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2018 (12) TMI 1861 - ITAT MUMBAIEstimation of income - Bogus purchases - HELD THAT:- AO had specific information in his possession to indicate that certain purchases made by the assessee in the impugned assessment years are not genuine. It is also evident, the assessee could not conclusively prove that the purchases claimed to have been made from the declared source are genuine. However, the departmental authorities have not disputed the sales effected by the assessee, meaning thereby, the assessee might have purchased the goods from some unknown parties/source. For this reason alone the assessing officer has estimated the profit at 12.5% of the non genuine purchases. Therefore, the dispute now is only with regard to the profit rate to be applied for estimating the income on non genuine purchases. After considering the overall facts and circumstances of this particular case we are of the considered opinion that estimation of profit @ 5% of the alleged non genuine purchases would be reasonable. We direct the assessing officer to restrict the addition in both the Assessment Years under appeal to 5% of the non genuine purchases. We make it clear, our aforesaid decision is purely on the basis of facts involved in the present appeals.
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