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2021 (6) TMI 314 - AT - Income TaxEstimation of income - bogus purchases - CIT(A) has restricted the addition to 12.5% of the total amount of bogus purchases shown by the assessee as against 25% addition made by the AO - HELD THAT:- CIT(A) has restricted the addition by following the ratio laid down by the Hon’ble Gujarat High Court in the case of Simit P. Seth [2013 (10) TMI 1028 - GUJARAT HIGH COURT] in which it is held that in the cases of bogus purchases, only profit element embedded in the transaction is to be taken into consideration while determining the addition on estimate basis. In our considered view, the findings of the ld. CIT(A) are well reasoned and in accordance with the settled principles of law. We further notice that the facts of the case relied upon by the revenue are different from the facts of the present case. Hence, we do not find merit in the contention of the revenue. We accordingly dismissed the appeal filed by the revenue and uphold the findings of the ld. CIT(A). - Decided against revenue.
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