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TMI Blog2022 (12) TMI 1534X X X X Extracts X X X X X X X X Extracts X X X X ..... , in the instant case sales made out of disputed purchases were not doubted by the Revenue, the only logical conclusion could be that assessee had made purchases in the grey market in order to have savings in indirect taxes and instantly, profit element thereon. Hence, it would be just and fair to bring to tax only the profit element embedded in the value of such disputed purchases. We find that t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... /NFAC/S/250/2022- 23/10044800362(1) dated 18th August, 2022, against the order of assessment passed under Section 143(3) read with section 147 of the Income-tax Act, 1961 (hereinafter referred to as Act ) dated 17th March, 2015, by the learned Income Tax Officer, Ward 19(1)(2), Mumbai (hereinafter referred to as learned AO). 02. Identical issues are involved in both these appeals and hence, they a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... year had made certain purchases from certain parties, who were treated as tainted parties by the Sales Tax Department, Government of Maharashtra. In the opinion of the learned Assessing Officer, though assessee had furnished the relevant documents in the form of purchase invoices, bank statements evidencing payments by account payee cheques, stock registers, address of the suppliers, sales made o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ent embedded in the value of disputed purchases. This profit percentage was estimated by the learned Assessing Officer for A.Y. 2009-10 at 15% and for A.Y. 2010-11 at 12.5%. On first appeal, the learned CIT (A) directed the learned Assessing Officer to estimate the profit percentage at 12.5% for both the years. 06. Since, in the instant case sales made out of disputed purchases were not doubted by ..... X X X X Extracts X X X X X X X X Extracts X X X X
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