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TMI Blog2022 (11) TMI 620X X X X Extracts X X X X X X X X Extracts X X X X ..... ently taking the stand by estimating the profit element on the basis of reliance placed 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. 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 raised by the assessee is dismissed. - ITA No.1499/Mum/2020 And ITA No.1500/Mum/2020 And ITA No.1501/Mum/2020 - - - Dated:- 26-10-2022 - Shri Vikas Awasthy, Judicial Member And Shri M.Balaganesh, Accountant ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ng issue that needs to be adjudicated is as to whether the ld. CIT(A) was justified in confirming the disallowance made on account of non-genuine purchases by estimating the profit element at 3% thereon as against 5% estimated by the ld. AO. 4.1. We have heard rival submissions and perused the materials available on record. We find that assessee is engaged in the business of trading and manufacturing of diamonds. It is not in dispute that assessee had made purchases from certain parties who were treated as tainted dealers as per information gathered from the search carried out in the entities of Shri Bhawarlal Jain and Group. However, the sales made out of the purchases made from the disputed parties were not doubted by the Revenue. Ac ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... imating 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. 6. In the result, appeal of the assessee for A.Y.2010-11 is dismissed. ITA No.1500/Mum/2020 (A.Y.2011-12) 7. The facts and circumstances of A.Y.2010-11 are exactly identical with the facts prevailing in A.Y.2011-12 except with variance in figures. Hence, the decision rendered by us hereinabove for A.Y.2010-11 shall apply mutatis mutandis for A.Y.2011-12 also. ITA No.1501/Mum/2020 (A.Y.2013-14) 8. The only issue to be decided in this a ..... X X X X Extracts X X X X X X X X Extracts X X X X
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