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    <title>2024 (12) TMI 1756 - ITAT DELHI</title>
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    <description>Where an addition was based on an incorrect assumption that the assessee had purchase and sales transactions with a third party, rejection of books under section 145(3) could not be sustained. The record showed no such transactions, the assessee had filed party-wise details, and there was no material of bogus or hawala entries attributable to the assessee. In the absence of valid confrontation of the statements relied upon, estimating profit by applying an arbitrary gross profit rate was unjustified. The books rejection and consequential profit addition were therefore not sustainable and were deleted.</description>
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      <link>https://www.taxtmi.com/caselaws?id=468217</link>
      <description>Where an addition was based on an incorrect assumption that the assessee had purchase and sales transactions with a third party, rejection of books under section 145(3) could not be sustained. The record showed no such transactions, the assessee had filed party-wise details, and there was no material of bogus or hawala entries attributable to the assessee. In the absence of valid confrontation of the statements relied upon, estimating profit by applying an arbitrary gross profit rate was unjustified. The books rejection and consequential profit addition were therefore not sustainable and were deleted.</description>
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