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    <title>2026 (5) TMI 1629 - ITAT MUMBAI</title>
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    <description>Where sales are accepted and the purchases are recorded in the stock register with supporting books, an addition for alleged non-genuine purchases cannot be made on the entire purchase value. The tax consequence is confined to the profit element embedded in such purchases, because the dispute concerns the source and genuineness of the purchases rather than the existence of sales. On that basis, a 100% addition was held unsustainable and, in the factual context of diamond trading and the declared gross profit rate, the addition was restricted to 2% of the alleged non-genuine purchases, partly in favour of the assessee.</description>
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    <pubDate>Thu, 21 May 2026 00:00:00 +0530</pubDate>
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