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2017 (4) TMI 1465 - AT - Income TaxReopening of assessment u/s 147 - bogus purchases - HELD THAT:- After recording reasons for reopening, the AO has issued notice u/s.148. Thus, there is no infirmity in the order of CIT(A) for upholding the reopening. Coming to the merit of the addition, we found that allegation of the AO was as per information from the Sales Tax Department, assessee has taken accommodation purchases. However, the corresponding sales have not been denied by the AO. Without purchases there cannot be sale. Therefore, adding entire amount of purchases in assessee’s income is not justified. Referring to nature of assessee’s business, restrict addition to the extent of 12.5% of such bogus purchases. - Decided partly in favour of assessee.
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