TMI Blog2015 (6) TMI 1214X X X X Extracts X X X X X X X X Extracts X X X X ..... grey market. Even, if it is assumed for a moment that the assessee might have purchased goods from grey market, it was not established that the amount of purchases was less than that recorded in the books of account. Under these set of facts, it has to be held that the impugned addition has been made only on estimated basis that too on presumptions only. Hence, by following the decision rendered ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed u/s 271(1)(c) of the Act . 2. We heard the parties and perused the record. The revenue carried out search and seizure operations in Etco group and it was noticed that the assessee herein had made purchases worth ₹ 3.43 crores form M/s Triton Infotech Pvt Ltd. During the course of search operation, a statement was taken from the director of Shri Triton Infotech Pvt Ltd and he confessed ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... estimated basis. He further submitted that the penalty levied on the addition made in an identical manner in assessee s sister concern has since been deleted by the Tribunal. The Ld A.R furnished a copy of order dated 17-12-2014 passed in M/s Etco Telecom Ltd in ITA No. 5243/Mum/2012. On the contrary, the Ld D.R placed reliance on the order passed by Ld CIT(A). 4. Having heard rival submissions ..... X X X X Extracts X X X X X X X X Extracts X X X X
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