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2022 (6) TMI 412 - AT - Income TaxEstimation of income - bogus purchases - disallowance as restricted to 25% - discrepancy in the confirmation by assessee and assessee was asked to produce the parties and that none of the parties were produced by assessee - HELD THAT:- Assessee filed detailed written submission and the evidences to prove the identity, creditworthy of the parties and genuineness of the transaction. We find that the assessee furnished name, address, PAN, the amount was received by cheques and repayment by cheque, confirmation and balance-sheet were amounts of outstanding were provided. AO has not brought any adverse evidence against the transaction of four parties. We find that Ld. CIT(A) considering the evidence held that the Ld. CIT(A) deleted the addition on appreciation of sufficient evidence available on record which was conveniently ignored by Assessing Officer. We find that the AO made addition of entire unsecured loan on the basis of statement of Suresh Kumar Modi (HUF) and Shri Amit Kumar Modi. We further find that assessee availed loan of Rs.5.00 lakh from Basuki Synthetics Pvt. Ltd, which is clearly evident from the ledger account filed by the assessee - Assessing Officer made addition of Rs.10.00 lakh as loan. We find that the Ld. CIT(A) deleted the addition on appreciation of evidence available on record. - Decided against revenue.
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