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2021 (11) TMI 1116

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....jesh Ojha O R D E R PER M. BALAGANESH (A.M): These cross appeals in ITA Nos.3580/Mum/2018 & 3506/Mum/2018 for A.Y.2007-08 arise out of the order by the ld. Commissioner of Income Tax (Appeals)-37, Mumbai in appeal No.CIT(A)-37/IT-215/ITO-25(3)(4)/2015-16 dated 15/03/2018 (ld. CIT(A) in short) against the order of assessment passed u/s.143(3) r.w.s. 147 of the Income Tax Act, 1961 (hereina....

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....e find that assessee is a proprietor of Namrata Paper Agencies engaged in the business of trading in paper. The return of income for the A.Y.2007-08 was filed by the assessee on 21/04/2014 declaring total income of Rs. 6,63,520/-. It is not in dispute that assessee had made purchases from two parties totaling to Rs.53,56,525/- whose names appear to be tainted dealers in the website of sales tax de....

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....es treating the same as bogus while completing the re-assessment. 4.1. The ld. CIT(A) observed that the corresponding sales made by the assessee out of the disputed purchases were not doubted by the ld. AO and since there cannot be no sales without the purchases, only the profit element embedded there on could be brought to tax which was estimated by the ld. CIT(A) @12.5% by placing reliance on....