2020 (5) TMI 695

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.... Accountant Member: The present Appeal has been filed by the assessee against the order of Ld. Commissioner of Income Tax (Appeals) - 22 in short referred as 'Ld. CIT(A)', Mumbai, dated 11.09.18 for Assessment Year (in short AY) 2010-11. 2. The brief facts of the case are that assessee filed its return of income on 14.10.2010 declaring total income of Rs. 3,86,900/-. The return was processed....

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....IT(A) is too high and he relied upon the various judgments passed by the Coordinate Bench of ITAT, wherein the bench has estimated @ 3% of the alleged bogus purchases. 6. On the other hand, Ld. DR relied upon the orders passed by revenue authorities and submitted that estimation made by Ld. CIT(A) should be sustained. 7. Considering the rival contentions and material placed on record, w....

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....ing revealed that all the suppliers were engaged in carrying out only paper transactions without actual delivery of material. The complete onus to prove the purchases conclusively was on assessee, which has remained un-discharged. In such a scenario, the addition, which could be made, was to account for profit element embedded in these purchase transactions to factorize for profit element ear....