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2025 (4) TMI 1624

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....RABLE MR.JUSTICE D.N. RAY For the Appellant(s) No. 1 : Ms Vaibhavi K Parikh (3238) For the Opponent(s) No. 1 : Karan G Sanghani (7945) ORAL ORDER (PER : HONOURABLE MR. JUSTICE BHARGAV D. KARIA) 1. This appeal is filed by the appellant assessee under Section 260(A) of the Income Tax Act, 1961 (for short 'the Act'), proposing the following substantial questions of law arising out of t....

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....olding the impugned purchases as bogus purchases? (iv) Whether, in the facts and circumstances of the case, the Income Tax Appellate Tribunal was right in law in enhancing the addition on alleged bogus purchases to 6% of the amount of disputed purchases as against 5% confirmed by the Commissioner of Income Tax (Appeals) without giving any cogent reasons? (v) Whether, in the facts....

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....s from the same order which raised the same issue may also be dismissed as this Court has referred to and relied upon the decision in case of Principal Commissioner of Income Tax vs. Pankaj K. Chaudhary in Tax Appeal No.617 of 2022 decided on 07/03/2023. 3. We have perused the judgment and order dated 27/02/2024 in Tax Appeal No.107 of 2024 in case of the appellant therein rendered by this Cour....

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....fied in estimating the addition in respect of bogus purchases at the rate of 6% of such purchases by relying on the decision of the Hon'ble Gujarat High Court in the case of Mayank Diamonds Pvt. Ltd. (2014)(11) TMI 812 as against the direction of the the Hon'ble High Court in that case to make addition at the rate of 5% of the total turnover?" 5. After considering the decision in case of Princi....