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2021 (3) TMI 164 - AT - Income TaxEstimation of income - bogus purchases - Commissioner (Appeals) restricted the disallowance to 12.5% of the disputed purchases - HELD THAT:- AO disallowed entire purchases made from M/s. Sumit Sales on the reasoning that the assessee was unable to furnish any evidence to prove that purchases, however, as observed by Commissioner (Appeals), the Assessing Officer has not disputed that the assessee had effected the corresponding sales. Assessee might have purchased the goods from grey market by suppressing the profit element. In such circumstances, as rightly held by Commissioner (Appeals), only the profit element embedded in such purchases can be considered for addition. Further, in my considered opinion, the disallowance sustained by Commissioner (Appeals) by estimating the profit rate at 12.5% is fair and reasonable; hence, does not require any interference. Ground raised is dismissed.
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