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2020 (12) TMI 767 - AT - Income TaxBogus purchases - unverifiable purchases to the extent of 3% of value thereof as against 10% made by the ld. AO in the assessment - HELD THAT:- CIT(A) had considered the entire modus operandi of the assessee and had accepted the fact that the assessee had indeed made sales out of the disputed purchases and hence, it could be safely presumed that the assessee could have only made purchases from the grey market in order to have some saving in indirect taxes and incidental profits thereon. We find that the ld. CIT(A) had also placed reliance on Mercury International 2016 (8) TMI 1519 - ITAT MUMBAI] case wherein under identical facts and circumstances, this Tribunal had restricted the profit element embedded in the value of disputed purchases at 3%. We find that the ld. DR before us was not able to provide any other contrary decision before us. Hence, we do not find any infirmity in the order of the ld. CIT(A) and accordingly, the grounds raised by the revenue are dismissed.
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