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2021 (11) TMI 499 - AT - Income TaxReopening of assessment u/s 147 - bogus purchases - HELD THAT:- As decided in own case [2021 (8) TMI 1246 - ITAT HYDERABAD] AO had rightly initiated the impugned re-opening process in all these three cases. Estimation of income on bogus purchases - It depends on facts of each and every case than involving any legal interpretation which could be treated as a valid precedent as per the hon'ble jurisdictional high court's decision in CIT Vs. B.R. Constructions [1992 (6) TMI 13 - ANDHRA PRADESH HIGH COURT]. Faced with this situation, we deem it appropriate in larger interest of justice that the impugned bogus purchases in all these three year(s) deserve to be restricted to disallowance @ 8% only in the given facts and circumstances with a rider that the same shall not be taken as a precedent in any other case. Necessary computation shall follow as per law.
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