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2020 (8) TMI 506 - AT - Income TaxTrading addition - Estimation of income - bogus purchases - Non rejection of books of accounts - HELD THAT:- On the credit side of the trading account, sales and closing stock are verifiable and the opening stock is also reflected in the books of account, purchases and the other quantitative details are tallying with the books of accounts and purchases, then there cannot be any inference that purchases made and shown by the assessee are bogus. As regards the difference of rates the AR has already pointed out that assessee had purchased different quality of steel alloys the rate of which was ₹ 110 per kg from different party also and from M/s Maa Durga Trading Company the assessee had purchased steel alloy @ ₹ 32 and @ ₹ 35 and also ₹ 110 per kg. Such an inference drawn by the CIT (A) is divorced from the facts and material on the record. Thus when purchased are duly accepted by the VAT Department including the sales and manufacturing account and the quantity utilized for the manufacturing has not been disputed and trading account and books of account have not been rejected, then no separate addition on account of purchase cannot be made. - Appeal of the assessee is allowed.
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