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2018 (8) TMI 1915 - AT - Income TaxBogus purchases - AO making an addition on account of unexplained purchase u/s 69C by calculating peak credit and by treating genuine purchase as accommodation entry - addition so made was reduced by CIT(A) to the extent of 3% of the alleged bogus purchases - HELD THAT:- In the instant case, assessee has precisely asked for cross examination and the copy of the statement which was not supplied either by AO or by CIT(A) nor any corroborative evidence was brought on record to prove that assessee has purchased goods from grey market. Keeping in view the profit rate shown by the assessee at 7.17% in respect of goods exported, there is no justification for making further addition of 3%. It is also a matter of record that assessee has filed ledger account with confirmation of the parties from whom purchases were made. Stock Register and quantative details of the goods purchased and exported was also filed before the lower authorities, wherein no discrepancy was pointed out. Keeping in view totality of facts and circumstances of the case vis-à-vis profit declared by the assessee at 7.17%, no further addition is warranted. - Decided against revenue
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