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2025 Supreme(Online)(ITAT) 5103

INCOME TAX APPELLATE TRIBUNAL (CHANDIGARH BENCH)
KRINWANT SAHAY, AM, RAJPAL YADAV, VP
Pragatie Steels – Appellant
Versus
Department – Respondent


Advocates:
For the Appellants/Petitioners:Shri Sudhir Sehgal, Advocate
For the Respondents: Shri Manav Bansal, CIT, DR

Table of Content
1. foundation of the appeals and procedural background. (Para 1 , 2)
2. essentials of the taxation claims by the assessee. (Para 3 , 4 , 6 , 7 , 8)
3. importance of maintained records in substantiating deductions. (Para 10 , 19 , 21)
4. final determinations of the tribunal regarding evidence. (Para 22 , 23)

आदेश/Order

PER KRINWANT SAHAY, AM:

This is an appeal filed by the Assessee and Cross Appeal filed by the Department against the order of the Ld. CIT(A)/NFAC, Delhi dt. 18/07/2024 pertaining to Assessment Year 2021-22.

2. Since both the above appeals were heard together, therefore they are being disposed of by this consolidated order for the sake of convenience and brevity.

3. We will first deal with the appeal of the Assessee in ITA No. 889/Chd/2024 pertaining to Assessment Year 2021-22, wherein the assessee has raised following grounds:

“1. That the Ld. CIT(A) had erred in confirming the pat addition of Rs. 1,32,34,287/- on estimated basis by applying a rate of 12.5% as profit entered in impugned purchases from certain parties.

2. a) That the Ld. CIT(A), NFAC, Delhi has erred in ignoring the documentary evidences of the genuine being purchases made by the assessee like T

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