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    <title>2024 (4) TMI 981 - ITAT MUMBAI</title>
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    <description>ITAT Mumbai held that when both suppliers are allegedly bogus, comparing rates between them is inappropriate as both transactions are tainted. The CIT-A&#039;s approach of calculating additions based on rate differences between bogus suppliers was rejected. The tribunal noted that without genuine purchase transactions for comparison, precedents with varying addition rates (1%-12.5%) couldn&#039;t be applied blindly. Following the assessee&#039;s earlier years where CIT-A restricted additions to 3% of bogus purchases without revenue dispute, the tribunal found it reasonable to maintain the same 3% addition rate. The assessee&#039;s appeal was partly allowed.</description>
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      <title>2024 (4) TMI 981 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=751800</link>
      <description>ITAT Mumbai held that when both suppliers are allegedly bogus, comparing rates between them is inappropriate as both transactions are tainted. The CIT-A&#039;s approach of calculating additions based on rate differences between bogus suppliers was rejected. The tribunal noted that without genuine purchase transactions for comparison, precedents with varying addition rates (1%-12.5%) couldn&#039;t be applied blindly. Following the assessee&#039;s earlier years where CIT-A restricted additions to 3% of bogus purchases without revenue dispute, the tribunal found it reasonable to maintain the same 3% addition rate. The assessee&#039;s appeal was partly allowed.</description>
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