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TMI Blog2019 (11) TMI 323X X X X Extracts X X X X X X X X Extracts X X X X ..... gainst the order dated 4th June 2018, passed by the learned Commissioner of Income Tax (Appeals)-2, Pune, for the assessment year 2009-10. 2. Ground no.1.2, is not pressed, hence dismissed. 3. Ground no.1.7, being general in nature does not require adjudication. 4. The rest of the grounds are on the issue of addition of Rs. 11,66,082, made on account of non-genuine purchases. 5. Brief facts ar ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t proceedings, the Assessing Officer called upon the assessee to prove the genuineness of purchases made by furnishing corroborating evidences. Further, to verify the genuineness of such purchases, the Assessing Officer conducted independent enquiry by issuing notices under section 133(6) of the Act to the concerned parties. However, as alleged by the Assessing Officer, all such notices returned b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 6. The learned Authorised Representative submitted, in the course of assessment proceedings, the assessee had furnished purchase bills, payment details, quantitative tally of purchases, consumption and sales with party wise details. He submitted, the Assessing Officer has not disputed the consumption of raw materials and sale of finished products. In such circumstances, disallowance of entire pur ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cannot be completely overlooked. Thus, a reasonable presumption can be drawn that the assessee may not have purchased the goods from the declared source but has purchased them from third parties and for regularizing such purchases has obtained accommodation bills. In such circumstances, the entire purchases made by the assessee cannot be disallowed and added back to the income of the assessee. Rat ..... X X X X Extracts X X X X X X X X Extracts X X X X
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