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    <title>2026 (1) TMI 358 - ITAT DELHI</title>
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    <description>Whether an addition for alleged bogus purchases could be sustained when sales were not disputed was the dominant issue. The AO identified deficiencies in the assessee&#039;s purchase function and treated the purchases as lacking credibility, but did not point to any infirmity in the corresponding sales reported in the financial statements. On this basis, the CIT(A) held that only the excess of the estimated addition over the income already offered in the return was warranted as a just and fair estimation, rather than a full disallowance. The ITAT upheld this reasoning and dismissed the Revenue&#039;s appeal.</description>
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      <link>https://www.taxtmi.com/caselaws?id=784602</link>
      <description>Whether an addition for alleged bogus purchases could be sustained when sales were not disputed was the dominant issue. The AO identified deficiencies in the assessee&#039;s purchase function and treated the purchases as lacking credibility, but did not point to any infirmity in the corresponding sales reported in the financial statements. On this basis, the CIT(A) held that only the excess of the estimated addition over the income already offered in the return was warranted as a just and fair estimation, rather than a full disallowance. The ITAT upheld this reasoning and dismissed the Revenue&#039;s appeal.</description>
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