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2021 (3) TMI 657 - AT - Income TaxEstimation of income - Bogus purchases - receipt of certain information from Sales Tax Department that the assessee procured accommodation purchase bills - HELD THAT:- Assessee had made certain purchases from concerns run by a tainted group. It was admitted by key persons of those concerns that they did not carry out any genuine business activities. During survey proceedings also, the assessee could not satisfactorily explain the purchases made during the year. The assessee could not produce any of the suppliers to prove the genuineness of the purchases. Hence the assessee was unable to discharge the primary onus of proving impugned purchases. On the facts of the case, it was a fit case for estimation of income earned on these tainted purchases. We find the estimation of 12.5% to be fair and reasonable. No new material is before us to deviate from the adjudication of Ld. CIT(A) in the impugned order. Validity of reassessment proceedings - HELD THAT:- We find that original return was processed u/s. 143(1) and the case was reopened upon receipt of specific information from Sales Tax Authorities which indicated possible escapement of income in the hands of the assessee. Nothing more was required at this stage. Therefore, no infirmity could be found in the jurisdiction acquired by Ld. AO. Resultantly, the legal grounds as well as appeal stand dismissed. AY 2013-14 - We find that the discrepancies found during the course of survey proceedings remained to be explained by the assessee to the satisfaction of lower authorities. The unaccounted purchases/sales, shortage of stock and cash were noted during the course of survey. The onus to explain the discrepancies remained un-discharged. Therefore, the estimations as made by lower authorities, in our considered opinion, are quite fair and reasonable and no interference is called for. Resultantly, the appeal stand dismissed.
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