In the result, assessee`s appeal for both the assessment years, that is,
Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Hearing) Sl.
disallowance by the restricting it to 5% of the total purchases following the decision of the Hon'ble Gujarat High Court in the case of M/s Mayank Diamond Pvt. Ltd. reported in 2014(1) TMI 812 (Guj.). In the decision of the Hon'ble ITAT Bench, Surat in the case of Deputy Commissioner of Income 239 & 304/SRT/2019 & 122 & 124/SRT/2020 Ravjibhai