TMI Blog2021 (5) TMI 251X X X X Extracts X X X X X X X X Extracts X X X X ..... hrough banking channels. There could be no sale without actual purchase of material keeping in view the assessee's nature of business. The facts of the case made it a fit case to estimate the profit element embedded in these transactions. The estimation of 12.5% as made by Ld. CIT(A) was quite fair and reasonable on the facts of the case. Therefore, concurring with findings of Ld. CIT(A) in th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... acts are that the assessee being resident corporate assessee stated to be engaged as dealer of chemical was assessed for the year under consideration u/s. 143(3) r.w.s. 147 on 30/03/2015. The original return filed by the assessee was processed u/s. 143(1). However, pursuant to receipt of certain information from DGIT (Inv.), Mumbai, it transpired that the assessee made suspicious purchases aggrega ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the suppliers. Consequently, an opinion was formed by Ld. AO that the assessee could not discharge the onus of establishing these purchases. Finally, the total purchases of ₹ 317.70 Lacs made by the assessee from seven suppliers were added back to its income while framing the assessment. 4. Upon further appeal, the assessee filed additional evidences u/r 46A which were subjected to reman ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... gh banking channels. There could be no sale without actual purchase of material keeping in view the assessee's nature of business. The facts of the case made it a fit case to estimate the profit element embedded in these transactions. The estimation of 12.5% as made by Ld. CIT(A) was quite fair and reasonable on the facts of the case. Therefore, concurring with findings of Ld. CIT(A) in the im ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
