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2019 (8) TMI 1329 - AT - Income TaxRectification u/s 254 - bogus purchases - HELD THAT:- We find that the Tribunal has deliberated at length on the issue involved in these appeals, in respect of additions made by the AO towards alleged bogus purchases from certain hawala dealers/suspicious dealers, in light of facts brought out by the AO, during assessment proceedings and also arguments advanced by the assessee. Tribunal had given categorical finding, in respect of purchases claims to have made from certain parties, in light of admission of the assessee counsel before the AO and came to the conclusion that when, the assessee has surrendered the income before the AO on being confronted with the result of enquiries conducted, during the course of assessment proceedings, which clearly established the fact that the purchases from the above parties are bogus and this fact was further, supported by the report of investigation wing, which is once again based on information received from sales tax department. In the light of above observations of the Tribunal, if we examine the contents of miscellaneous application filed by the assessee, we find that the assessee has failed to make out a case of prima-facie mistake apparent on record from the order of the Tribunal, which could be rectified u/s 254(2) - miscellaneous application filed by the assessee for AY 2009-10, 2010-11 and 2011-12 are dismissed.
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