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2022 (3) TMI 1196 - AT - Income TaxEstimation of income - bogus purchases - HELD THAT:- The claim of the assessee that assessee has discharged its complete onus as well as the entire addition has been made purely on the basis of the assumptions and surmises is purely devoid of any merit. The assessee failed to produce the parties from womb assessee has purchased the goods. The claim of the assessee that it has already disclosed higher gross profit margin at the rate of 18.5% the further addition at the rate of 12.5% of the bogus purchase is not justified, does not have any merit. The assessee when it has sold the goods to the third parties and obtained bogus purchase bills of those goods naturally there would be certain expenditure that assessee has incurred for obtaining such accommodation entries and therefore no infirmity can be found in estimating the profit at the rate of 12.5% of such bogus purchases. Even before the learned CIT – A assessee agreed four addition to the extent of 5% of bogus purchases. There is no justification for retaining profit at the rate of 2% of such bogus purchases as addition. Therefore, we also reject the arguments of the assessee of restricting the profit only to 2 percentage.
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