TMI Blog2020 (11) TMI 342X X X X Extracts X X X X X X X X Extracts X X X X ..... notices issued u/s. 133(6) remained unserved and assessee failed to produce even a single party. Truly, there could not be any sale without actual purchase of material and therefore a presumption could be drawn that the material was purchased from the open market while invoices were procured from tainted suppliers. Therefore, estimating the additions @12.5% was quite fair and reasonable. There ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... matter was proceeded with ex-parte qua the assessee since the material on record was quite sufficient for disposal of the appeal. The Ld. DR pleaded for restoration of additions made by Ld. AO. 3. The material on record would show that the assessee being resident firm is stated to be engaged in the business of manufacturing of conveyer belt. It was assessed for the year under consideration u/s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ransactions. The assessee had claimed that the goods were received and corresponding sales were accounted for and there could not be any sales without purchases. Accepting the same, Ld. AO made peak addition of ₹ 42.53 Lacs u/s. 69C. 4. Upon further appeal, Ld. CIT(A), inter-alia, relying upon the decision of Hon'ble Gujarat High Court in the case of CIT Vs. Simit P. Sheth [356 ITR ..... X X X X Extracts X X X X X X X X Extracts X X X X
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