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TMI Blog2018 (1) TMI 283X X X X Extracts X X X X X X X X Extracts X X X X ..... 70 entities with the sole objective of providing accommodation bills to the interested person through network of agents. The entities were being managed by the employees / relatives of the said group who were merely name lender and had no knowledge about the business being carried out by these entities. All these factors cast a serious doubt on assessee’s claim. Therefore, the addition, which could be made, was to account for profit element embedded in these purchase transactions to factorize for profit element earned by assessee against possible purchase of material in the grey market and undue benefit of VAT against alleged bogus purchases, which Ld.CIT(A) has rightly done. The assessee has placed reliance on several judicial pronounc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... moreover, the assessee has not raised any objection against the same. 2.1 Facts leading to the same are that the assessee being resident corporate assessee engaged as manufacturer exporter of diamond studded jewellery was assessed for impugned AY u/s 143(3) on 23/03/2016 at ₹ 2,24,76,960/- after sole addition of certain alleged bogus purchases for ₹ 73,42,508/-. The original return was e-filed by the assessee on 30/09/2013 at ₹ 1,51,34,450/-. 2.2 During assessment proceedings, it was noted that the assessee made suspicious purchases of ₹ 5,87,40,062/- from seven concerns, who, as per information received from DGIT (investigation), Mumbai were engaged in providing accommodation / bogus bills. All t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... T(A) vide impugned order dated 30/09/2016 where the assessee reiterate the said contentions. The Ld. CIT(A) after considering assessee s submission several judicial pronouncements, estimated the same to 3%. Aggrieved, the assessee as well as revenue is in further appeal before us. 4. The Ld. Departmental Representative [DR] drew our attention to that fact that the assessee made heavy purchases from seven entities, all of which were controlled by the same group and hence, the nature of transactions being made by the assessee with these entities was well within his knowledge. The Ld. DR further contended that the assessee was well aware of the operations of the group and procured accommodation bills to suppress the profits to take adva ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ls to the interested person through network of agents. The entities were being managed by the employees / relatives of the said group who were merely name lender and had no knowledge about the business being carried out by these entities. All these factors cast a serious doubt on assessee s claim. Therefore, in such a situation, the addition, which could be made, was to account for profit element embedded in these purchase transactions to factorize for profit element earned by assessee against possible purchase of material in the grey market and undue benefit of VAT against alleged bogus purchases, which Ld.CIT(A) has rightly done. The assessee has placed reliance on several judicial pronouncements but we find the matter to be a factual ..... X X X X Extracts X X X X X X X X Extracts X X X X
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