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    <title>2017 (12) TMI 858 - ITAT MUMBAI</title>
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    <description>Reopening of assessment was sustained where the Assessing Officer relied on tangible material from the Sales Tax Department and DGIT (Investigation) showing possible hawala and accommodation entries, because at the reopening stage only a reason to believe is required, not conclusive proof. In the bogus purchase dispute, sales were accepted but the suppliers were found non-existent and the assessee failed to produce confirmations, transport evidence, or the parties themselves; on those facts, only the profit element embedded in the purchases was taxable. The 12.5% estimate of bogus purchases was upheld as reasonable, and the reassessment and estimated disallowance were confirmed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=352589</link>
      <description>Reopening of assessment was sustained where the Assessing Officer relied on tangible material from the Sales Tax Department and DGIT (Investigation) showing possible hawala and accommodation entries, because at the reopening stage only a reason to believe is required, not conclusive proof. In the bogus purchase dispute, sales were accepted but the suppliers were found non-existent and the assessee failed to produce confirmations, transport evidence, or the parties themselves; on those facts, only the profit element embedded in the purchases was taxable. The 12.5% estimate of bogus purchases was upheld as reasonable, and the reassessment and estimated disallowance were confirmed.</description>
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