP and above said firm. The Ld. A.R. certified certificate true copy of the said letter, therefore we admit the same. Since no corroborated evidence has been cited against the assessee by the lower authorities and it was alleged by the Assessing Officer that unaccounted sales were made to PUNSUP Now certificate dated 09/09/2021has been issued by the District Manager PUNSUP, Ferozpur when both the parties are denying any transaction then how addition can be sustained. So in the absence of any concrete evidence against the assessee such addition cannot be sustained. Thus we allow this ground of appeal
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