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2021 (3) TMI 632 - AT - Income TaxEstimation of income - Bogus purchases - HELD THAT:- Nature of business of the assessee and the nature of investigation done by the AO and thereafter, held that disallowance be kept at 6.75% (being gross profit rate) of transactions covered by accommodation entries. CIT(A) has taken note of the fact that the AO has not issued notice u/s 133(6) to the said parties to verify the genuineness of purchases. We agree with the above findings of the Ld. CIT(A) and affirm his order. Again considering the facts and circumstances of the case for AY 2010-11, the Ld. CIT(A) has restricted the disallowance to 8.25% (being a rate higher than gross profit rate on account of fact that deficiency is reasonably proved by the Assessing Officer) of transactions covered by accommodation entries. For AY 2011-12, the Ld. CIT(A) has followed the rate applied for AY 2009-10 i.e. 6.75% of value of accommodation entries found to be bogus on the ground that the facts for AY 2011-12 are similar to AY 2009-10.
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