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2017 (9) TMI 305 - AT - Income TaxLegality /Validity of reopening of assessment u/s 148 - hawala transactions - bogus purchases - assessee agreed for addition but requested for a fair and reasonable estimate of profits embedded in these purchases - Held that:- Assessee has specifically stated that it does not want to challenge the legality and validity of reopening of assessment u/s 147/148 but want quite reasonable and fair addition and hence ground no. 1 stood dismissed as not being pressed. Addition to the tune of 12.5% of the alleged purchases are upheld towards profit embedded in these purchases wherein material was procured from grey market at lower prices while invoices at inflated price was obtained from these alleged bogus dealers, instead of 24.71% (GP of last year) as was upheld/sustained by lower authorities. We direct the A.O. to work out the additions to the income of the assessee at the rate of 12.5% of the alleged bogus purchases over and above declared income -Decided partly in favor of assessee.
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