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    <title>2025 (12) TMI 484 - ITAT AHMEDABAD</title>
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    <description>ITAT Ahmedabad allowed the assessee&#039;s appeal partly. It held that, although absence of transportation and related evidences created doubt about the genuineness of purchases, the existence of corresponding accepted sales established that real trading had occurred. Applying settled law that entire purchases cannot be disallowed even where suppliers are unverifiable, the Tribunal restricted the addition to 2% of the disputed purchases, i.e., Rs. 3,50,330/-, as profit embedded in such purchases. Since the purchases were recorded in regular books and payments were made through banking channels, the addition so sustained was treated as estimated business income, outside the ambit of s. 69C, and therefore not taxable under s. 115BBE.</description>
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      <title>2025 (12) TMI 484 - ITAT AHMEDABAD</title>
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      <description>ITAT Ahmedabad allowed the assessee&#039;s appeal partly. It held that, although absence of transportation and related evidences created doubt about the genuineness of purchases, the existence of corresponding accepted sales established that real trading had occurred. Applying settled law that entire purchases cannot be disallowed even where suppliers are unverifiable, the Tribunal restricted the addition to 2% of the disputed purchases, i.e., Rs. 3,50,330/-, as profit embedded in such purchases. Since the purchases were recorded in regular books and payments were made through banking channels, the addition so sustained was treated as estimated business income, outside the ambit of s. 69C, and therefore not taxable under s. 115BBE.</description>
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