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2019 (3) TMI 2 - AT - Income TaxAddition of bogus purchases - ex parte order - Assessment u/s 147 based on investigation report - profit rate determination - assessee was able to co-relate the purchase of material with the allocation of raw materials and sales of finished products. - HELD THAT:- Neither before the AO nor before the Commissioner (Appeals) the assessee has produced any supporting evidence either to prove delivery of goods or the fact that the goods were actually sold by the concerned parties. Assessee even could not establish the existence of the concerned parties, considering the fact that the notices issued under section 133(6) returned back unserved. Claim of the assessee that the purchases made are genuine cannot be accepted. AO has accepted the fact that the assessee has purchased goods from some other source and for that reason alone he has estimated the profit at the rate of 12.5% which has been sustained by Commissioner (Appeals). The assessee has neither appeared before us nor brought any material on record to controvert the aforesaid factual finding of the departmental authorities and has also failed to demonstrate that the profit rate adopted at 12.5% is unreasonable. - Decided against assessee.
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