TMI Blog2021 (6) TMI 318X X X X Extracts X X X X X X X X Extracts X X X X ..... 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 - CIT(A), after due consideration of assessee's submissions as well as material on record, estimated the additions @25% which is more than enough to take care of the leakage of revenue. Therefore, the estimation could not be termed as unjustified ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ident individual stated to be engaged in manufacturing of engineering goods consisting of molds, dies etc. was assessed for the year under consideration u/s. 143(3) r.w.s. 147 on 26/02/2016. The original return filed by assessee was processed u/s. 143(1). However, pursuant to receipt of certain information from DGIT (Inv.) / Sales Tax Department, Mumbai, it transpired that the assessee made allege ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the order. The disallowance was made @100% against 8 parties whereas the disallowance against one party was estimated @25%. In the alternative, Ld. AO proposed disallowance of ₹ 34.21 Lacs u/s. 40(A)(3) which represent purchases made from seven entities since the assessee would have made payment out of sources best known to him. 4. The Ld. CIT(A), inter-alia, considering the decision of H ..... X X X X Extracts X X X X X X X X Extracts X X X X
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