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    <title>2018 (10) TMI 1857 - ITAT MUMBAI</title>
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    <description>Alleged bogus purchases cannot be disallowed in full where the purchases were consumed in contract work, sales were accepted, payments were routed through banking channels, and the adverse sales-tax material was uncorroborated; only the profit element embedded in the purchases can be taxed, and the 12.5% restriction was upheld. Under section 40A(2)(b), disallowance applies only to the excessive or unreasonable portion paid to a specified person, so a blanket disallowance is impermissible; the 20% partial disallowance was sustained. Reconciliation of purchase differences and uncorroborated loose papers or laptop printouts could not justify additions under sections 69 or 69C, so the deletions were upheld.</description>
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    <pubDate>Thu, 04 Oct 2018 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=291570</link>
      <description>Alleged bogus purchases cannot be disallowed in full where the purchases were consumed in contract work, sales were accepted, payments were routed through banking channels, and the adverse sales-tax material was uncorroborated; only the profit element embedded in the purchases can be taxed, and the 12.5% restriction was upheld. Under section 40A(2)(b), disallowance applies only to the excessive or unreasonable portion paid to a specified person, so a blanket disallowance is impermissible; the 20% partial disallowance was sustained. Reconciliation of purchase differences and uncorroborated loose papers or laptop printouts could not justify additions under sections 69 or 69C, so the deletions were upheld.</description>
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      <pubDate>Thu, 04 Oct 2018 00:00:00 +0530</pubDate>
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