TMI Blog2017 (7) TMI 774X X X X Extracts X X X X X X X X Extracts X X X X ..... f all the 23 parties from whom purchases were made by PRPL. The Assessee had also placed detailed evidence for each of the said 23 parties. This was examined afresh by the ITAT. As an exhaustive and detailed factual enquiry has been undertaken, both, by the CIT(A) and the ITAT to arrive at concurrent factual findings which have not been shown to be perverse. - Decided against revenue. - ITA 52/2015 - - - Dated:- 5-7-2017 - S. Muralidhar And Prathiba M. Singh, JJ. For the Appellant : Mr. Rahul Chaudhary, Standing Counsel For the Respondent : None ORDER 1. This is an appeal by the Revenue under Section 260A(1) of the Income Tax Act, 1961 ( Act ) against the order dated 16th May, 2014 of the Income Tax Appellate Trib ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ch, 2012 after concluding that the entire disallowance is based on third party information gathered by the Investigation Wing of the Department, which have not been independently subjected to further verification by the AO . 6. The Revenue's consequent appeal was dismissed by the ITAT by the impugned order. The conclusions arrived at by the ITAT were as under: i. In support of the claim of purchases made by PRPL, photocopies of the sale invoices issued to it along with the confirmed copy of account with PAN for the financial years 2007-08 as well as 2008-09 were filed. Copies of the VAT returns wherever made available of the 23 parties which had sold the material to PRPL and which in turn sold the material to the Assessee were a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ore, could not be disregarded. In fact, the AO had examined the bank accounts of not only PRPL but also of the 23 concerns to whom payments were made by PRPL. v. The Assessee had discharged the burden of proving the identity of PRPL and the genuineness of the purchases made by the Assessee from it. 7. Having perused the impugned orders of the CIT(A) and the ITAT, and having heard learned counsel for the parties, the Court is satisfied that an exhaustive and detailed factual enquiry has been undertaken, both, by the CIT(A) and the ITAT to arrive at concurrent factual findings which have not been shown to be perverse. 8. No substantial question of law arises from the impugned order of the ITAT. The appeal is, accordingly, dismis ..... X X X X Extracts X X X X X X X X Extracts X X X X
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