2020 (1) TMI 1314

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.....343- 345/Mum/2019 common order dated 20/08/2019. Accordingly, the appeals have come up for fresh hearing before this bench. 1.2 As evident from grounds of appeal raised before us, the grievance of the assessee in all the three years is common i.e. estimated additions on account of alleged bogus purchases. Although the assessee has also challenged the reassessment proceedings on legal grounds, however, these grounds have not been pressed before us by learned Authorized Representative for assessee and accordingly, the same stands dismissed. 1.3 We have carefully heard the arguments advanced by both the representatives and perused relevant material in record including judicial pronouncements cited before us in support of the arguments. ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....onfirm the transactions. The field inquiries established that none of the parties was existing at the given addresses. Finally, not satisfied with assessee's submissions / explanations, the stated purchases were disallowed and added back to the income of the assessee. 3. The learned first appellate authority after examining the factual matrix in the light of various judicial pronouncements rendered by higher authorities, came to a conclusion that when the sales were accepted, entire purchases could not be disallowed but what needed to be taxed was the profit element embedded in such transactions. The same was estimated @12.5% of alleged bogus purchases. Still aggrieved, the assessee is under further appeal before us. 4. After careful ....