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    <title>2026 (5) TMI 938 - ITAT MUMBAI</title>
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    <description>A Revenue appeal based on information from the Investigation Wing about accommodation entries and bogus purchases was treated as falling within the Circular No. 5/2024 exception for organised tax evasion cases supported by external intelligence, so the monetary limit did not bar hearing on merits. On the substantive issue, the Tribunal followed earlier final years and applied the rule of consistency, holding that where books were not rejected and purchase and sales details were not found defective, the profit element in bogus purchases could be restricted to 0.2% of the disputed purchases. The same estimation was therefore maintained absent any material change in facts or law.</description>
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