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TMI Blog2021 (6) TMI 349X X X X Extracts X X X X X X X X Extracts X X X X ..... e the appeal was initially disposed-off by the Tribunal as low-tax effect case vide common order dated 21/08/2018. However, the order has been recalled vide MA No. 303/Mum/2019 order dated 28/02/2020 since it was pointed out by the revenue that the case was covered by exception 3(e) of CBDT Circular dated 20/08/2018. Accordingly, the case has come up for fresh hearing before this bench. 2. The re ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Tax Department, Mumbai, it transpired that the assessee made alleged bogus purchases of Rs. 63.54 Lacs from thirteen entities as detailed in the assessment order. Accordingly, the case was reopened as per due process of law and the assessee was required to file requisite details to substantiate the purchases. 4.2. The assessee could not filed documentary evidences in support of purchases which l ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... embedded in these transactions was to be brought to tax. The estimation was made @12.68% which was nothing but Gross Profit rate shown by the assessee during the year. Aggrieved, the revenue is in further appeal before us. 7. Going by the factual matrix as enumerated in the orders of lower authorities, we find that the Sales Turnover was not in doubt and there could be no sale without actual purc ..... X X X X Extracts X X X X X X X X Extracts X X X X
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