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    <title>2012 (6) TMI 287 - ITAT DELHI</title>
    <link>https://www.taxtmi.com/caselaws?id=213967</link>
    <description>The Tribunal ruled in favor of the assessee, holding that the disallowance under Section 40A(2)(a) was not justified as the purchases were made at market rates and not excessive. Additionally, the rejection of the assessee&#039;s books and the application of a Gross Profit rate by the Assessing Officer were deemed arbitrary and lacking concrete evidence. The Tribunal found no support for the allegation that the assessee was a shell company or that transactions were not at arm&#039;s length. Consequently, the Tribunal deleted the additions made by the Assessing Officer and allowed the assessee&#039;s appeal.</description>
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    <pubDate>Fri, 29 Apr 2011 00:00:00 +0530</pubDate>
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      <title>2012 (6) TMI 287 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=213967</link>
      <description>The Tribunal ruled in favor of the assessee, holding that the disallowance under Section 40A(2)(a) was not justified as the purchases were made at market rates and not excessive. Additionally, the rejection of the assessee&#039;s books and the application of a Gross Profit rate by the Assessing Officer were deemed arbitrary and lacking concrete evidence. The Tribunal found no support for the allegation that the assessee was a shell company or that transactions were not at arm&#039;s length. Consequently, the Tribunal deleted the additions made by the Assessing Officer and allowed the assessee&#039;s appeal.</description>
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      <pubDate>Fri, 29 Apr 2011 00:00:00 +0530</pubDate>
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