On appeal by the Revenue the Hon Court held  that both the CIT(A) as well as the ITAT have come to a concurrent factual finding that assessee was a 100% export oriented unit and was purchasing goods from various parties. Assessee was getting the goods manufactured from other manufacturers to whom payments had been made through banking channel. Both authorities have accepted the fact that manufacturers were supplying the goods with details of raw-materials consumed and the batch number and the AO had not even doubted the Batch Manufacture Record (“BMR”), Goods Received Note (“GRN”), delivery challans, etc. issued by the transporter with regard to supply of goods/supply of raw-materials. The AO had not even pointed out any defect in the tally on the quantity delivered. The AO,  had not even made enquiry with the suppliers and the payment of Value Added Tax by assessee has also been ignored. Therefore, the CIT(A) and the ITAT came to a finding that the AO cannot, simply relying upon information received by the Sales Tax Department, without doing any further conclude that the purchases made by assessee were not genuine. (ITXA No. 1198 OF 2018 dt. 03/04/2024)(AY. 2010-11)