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    <title>2017 (8) TMI 1658 - ITAT PUNE</title>
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    <description>Reopening under section 147 was upheld because the assessee did not substantiate the challenge with material showing the reassessment was invalid. In relation to alleged bogus purchases from hawala dealers, the sales were accepted and the corresponding inflow of goods could not be ignored, so the entire purchase amount was not added as income. The proper approach was estimation of the profit element embedded in such purchases, and the disallowance was restricted to 10% of the alleged bogus purchases as a fair estimate.</description>
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      <link>https://www.taxtmi.com/caselaws?id=301138</link>
      <description>Reopening under section 147 was upheld because the assessee did not substantiate the challenge with material showing the reassessment was invalid. In relation to alleged bogus purchases from hawala dealers, the sales were accepted and the corresponding inflow of goods could not be ignored, so the entire purchase amount was not added as income. The proper approach was estimation of the profit element embedded in such purchases, and the disallowance was restricted to 10% of the alleged bogus purchases as a fair estimate.</description>
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