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2018 (3) TMI 1625 - ITAT PUNEDisallowances u/s. 40A(2)(a) - purchase of gold ornaments and gold bullion by assessee from sister concerns at higher rate - estimation of GP at 2.75% as against GP of 2.22% declared by assessee - Disallowances u/s. 14A r.w. Rule 8D - valuation of stock - Held that:- there are fictitious transactions between assessee and other group concerns to inflate the turnover. The Commissioner of Income Tax (Appeals) while estimating GP at the rate of 2.75% has taken cue from the decision of the Tribunal in the case of M/s. Rajmal Lakhichand (2015 (1) TMI 1393 - ITAT PUNE). - Thus, following the decision of the Hon'ble ITAT in the case of Rajmal Lakhichand, the adoption of G.P. rate of 2.75% as against the G.P. rate of 2.22% disclosed by the appellant will be fair and meet the ends of justice. Decided partly in favor of assessee.
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