9911796707
TMI Blog2021 (3) TMI 148X X X X Extracts X X X X X X X X Extracts X X X X ..... On the facts and in the circumstances of the case, the learned CIT erred in setting aside the assessment order u/s 263 of the Act without fully appreciating the facts of the case. 2. The learned CIT erred in setting aside the assessment order u/s 263 of the Act even though the impugned transactions were confirmed by the concerned parties in response to notice u/s 133(6). at on the facts and in the circumstances of the case, the Id CIT, Bikaner erred in not recording own satisfaction in respect of assessment order passed by the Id AO is erroneous so as it prejudicial the interest of revenue as per provision of section 263 of the Act. 3. The action of learned CIT is nothing but change of opinion, which cannot be a ground for invoking the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... x Department, it transpired that the assessee made aggregate purchases of Rs. 246.98 Lacs from an entity namely M/s Prime Star, an alleged entry provider belonging to Bhanwarlal Jain Group. Accordingly, the assessee was directed to substantiate these transactions. 3.2 In defense of purchase transactions, the assessee submitted purchase invoices, ledger confirmations, copy of ITR-V of the supplier, its audited financial statements, bank statements highlighting payment through banking channels. It was submitted that goods purchased from this party was one to one identified and sold locally as well as exported outside India. The assessee also pleaded that only the profit margins embedded in these transactions could be taxed. 3.3 The Ld. AO, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... aforesaid, the assessee is in further appeal before us challenging the validity of revisional jurisdiction as exercised by Ld. Pr.CIT u/s 263. 5. Upon perusal of assessment order, we find that issue of suspicious purchases was under due consideration of Ld.AO. The requisite purchase details as to purchases made from M/s Prime Star were called-for by Ld. AO from the assessee during the course of assessment proceedings. The notice u/s 133(6) was issued to confirm the transactions. The assessee submitted various details as well as documentary evidences in the shape of purchase invoices, ledger confirmations, copy of ITR-V of the supplier, its audited financial statements, bank statements highlighting payment through banking channels. It was a ..... X X X X Extracts X X X X X X X X Extracts X X X X
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