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2019 (3) TMI 62 - HC - Income TaxBogus purchases - addition u/s 69C - Tribunal disallowing 12.5% of the bogus purchases - HELD THAT:- There is no mention of the grievance by the Assessee or even with regard to non-consideration of various documents such as Sales Ledger, Purchase Ledger etc. by AO in the order of the Tribunal. The submission of Assessee that the same was urged before the Appellate Tribunal, but was not considered, cannot be accepted. If the Tribunal had failed to make a note of the submission of a party in its order, then the appropriate remedy for the party was to move the Tribunal for rectification of the order ensuring it that the submissions made by it are recorded in the order. Given the factual matrix that the Appellant had not challenge the finding of bogus purchases, the above issue could not have been raised by it before the Tribunal. Disallowance in the present facts do not give rise to any substantial question of law.
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