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    <title>2026 (5) TMI 557 - ITAT MUMBAI</title>
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    <description>Where alleged bogus purchases are not supported by delivery evidence and the supplier transaction is unproved, but the corresponding sales are accepted and the goods are shown to have been sold onward, the addition is ordinarily confined to the embedded profit element rather than the full purchase value. On those facts, the Tribunal deleted the impugned addition because the assessee had already voluntarily offered 12.5% of the disputed purchases and no further material justified a higher addition. The separate challenge to penalty proceedings under section 271(1)(c) was dismissed as premature because no final penalty determination had yet been made.</description>
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      <link>https://www.taxtmi.com/caselaws?id=791355</link>
      <description>Where alleged bogus purchases are not supported by delivery evidence and the supplier transaction is unproved, but the corresponding sales are accepted and the goods are shown to have been sold onward, the addition is ordinarily confined to the embedded profit element rather than the full purchase value. On those facts, the Tribunal deleted the impugned addition because the assessee had already voluntarily offered 12.5% of the disputed purchases and no further material justified a higher addition. The separate challenge to penalty proceedings under section 271(1)(c) was dismissed as premature because no final penalty determination had yet been made.</description>
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