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2018 (4) TMI 314 - AT - Income TaxInitiating the reassessment proceedings u/s.147 - default to take steps under section 143(3) - non service of notice - Estimating the Gross Profit on alleged bogus purchases @25% - Held that:- As decided in ACIT Vs. Rajesh Jhaveri Stock Brokers Pvt. Ltd. [2007 (5) TMI 197 - SUPREME Court] so long as the ingredients of section 147 are fulfilled, the Assessing Officer is free to initiate proceeding under section 147 and failure to take steps under section 143(3) will not render the Assessing Officer powerless to initiate reassessment proceedings even when intimation under section 143(1) - Decided in favour of revenue. Bogus purchases - Held that:- The assessee in the first year i.e. assessment year 2009-10 has maintained quantitative details. In other words, it has the evidence of purchasing goods and its sales. In such circumstances, at best, higher gross profit rate can be applied. Following our decision in earlier orders, we hold that GP rate of 10% over and above GP declared by the assessee in its books of account, be applied to work out the additional income in the hands of assessee.
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