9911796707
TMI Blog2023 (6) TMI 106X X X X Extracts X X X X X X X X Extracts X X X X ..... 2. In this appeal, the assessee has raised the following grounds:- "1. The appellate order dated 27-05-2022 passed by CIT(A), National Faceless Appeal Centre, Delhi is quite arbitrary, illegal and contrary to the facts of the case of your appellant. 2. The Ld. CIT(A) has further erred in not allowing the claim of appellant in respect to the re- opening of assessments. 3. The case laws relied upon by him is not at all relevant to the facts and circumstances of the present case. 4. The Ld. CIT(A) has further grossly erred in rejecting the appellant's contention that there was no new information on record to warrant the initiation of proceedings u/s.148 of the Act. 5. The Ld. CIT(A)'s conclusion that opportunity to cross ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... come of Rs.30,62,800/-. The return filed by the assessee was initially processed u/s 143(1) of the Act. Thereafter, on the basis of information received from DGIT (Inv.), Mumbai, proceedings u/s 147 of the Act were initiated, and notice u/s 148 of the Act was issued on 28/03/2018 in the case of the assessee. As per the said information, the assessee is a beneficiary of bogus purchases from a concern, viz. M/s Krishna Diam, of Gautam Jain Group, who are entry/accommodation bills provider. Accordingly, in absence of proof of the genuineness of purchases made by the assessee, the AO vide order dated 14/12/2018 passed u/s 143(3) r.w.s. 147 of the Act treated the entire purchase of Rs.71,39,812/- from the aforesaid entity as bogus and added the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... aced on the aforesaid report of the Task Force. In the instant case, the assessee is engaged in the business of both trading as well as manufacturing of diamonds. Considering the same, we find that the ld. CIT(A) was duly justified in estimating the profit percentage at 3% on which we do not deem it fit to interfere. In other words, the estimation of profit percentage at 3% by the ld. CIT(A) is just and fair and does not require any interference. Accordingly, the ground No.2 raised by the assessee is dismissed." 7. As, in the present case there is no dispute regarding the fact that the assessee is also in the business of trading in diamonds, therefore, respectfully following the aforesaid decision, we deem it appropriate to restrict the d ..... X X X X Extracts X X X X X X X X Extracts X X X X
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