TMI Blog2021 (9) TMI 252X X X X Extracts X X X X X X X X Extracts X X X X ..... m DGIT (Inv.), it transpired that the assessee made suspicious purchase in A.Ys. 2010-11 2011-12. On the basis of said information, Ld. AO formed a belief that assessee would have taken bogus bills in A.Y. 2012-13 also to suppress profits. Another reason of reopening was the fact that there was difference in TDS figures. On the given facts, in our opinion, the presence of this material/informati ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Respondents : Kailash Gaikwad, Ld. DR ORDER Manoj Kumar Aggarwal, Accountant Member 1. Aggrieved by confirmation of certain addition of alleged bogus purchases of ₹ 14.66 Lacs for Assessment Year 2012-13, the assessee is in further appeal before us. The assessment was framed u/s. 143(3) r.w.s. 147 on 26/03/2015 which was confirmed by Ld. CIT(A)-26, Mumbai vide impugned order date ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the assessee would show that as per information received from DGIT (Inv.), it transpired that the assessee made suspicious purchase in A.Ys. 2010-11 2011-12 which ultimately culminated into certain additions in the hands of the assessee. These additions have been accepted by the assessee. On the basis of said information, Ld. AO formed an opinion that the assessee would have taken bogus bills ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ation stage, what was required is only a reason to believe and not the established fact of escapement of income. At the stage of issue of notice, the only question to be considered was whether there was relevant material on which a reasonable person could have formed a requisite belief that income has escaped assessment. Based on precise information as received from DGIT (Inv.), Ld. AO had this be ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... enough to reopen the case and no infirmity could be found in reopening the case of the assessee. The legal grounds, thus raised, stand dismissed. 5. Regarding quantum of additions, Ld. AR has submitted that similar issue arose in A.Ys. 2010-11 2011-12 wherein Ld. AO estimated addition of 15% in set-aside proceedings. Since the same has been accepted by both the sides, similar estimation may b ..... X X X X Extracts X X X X X X X X Extracts X X X X
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