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2017 (11) TMI 1365 - AT - Income TaxEstimation of income at 10% of the purchase price - Held that:- We direct the A.O. to re-compute the income of the assessee at 5% of purchase price. Accordingly, this ground of appeal raised by the assessee is allowed. Unexplained investment - Held that:- During the appeal hearing, the Ld. A.R. did not bring any evidence to show the source of the payment of ₹ 4,16,667/-. Though the Ld. A.R. argued that once the income is estimated no further addition required to be made, the payment was the initial payment made in the beginning of the year, hence it cannot be held that the assessee has generated income out of business in the beginning of the day, therefore, the argument of the assessee is untenable, accordingly, rejected. Since the assessee failed to explain the sources of the initial investment, we hold that the A.O. has rightly made the addition, which was confirmed by the Ld. CIT(A). Addition u/s 69 - Held that:- CIT(A) examined the transaction of each creditor and given finding that the transactions are not genuine and in some cases the identity of the creditor was also doubtful. None of the creditors are having credit worthiness to make the advances. The ld. CIT(A) also verified the transactions with respect to the DDs purchased and found that there was no evidence to show that the creditors have taken the DDs and the DDs were taken out of the bank withdrawals. The serial No. of DDs and the manner in which DDs were taken to pay the license fee also held to be doubtful and the transactions cannot be held as genuine. During the appeal hearing, the Ld. A.R. did not bring any evidence to controvert the finding of the Ld. CIT(A). Therefore, we do not find any infirmity in the order of the Ld. CIT(A) and the same is upheld and the appeal of the assessee on this ground is dismissed.
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