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    <title>2026 (7) TMI 620 - ITAT AHMEDABAD</title>
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    <description>Where alleged bogus purchases were supported by accepted turnover, unchallenged sales, banking-channel payments and documentary material, and the books were not rejected under section 145(3), only the embedded profit element could be estimated; the addition was sustained at 3.5% of the disputed purchases. Reopening under sections 148A and 147 was also upheld because it was based on information, post-search enquiries and the supplier&#039;s statement, and the record did not show direct reliance on incriminating seized material requiring proceedings under section 153C instead. The assessee failed on both issues, and the connected appeals and cross-objections were dismissed.</description>
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    <pubDate>Tue, 07 Jul 2026 00:00:00 +0530</pubDate>
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      <title>2026 (7) TMI 620 - ITAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=794734</link>
      <description>Where alleged bogus purchases were supported by accepted turnover, unchallenged sales, banking-channel payments and documentary material, and the books were not rejected under section 145(3), only the embedded profit element could be estimated; the addition was sustained at 3.5% of the disputed purchases. Reopening under sections 148A and 147 was also upheld because it was based on information, post-search enquiries and the supplier&#039;s statement, and the record did not show direct reliance on incriminating seized material requiring proceedings under section 153C instead. The assessee failed on both issues, and the connected appeals and cross-objections were dismissed.</description>
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