TMI Blog2022 (5) TMI 688X X X X Extracts X X X X X X X X Extracts X X X X ..... made from unexplained sources - HELD THAT:- It could thus be seen that the entire issue is based on facts. The Commissioner (Appeals) and the Tribunal concurrently came to findings of facts which are not perverse. The Tribunal in the above quoted portion of the order has accepted the explanation of the assessee that the entire purchase was made from M/s. Maximum Synthetics Pvt. Ltd. and it was al ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... CIT(A) by deleting the addition of Rs.7,82, 95,551/- as made by the AO u/s 69 of the Act, 1961 on account of purchases made but not recorded the same in regular books of account. 2. Whether the ITAT has failed to appreciate the fact that the purchase of finished fabrics to the tune of Rs.7,82,95,551/- was not entered in the books of accounts and also sale thereof were made out of books of acco ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ecord, we noticed that the entire addition made by the AO is on the basis of purchase details of finished fabrics above Rs.1,00,000/- submitted by the assessee vide letter dated 09.11.2018 along with the ledger account and sample bills. In this letter details of 10 parties from whom purchase of finished fabrics was made is given. This list includes name of six parties from whom no purchases were i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... h as the banker may take a view that assessee is mainly dependent on purchases from one supplier only and therefore the said bifurcation was provided to the bank which was also submitted to the AO but the fact remains is that no purchase is made from these six parties and therefore, the same is not part of books of accounts. It could thus be seen that the entire issue is based on facts. The Co ..... X X X X Extracts X X X X X X X X Extracts X X X X
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