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2021 (12) TMI 923

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....J. Sethi ORDER PER C.N. PRASAD (JM) 1. These three appeals are filed by the assessee against different orders of the Learned Commissioner of Income Tax (Appeals)-20, Mumbai [hereinafter in short "Ld.CIT(A)"] for the A.Ys. 2009-10, 2010-11 and A.Y. 2013-14 in estimating the Gross Profit element from the purchases made from various parties referred to in the Assessment Order at 12.5% 2. ....

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....abrics. The Tribunal while estimating the Gross Profit element at 1% for the A.Y. 2008-09 made the following observations: - "3.2. We find that the Ld. AR vehemently argued that there is no dispute that the aforesaid five suppliers had only supplied fabrics to the assessee and in support of which he enclosed certain sample invoices from the aforesaid suppliers. He also drew our attention ....

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....purchases. 3.4. We find that there is no dispute that assessee is trading in fabrics and that the purchases made from the aforesaid five suppliers were in respect of purchases of fabrics. It is not in dispute that the sales made out of purchases made from aforesaid five suppliers were not doubted by the Revenue. It is not in dispute that purchase of fabrics does not get eligible for levy ....