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2022 (8) TMI 847 - AT - Income TaxEstimation of income - bogus purchases - additions @ 5% of bogus purchases - main submission of the ld. AR of the assessee are that the assessee has shown Gross Profit @ 22.10% which is high in the line of business of the assessee - HELD THAT:- We do not find any merit in the submission of the assessee as no such submission was raised either before Assessing Officer or before ld. CIT(A). Before Assessing Officer no such fact and figure was furnished. AO while rejecting the books of accounts clearly held that no details of quantity and quality wise and rough and polished diamond was furnished - details of carat wise diamond manufactured and quality details were not furnished. The assessee for the first time has come with these fact and figure. No such one to one correlation of purchase and export was prove before Assessing Officer. The case laws relied by ld. AR is not applicable on the facts of the present case as furnished in the case of Pankaj Kawarlal Jain [2019 (8) TMI 1769 - ITAT SURAT] in the instant case, there is clear finding of AO that no quantity wise and quality wise detail were furnished, no original challan or jhangad was produced. The assessee has not established as to how much rough diamond used for manufacturing in diamond. Thus, in view of aforesaid discussion, we do not find any merit for further reducing the addition of disputed purchases shown from alleged hawala/bogus entry provider. - Decided against assessee.
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