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2021 (12) TMI 402 - ITAT PUNEReopening of assessment u/s 147 - receipt of information from Sales Tax Department, Maharashtra which had conducted inquiries in cases of several dealers located on across Maharashtra and had unearthed of a racket involving more than 1935 Hawala Dealers and more than 33,700 beneficiaries including the present assessee - HELD THAT:- We incline to hold that initiation of reassessment proceedings, u/s.148 of the Act and issued notice to the assessee was based on valid reason on the strength of new tangible material which was not before the AO during the original assessment proceedings. Therefore, we are unable to see any ambiguity, perversity or invalidity in the action of the AO in initiating reassessment proceedings, issuing notice u/s.148 of the Act and framing reassessment order u/s.143(3) r.w.s.147 of the Act. Therefore, we are of the opinion that the findings recorded by the First Appellate Authority is quite reasonable and justified and thus, the same does not call for any interference. Consequently, the findings of the Ld. CIT(Appeals) is upheld and Ground No.1 raised in appeal by the assessee is dismissed. Estimation of income - bogus purchases - Disallowance of 25% of total impugned bogus purchases - HELD THAT:- As per case M/S. PARAMSHAKTI DISTRIBUTORS PVT. LTD. [2019 (7) TMI 838 - BOMBAY HIGH COURT] we are of the considered view that it would be reasonable to sustain addition @ 10% of the amount of bogus purchases, being profit element involved therein.
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