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2014 (4) TMI 440 - ITAT DELHIAddition u/s 69C of the Act – Unexplained purchases – Deletion of disallowance of 100% expenditure and depreciation – Held that:- The decision in ACIT, Central Circle-21 Vs. Blue Luxury Index Pvt. Ltd. [2012 (7) TMI 467 - ITAT DELHI] followed - The entire purchases added by the AO are accounted for the books of account - The AO, without rejecting the books results added the entire purchases, source of which, according to the CIT(A), was duly explained - CIT(A) found that sales had been made by account payee cheques and duly reflected in stock registers and supported by sale and purchase vouchers – the AO in his remand report did not comment adversely on the contentions of the assessee in respect of purchases and sales – thus, the CIT(A) rightly deleted the additions - source of the expenditure incurred in purchases is obviously explained - the Revenue did not place any material for controverting the findings of facts recorded by the CIT(A) – Decided against Revenue. Disallowance of expenses – Held that:- CIT(A) found that in the assessment of the assessee for Assessment Year 2002-03, no disallowance of expenses was made while the AO, did not point out any item of expenditure, warranting disallowance – thus, in the absence of any basis, when the Revenue did not even identify any specific amount of expenditure, which was not related to the business of the assessee, any interference cannot be called for – Decided against Revenue.
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