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2023 (4) TMI 577 - AT - Income TaxEstimation of income - bogus purchases - HELD THAT:- Assessee has failed to prove the genuineness of the purchases made from these entities. Revenue has not doubted the sales declared by the assessee. Further, it cannot be doubted that without the purchase of material, the manufacturing activity of the assessee’s concern cannot be carried out. Therefore, it appears to be a case of bogus bills arranged from the aforesaid entity and material purchased from somewhere else at a lower cost. Entire bogus purchases cannot be added in such a case. We are of the considered view that a reasonable disallowance of the purchases would meet the possibility of revenue leakage - no infirmity in the addition of 12.5% of disputed purchases as sustained by the learned CIT(A). We find that the same is also in line with the judgment of the Hon’ble jurisdictional High Court in PCIT vs Paramshakti Distributors Ltd. [2019 (7) TMI 838 - BOMBAY HIGH COURT] - Appeal by the Revenue is dismissed.
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