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2021 (5) TMI 774

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..... es issued u/s 133(6) did not elicit satisfactory response. Therefore, it was a fit case for estimation of additions on these suspicious purchases. In our considered opinion, Ld.CIT(A) has clinched the issue in the correct perspective. The estimation of 12.5% was quiet fair and reasonable and the same do not require any interference on our part. Therefore, by confirming the stand of Ld. CIT(A), we dismiss the appeal. - I.T.A. No.2762/Mum/2019, 2763/Mum/2019 (Assessment Year: 2009-10, 2010-11) - - - Dated:- 3-2-2021 - HON BLE SHRI MAHAVIR SINGH, VP AND HON BLE SHRI MANOJ KUMAR AGGARWAL, AM Assessee by: None Revenue by: Shri T.S. Khalsa- Ld. Sr. DR ORDER PER BENCH 1. Aforesaid appeals by revenue for Assessment Yea .....

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..... iate the purchase transactions. In defense, the assessee submitted that the purchases were supported by valid invoices and the payments were through account channels. The ledger extracts of the suppliers along with their confirmation of accounts as well as Permanent Account Numbers was also submitted. However, notices issued u/s 133(6) to these parties was returned back unserved by the postal authorities and therefore, a conclusion was drawn that the purchases made by the assessee from these suppliers were bogus. Finally, these purchases were disallowed as unproved and unexplained expenditure within the meaning of Section 69C of the Act. 5. Before Ld. CIT(A), the assessee reiterated that the purchases were genuine and drew attention to t .....

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..... of the suppliers for confirmation of accounts and notices issued u/s 133(6) did not elicit satisfactory response. Therefore, it was a fit case for estimation of additions on these suspicious purchases. In our considered opinion, Ld.CIT(A) has clinched the issue in the correct perspective. The estimation of 12.5% was quiet fair and reasonable and the same do not require any interference on our part. Therefore, by confirming the stand of Ld. CIT(A), we dismiss the appeal. 7. Facts as well as issues are pari-materia the same in AY 2010-11 wherein the assessee was saddled with additions of ₹ 96.98 Lacs on account of suspicious purchases. The Ld. CIT(A) restricted the same to 12.5% applying similar reasoning and logic. Aggrieved, the re .....

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