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Where alleged bogus purchases are not supported by proof of actual goods movement, but the books, sales and disclosed profits remain accepted, only the profit element embedded in those purchases may be disallowed rather than their full value. The High Court upheld the Tribunal's factual estimate of a 10 per cent disallowance, finding no legal infirmity. On reassessment, a notice under section 148A(b) need not supply every item of material held by the Assessing Officer; the prescribed reopening procedure was found to have been followed. The challenges to both the disallowance restriction and reassessment were rejected, and both cross-appeals were dismissed.
Where alleged bogus purchases are not supported by proof of actual goods movement, but the books, sales and disclosed profits remain accepted, only the profit element embedded in those purchases may be disallowed rather than their full value. The High Court upheld the Tribunal's factual estimate of a 10 per cent disallowance, finding no legal infirmity. On reassessment, a notice under section 148A(b) need not supply every item of material held by the Assessing Officer; the prescribed reopening procedure was found to have been followed. The challenges to both the disallowance restriction and reassessment were rejected, and both cross-appeals were dismissed.
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