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2019 (3) TMI 1874 - ITAT DELHIEstimation of income - Bogus purchases - HELD THAT:- Assuming that the entire purchases from Rajasthan Metals was bogus, then it would be commercially impossible for the assessee to sell ₹ 5.54 crores of goods. Moreover, sales effected by the assessee has been accepted by the Sales Tax Department. The assessee has given complete quantitative details in the form of stock register of raw material as S.S. Patti which is exhibited at page E-3/81 to E-3/109 of the paper book. A perusal of the same clearly reveals that the raw materials, in fact, entered the business of the assessee which were used for making final product and accordingly, sales were executed by the assessee. It appears that the assessee must have purchased the raw material from the grey market and must have taken supporting purchase bills from the accommodation entry provider which means that raw material were, in fact, purchased and there was movement of the same which enables the assessee to produce its final product. In our considered opinion, over and above the additions sustained by the ld. CIT(A), the assessee must have incurred some expenditure in procuring accommodation bills which we estimate at 5% of the total purchases from Rajasthan metals which is ₹ 1.45 crores which means that the assessee must have incurred expenditure of ₹ 7 lakhs for procuring accommodation bills. Modifying the findings of the ld. CIT(A), we direct the Assessing Officer to restrict the addition to ₹ 13.43 lakhs. - Decided partly in favour of revenue allowed.
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