Non-genuine metal purchases with undisputed corresponding sales warrant an addition only for the profit element embedded in those purchases, rather than their full value. ITAT treated the business and dispute as materially similar to the immediately preceding year and, as Revenue showed no material factual difference, followed the prior-year estimation. The addition was reduced from 12.5% to 5% of the disputed purchases. Reopening grounds remained open, and consequential interest was to be recomputed.
Non-genuine metal purchases with undisputed corresponding sales warrant an addition only for the profit element embedded in those purchases, rather than their full value. ITAT treated the business and dispute as materially similar to the immediately preceding year and, as Revenue showed no material factual difference, followed the prior-year estimation. The addition was reduced from 12.5% to 5% of the disputed purchases. Reopening grounds remained open, and consequential interest was to be recomputed.
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