TMI Blog2019 (7) TMI 1995X X X X Extracts X X X X X X X X Extracts X X X X ..... agents, but were traders themselves - HELD THAT:- The remand report of AO was received by the CIT(A) on 02.08.2018, wherein, we find that the AO has reiterated what was available in the assessment order and nothing more than that after retention of the additional evidences, surprisingly, for nearly eight years and the reason for that may be best known to him. On perusal of the remand report, as reproduced in the appellate order, the only contention of AO is that the suppliers from whom the assessee had purchased hides and they are not butchers. Even though it was purchased from those suppliers, those suppliers would have purchased from the butchers only and there is no other go and nothing is prevented the supplier to function as an age ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ) of the Act. Subsequently, the assessment was reopened under section 147 of the Act consequent to the survey conducted under section 133A of the Act on 03.11.2009, wherein, the impounded materials show that the assessee had purchased raw materials by cash payment amounting to ₹.99,50,546/-, which is in violation of the provisions of section 40A(3) of the Act. After considering the submissions of the assessee during the course of reassessment proceedings, the Assessing Officer completed the assessment under section 143(3) r.w.s. 147 of the Act and determined the income of the assessee at ₹.22,73,612/- after making disallowances. On appeal, after considering the written submissions of the assessee, the ld. CIT(A) confirmed the di ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... aim of exemption under Rule 6DD(f) of the Act. The Assessing Officer also rejected the claim of exemption under Rule 6DD which exempts payments made to agents on behalf of the buyers for the reason that the said parties from whom the assessee purchased were not agents, but were traders themselves. During the course of appellate proceedings, the assessee provided letters from certain suppliers of raw skin in support of his submission. Accordingly, the ld. CIT(A) forwarded the same to the Assessing Officer for verification and submission of report vide his letter dated 01.09.2010. The remand report of the Assessing Officer was received by the ld. CIT(A) on 02.08.2018, wherein, we find that the Assessing Officer has reiterated what was availab ..... X X X X Extracts X X X X X X X X Extracts X X X X
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