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2019 (2) TMI 1468 - AT - Income TaxUnexplained expenditure u/s 69C - bogus purchases -Admission of additional evidence- HELD THAT:- We find that the assessee in this case has submitted all the necessary evidences in support of the impugned transactions and the CIT(A) has drawn a correct conclusion. It is clear that the A.O. has given an extremely short notice, wherein the notices could not be responded. All the necessary details were subsequently available and the same were provided to the A.O. in the remand proceedings. The details have also been made available to us in the paper book. From the same, we find that all the necessary confirmations of the transactions are available. All the payments are through banking channels. No discrepancy in this regard is noted. The other planks made by the assessee are also cogent that the assessee has provided the copies of the bank statements for all the additions proposed to be made u/s.69C of the Act. Hence, the additional unexplained expenditure as mandated in section 69C is not sustainable, as section 69C provides that where in any financial year an assessee has incurred any expenditure and he offers no explanation about the source of such expenditure or part thereof, or the explanation, if any, offered by him is not, in the opinion of the Assessing Officer, satisfactory, the amount covered by such expenditure or part thereof, as the case may be, may be deemed to be the income of the assessee for such financial year. When the assessee has provided all the evidences of the payment and the payments are recorded in the books of account, they are not liable to be added u/s. 69C of the Act. Furthermore, the transaction from some of the parties have also been accepted in the subsequent assessment year. It is also not the case that any sales corresponding to the purchases/transactions has been disallowed or doubted. - Decided in favour of assessee.
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