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2021 (6) TMI 971 - AT - Income TaxBogus purchases - Estimation of income - CIT-A restricted the disallowance to 25% - HELD THAT:- Assessee may not have been able to prove the genuineness of purchases from the declared source, however, it is a fact on record that the Assessing Officer has not disputed the sales effected by the assessee - assessee must have purchased goods from some other undisclosed source or from grey market - it is the settled legal position that the entire purchases cannot be disallowed, but only the profit element embedded in such purchases can be considered for addition. Therefore, we restrict the disallowance to 25% of the non-genuine purchase is fair and reasonable - Decided against revenue.
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