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2021 (2) TMI 355 - AT - Income TaxEstimation of income - bogus purchases - assessee neither could produce the concerned parties nor could furnish transportation bills, weighment bills, etc. - Commissioner (Appeals) restricted the addition to 12.5% of the alleged non-genuine purchases - HELD THAT:- The very fact that the Assessing Officer did not disallow the entire purchase but has restricted the disallowance to 15% of the alleged non-genuine purchases indicates that the Assessing Officer also believes that the assessee had purchased the goods, though, may not be from the declared source. Therefore, he has proceeded to add the profit element embedded in such purchases. Considering the nature of business carried on by the assessee and keeping in view the decision of the Tribunal in similar nature of cases, learned Commissioner (Appeals) decision to restrict the disallowance to 12.5% of the alleged non genuine purchases is fair and reasonable. Therefore, the order of learned Commissioner (Appeals) is upheld by dismissing the grounds raised by the Revenue.
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