2021 (6) TMI 848

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... the factual matrix, it is evident that assessee's sales turnover was not in doubt. 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. Therefore, as pleaded by Ld. AR and to put an end to litigation, we estimate the additions a .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... appellate order has not considered the outcome of remand proceedings wherein the assessee substantiated these purchase to a great extent. In the alternative, Ld. AR pleaded for certain estimation considering the factual matrix and keeping in mind the assessee's nature of business. The Ld. DR, on the other hand, pleaded for dismissal of the appeal. 3. The material facts are that the assesse .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... dditions so made by Ld. AO were confirmed. From the impugned order, it is quite evident that the order has not considered the outcome of remand proceedings. Aggrieved, the assessee is in further appeal before us. 5. From the material on record, we find that the assessee, vide letter dated 26/09/2018 has filed confirmation of accounts from 4 parties under consideration. The ledger extracts as pl .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X