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TMI Blog2020 (3) TMI 1476X X X X Extracts X X X X X X X X Extracts X X X X ..... tion that some X-Rays having been done, and there is no receipts issued or there is any suppression of receipts. Therefore, in view of the above facts and circumstances of the case, we find no merit in the addition sustained by the ld CIT(A) hence we direct the A.O. to delete the same. Addition for discounts - AO made addition on the ground that in the search year it was found that the appellant had claimed certain discounts which could not be verified - CIT(A) sustained disallowance @ 25% - HELD THAT:- There is no claim of discount as such, and the addition was based on estimated discounts. In case there is no claim of such discounts the question of disallowance of any addition is uncalled for. There is no case of suppression of receipts b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ipur has erred in granting relief of Rs. 75,392/- only out of total addition of Rs. 3,87,730/- on account of suppression of xray receipt revenue based on ad-hoc estimation basis made by the Ld. AO, which unjustified, unwarranted bad in law and liable to be deleted entirely. 4. Under the facts and circumstances of the case and in law, Ld. CIT (Appeals)-II Udaipur has erred in granting relief of Rs.14,11,384/- only out of total disallowance of Rs. 18,81,845/- on account of discount claimed by the appellant on ad-hoc estimation basis made by the Ld. AO, which unjustified, unwarranted bad in law and liable to be deleted entirely. 5. The appellant prays for justice and the appeal deserves to be allowed. 6. The appellant craves leave to add, alte ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ad not been considered, error of technician, package charges, scheme charges etc. has not been considered. Sometimes films are wasted due to calibration technical issues and even repeat X- Rays are done, if the same is not done properly. The assessee also relied upon some judicial decisions in support that the estimated addition cannot be made. 5. We also observe that the addition is not based upon any material or evidence for the year under consideration and even during search nothing has been found related to the year. There is no basis for estimation of suppression of X-Rays. Even the technician during the search proceedings had stated that in every bundle certain X-Rays gets damaged, and further there are various other reasons by which ..... X X X X Extracts X X X X X X X X Extracts X X X X
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