2014 (6) TMI 967

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....ondent by: Shri Shrikant Namdeo O R D E R PER N.K. BILLAIYA, AM: These two appeals by the assessee for two different assessment years i.e. 2006-07 and 2008-09 are directed against two separate orders of the Ld. CIT(A)-24, Mumbai dt.12.03.2012. In both these appeals the assessee has raised one common issue though quantum may defer, both these appeals were heard together and dispose of by t....

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....n, it came to the notice of the survey party that the aforestated persons were engaged exclusively in the activity of issuing accommodation bills on which they received commission at the rate of 1%. It was also noticed that assessee is also one of the persons who had made purchases from the aforementioned parties. The assessee was asked to justify his purchases from the aforementioned parties. ....

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....ny favour from the AO who was of the opinion that the assessee has availed bogus bills amounting to Rs. 10,59,265/-. The AO went on to treat the purchases amounting to Rs. 10,59,265 from the said Shri Rakeshkumar M. Gupta and his family members as bogus and accordingly added the same to the returned income of the assessee and completed the assessment. 3. Aggrieved by this, the assessee carried ....

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....sed the orders of the lower authorities. We find that the entire addition has been made on the statement of one Shri Rakeshkumar M. Gupta and his family members. It is the allegation of the Revenue that the said family members were issuing accommodation bills to the assessee. The AO accordingly went on to treat the entire purchases as bogus purchases. However, we find that the sales made by the as....