9911796707
TMI Blog2021 (10) TMI 258X X X X Extracts X X X X X X X X Extracts X X X X ..... M: This appeal of assessee is arising out of the order of the Commissioner of Income Tax (Appeals)]-32, Mumbai [in short CIT(A)], dated 27.06.2017. The assessment was framed by the Income Tax Officer, Ward 20(1)(2) (in short ITO/ AO) for the A.Y. 2011-12 vide order dated 09.03.2016 under section 143(3) read with section 147 of the Income-tax Act, 1961 (hereinafter 'the Act'). 2. The effective is ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ated to the purchase evidencing payments made to said parties by account payee cheques. The learned Assessing Officer issued notices under section 133(6) of the Act to all the parties, which were duly served but no replies were received from the said parties in response thereon. The learned Assessing Officer directed the assessee to produce the aforesaid parties, which was also not complied with b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s outstanding liabilities in the balance sheet of the assessee and the same had not been written back to the income by the assessee. Effectively, the learned CIT(A) held that the parties from whom credit purchases have been made are genuine and accordingly deleted the addition made in the sum of Rs. 25,44,256/-. 5. With respect to the remaining purchases to the tune of Rs. 1,49,71,795/- made from ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 42% in its books which has been accepted by the Revenue. It is not in dispute that sales made out of the purchases of Rs. 1,75,16,051/- from seven parties has not been doubted by the Revenue. For the purpose of determining the profit element embedded in the value of such purchases, taking into consideration the industry in which the assessee is dealing with, we deem it fit appropriate to estimate ..... X X X X Extracts X X X X X X X X Extracts X X X X
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