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2019 (2) TMI 1342 - AT - Income TaxReopening of assessment - Bogus purchases - estimation of profit @ 12.50% - HELD THAT:- AO deputed inspector to make enquiries who also reported that these parties do not exist at their given addresses. The assessee could not produce these parties before the authorities below. The assessee could not furnish the proof of delivery, transport challans and goods inward register at godown etc with respect to the alleged goods purchased by the assessee from these parties. The incriminating information was received from Maharashtra Sales Tax Department that these eleven parties from whom the assessee allegedly purchased material were accommodation entry providers who were merely issuing bogus bills without supplying/delivering any material. The genuineness of the purchases made from these eleven parties could not be proved by the assessee and the incriminating information received by Revenue from Maharashtra VAT department remained un-controverted. The authorities below have estimated embedded profits @12.5% of alleged bogus purchases made by the assessee from these accommodation entry providers who were issuing bogus bills without supplying material. Estimation of the profits have to be undertaken which requires some guess work to assess income underlying these bogus bills which are allegedly obtained to reduce profits. The higher appellate authorities in such cases will not normally interfere unless its shown that the guess work undertaken by Revenue authorities is palpably perverse which in our considered view in the instance case as assessed by both the authorities below is very reasonable and fair and do not call for our interference - Decided against assessee.
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