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2019 (7) TMI 23 - AT - Income TaxDisallowance @ 10% of the bogus purchases - HELD THAT:- Addition should be restricted to the extent of difference between the “gross profit rate on genuine purchases” and “gross profit rate of hawala purchases”. For these purposes, the matter stands remanded to the file of the Assessing Officer. Considering the commonality of the facts, we are of the opinion the issue under consideration should also be remanded to the file of the AO with similar direction as given in para 4 of the order of M/S. CHHABI ELECTRICALS PVT. LTD. [2017 (6) TMI 514 - ITAT PUNE] AO is also directed to examine the arguments relating to the change of opinion while passing a speaking order on technical ground after granting reasonable opportunity of being heard to the assessee. Accordingly, all the issues raised by the assessee in this appeal both on legal as well as on merits are allowed for statistical purposes.
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