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vi). The Ld CIT(A) analyzed the issues his order and held that there is no direct evidence brought on record by the AO that the purchases were bogus and further, the frozen meat is exported to Gulf Countries, Other Southern Asian countries and license of ASPEDA required for such meat processing were in place with the assessee and no adverse view has been drawn by such authorities.

vii). It was further held that the AO has mis-interpreted the statement of parties and drawn a wrong conclusion about the supplies of raw Boneless meat and in respect of Israr Ahmad, it was a case of mistaken identity and similarly other parties have also not denied any sales of raw boneless meat and for Elahi Trading Co., confirmed copy of account had been submitted, where sales of Raw Boneless Meat had been recorded. The CIT(A) also held at page 21 that the cases of the suppliers were also simultaneously taken by the AO and their assessments had been framed u/s 147/143(3) as per chart reproduced at page 21 of the order of CIT(A). It was further stated that the assessee have filed reconciliation of GST paid, along with annual return of GST and purchases were backed by invoices and all the payments were being made by cheque and further no conclusive evidence had been led that the purchases were bogus and the reliance was made by the CIT(A) on various case laws of Hon'ble Apex Court, High Courts and different Benches of the ITAT at pages 23 to 26 of the order and the CIT(A) has given his finding at para 7.8 of the order, in which, he has held that allegation of round tripping of funds is not substantiated at all and also the sales have not been doubted, the stock record have not been commented adversely and sales and purchases are two sides of same coin and hence to dispute the purchases from such major suppliers in the hand of assessee and treating the same as bogus purchases would not be justified and, thus, deleted the addition of Rs. 90,95,46,485/-.

IX. There is no evidence of the cash withdrawals by Mr. Irfan taken/handed over to the assessee.

X. The quantitative detail from Mr. Irfan giving the detail of 'Live Animals' bought from Mr. Irfan and GST have been paid, the sales have not been doubted and then by relying upon the various judgments, the finding has been recorded in para 8.11, page 48 and which is being relied upon.

18. Considered the rival submissions and material available on record. We observed from the assessment order that the AO observed from the records that assessee had purchased raw boneless meat (RBM) from certain parties, the list of parties is reproduced at para 7.1 of the assessment order. Since the assessee purchased the above RBM from parties, which are not the regular method of processing the meat and meat products by the assessee, he was of the view that this fact was unearthed only during the search, hence, it is incriminating material. Further, he observed that as per the manual of APEDA, the assessee had to get the certificate from the agency certified by APEDA on the fitness of the meat supplied by the assessee to the overseas customers, which should be fit for human consumption. Since the assessee has procured the RBM from certain suppliers, he doubted the documents relating to pre-shipment certificate issued by the recognized laboratory on the purchases made by the assessee, particularly the supply of RBM from the listed suppliers.AO observed in his order that "if the assessee is purchasing Raw Boneless Meat, how it would ensure that meat derived from only healthy animals is exported". With the above observation, he recorded the statement of Mr. Zulfiquar, who had not denied the above purchases, it was submitted that the assessee tried the above module of processing meat, may before cost cutting, which is slightly deviated from the regular method of processing the meat in their slaughterhouse. In the regular method, the assessee buys the livestock and does all the process of meat cutting to packing for the purpose of export. In this method, the assessee tried to eliminate the above process of cutting and cleaning of meat from the suppliers and repack them in the assessee's facility for the purpose of export.

19. The AO had wrongly observed that inspection certificates are must for procurement of RBM. It does not matter whether the meat is processed at assessee's slaughterhouse or outside, the final meat before packing for export must be certified by the approved lab by the APEDA. Without the above certificates, the assessee would not have exported the meat. We observed that the AO had accepted the export sales and only raises doubt on the procurement method adopted by the assessee, it is the decision of the businessman, who will decided where and how to procure the raw material for the purpose of its process/business. It is ultimately the final product which has to meet the standard fixed by the APEDA. The AO has merely doubted the procurement process and basically rejected the whole purchase of RBM from the suppliers, all of them and the assessee had accepted the trial run of the above method. The above aspect was aptly appreciated by the Ld CIT(A) in his order based on the documents submitted before him.

23. With regard to round tripping of funds, Ld CIT(A) observed that the AO had inferred on the basis of purchase of RBM, which is not the regular method of processing of meat, based on that he formed the algorithm and hypothesis without their being any material in its support, none of the material reproduced in assessment order like ledger copy, WhatsApp messages etc are not related to the impugned assessment year. After considering the relevant issues, he came to the conclusion that the purchases recorded by the assessee are genuine purchases and not bogus.