Held that the assessee having furnished documentary evidence to substantial that the contractors to whom packaging of some products was outsourced had genuine business, and the CIT(A) having recorded finding of fact that the transactions between the assessee and the said parties cannot be treated as non-genuine after verifying all the materials available on record, there is no valid reason to differ with the factual finding of the first appellate authority. Tribunal also held that the fact that no incriminating document indicative of out of book purchases of raw materials was found in the course of search and seizure operations either from the assessee’s premises or from the premises of its supplies nor any discrepancy was found in the stock position of raw materials, semi finished goods or finished goods, the impugned addition made by the AO towards the alleged out of books purchases on the basis of input-output ratio derived during the trial run is not sustainable (AY. 2013-14 to 2019-20)
DCIT v. Everest Food Product (P) Ltd. (2025) 237 TTJ 913 (Mum)(Trib)
S. 153A: Assessment-Search-Undisclosed income-Manufacturing facility of the assessee does not make it feasible for packaging of the products in small packets-First appellate authority has rightly appreciated the veracity of the evidence furnished by the assessee after verification-Input-output ratio-Order of CIT(A) was affirmed.[S. 132]
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