TMI Blog2021 (6) TMI 349X X X X Extracts X X X X X X X X Extracts X X X X ..... d there could be no sale without actual purchase of material keeping in view the assessee's nature of business. The facts of the case made it a fit case to estimate the profit element embedded in these transactions. The Ld. CIT(A), after due consideration of assessee's submissions as well as material on record, estimated the additions @12.68% which is more than enough to take care of th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... for fresh hearing before this bench. 2. The revenue assails the order of Ld. Commissioner of Income Tax (Appeals)-32, Mumbai [in short CIT(A)] dated 29/05/2017 which has provided certain relief to the assessee on account of alleged bogus purchases. 3. Though none appeared for assessee, however, material on record was sufficient for disposal of the appeal. The Ld. DR pleaded for restoration o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... filed documentary evidences in support of purchases which led Ld. AO to disallow the purchases of ₹ 63.54 Lacs while framing the assessment. 5. Before Ld. CIT(A), the assessee pointed out that the notices were issued by Ld. AO at old Ahmedabad address and therefore, the proceedings could not be attended to by the assessee. On merits, it was submitted that the additions made by Ld. AO woul ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nover was not in doubt and there could be no sale without actual purchase of material keeping in view the assessee's nature of business. The facts of the case made it a fit case to estimate the profit element embedded in these transactions. The Ld. CIT(A), after due consideration of assessee's submissions as well as material on record, estimated the additions @12.68% which is more than eno ..... X X X X Extracts X X X X X X X X Extracts X X X X
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