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2021 (12) TMI 97 - AT - Income TaxEstimation of income - bogus purchases - HELD THAT:- As decided in M/S. CHORON DIAMOND (I) PVT. LTD. AND VICE-VERSA [2017 (11) TMI 184 - ITAT MUMBAI] AO and the CIT(A) after examining the documents furnished by the assessee have concluded that the assessee has obtained bogus purchase bills from suspicious dealer. It is observed that although the dealer from whom the assessee has made alleged bogus purchases has confirmed the sale transactions but no document in the form of stock inward register, delivery receipt, etc. has been furnished by the assessee to prove trail of goods. The assessee has failed to discharge its onus in proving authenticity of purchase transactions. Therefore, the primary contention of the assessee to delete entire addition is rejected. Tribunal in the case of assessee engaged in trading of diamonds restricted the addition to 2% of unproved purchases. Considering the fact that the nature of assessee’s business and the nature and manner of addition is similar to the one referred in the aforesaid case, the addition on account of unproved transactions in the instant appeal is restricted to 2%.
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