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    <title>2020 (11) TMI 926 - ITAT AMRITSAR</title>
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    <description>Where sales were accepted but purchases were found non-genuine, only the profit element embedded in those purchases was treated as taxable and the matter was remitted for recomputation using the gross profit rate of genuine purchases. The corresponding sundry creditor balances were not treated as unexplained credits under section 68 because the liability had to be viewed in light of the actual source of goods. A disallowance under section 40A(3) was not sustained in the absence of proof of a single cash payment breaching the statutory limit. Conversion of 24 carat gold into 22 carat ornaments was regarded as manufacture for section 80IB purposes, and the related penalty under section 271(1)(c) was deleted where the remaining addition was only estimated.</description>
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      <description>Where sales were accepted but purchases were found non-genuine, only the profit element embedded in those purchases was treated as taxable and the matter was remitted for recomputation using the gross profit rate of genuine purchases. The corresponding sundry creditor balances were not treated as unexplained credits under section 68 because the liability had to be viewed in light of the actual source of goods. A disallowance under section 40A(3) was not sustained in the absence of proof of a single cash payment breaching the statutory limit. Conversion of 24 carat gold into 22 carat ornaments was regarded as manufacture for section 80IB purposes, and the related penalty under section 271(1)(c) was deleted where the remaining addition was only estimated.</description>
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