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2023 (8) TMI 1075 - MADHYA PRADESH HIGH COURTSuppression of sales of iron ore - different sale figures found during seizure in an incriminating evidence as per law which has led the AO to calculate suppression of sales to 20% - ITAT deleted the addition - HELD THAT:- A bare perusal of the contents reveals Tribunal found that in absence of any charge of evasion of royalty/tax, it cannot be presumed that there is any suppression of quantity of production from the mine or the purchase made by appellant from M/s Jai Minerals. The Tribunal also found that the findings leading to addition by the Assessing Officer are based on presumption rather than proof. Moreso, other findings rendered in the aforesaid paragraphs of the impugned order reveal that they are based on factual disputes and, therefore, neither give rise to any substantial proposed question of law as proposed by the Revenue or otherwise. In the absence of any substantial question of law arising from the findings of Tribunal which are purely factual in nature, this Court declines admission to this appeal.
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