TMI Blog2021 (9) TMI 112X X X X Extracts X X X X X X X X Extracts X X X X ..... ases made by the assessee in the assessment years under dispute are non genuine - HELD THAT:- The source of purchases at all stages remained doubtful. That being the case, the claim of the assessee that purchases have been made from the declared source is unacceptable - considering the fact that assessee failed to prove the source of purchases, it can be concluded that by adopting such means the a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s 2009-10, 2010-11 and 2011-12. 2. When the appeals were called for hearing no one was present on behalf of the assessee despite notice. Even, there is no application seeking adjournment either. In view of the aforesaid, we proceed to dispose of the appeals ex parte qua the assessee, after hearing the learned Departmental Representative and on the basis of material available on record. 3. Th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... In course of the re-assessment proceedings, the assessing officer raised doubt regarding certain purchases and called upon the assessee to prove the genuineness of them. The details of such purchases are as under:- Assessment Year Amount 2009-10 ₹ 88,18,716/- 2010-11 ₹ 8 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... out of the alleged non genuine purchases in each assessment year under dispute and added back to the income of the assessee. Though, the assessee contested the aforesaid disallowance before learned Commissioner of Income-tax (Appeals); however, he was unsuccessful. 6. We have considered the submissions of learned Departmental Representative and perused materials on record. It is evident, the a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ceptable. Further, considering the fact that assessee failed to prove the source of purchases, it can be concluded that by adopting such means the assessee has suppressed its true profits. In the aforesaid scenario, disallowance at 12.5%, being the profit element embedded in the alleged non genuine purchases, in our considered opinion, is fair and reasonable; hence, does not call for any interfere ..... X X X X Extracts X X X X X X X X Extracts X X X X
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