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2022 (11) TMI 133 - AT - Income TaxEstimation of income - bogus purchases - CIT(A) restricted the addition to the extent of 5% of aggregate of purchases shown from the entity of Shri Gautam Jain Group - HELD THAT:- Disallowance to the extent of 5% is on lower side particularly when the assessee has shown negligible net profit. The assessee has shown return income of Rs.5,11,120/-only on the turnover of more than Rs.113.00 Crore (Aprox). Thus, in order to meet out the possibility of revenue leakage 6% of the addition of aggregate of disputed purchase will meet the end of justice. We may refer that this combination, where the assessee is beneficiary of similar disputed purchases, either from Rajender Jain, Bhanwar Lal Jain, Gautam Jain or PK Jain, we have consistently restricted or increased the similar addition to 6% of such purchases. Taking the consistent view, the disallowance restricted by ld CIT(A) @ 5% are increased to 6% of the total aggregate of impugned / bogus purchase. Appeal of the Revenue is partly allowed.
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