2023 (5) TMI 70 - AT - Income Tax

Assessment u/s 153A - incriminating material found during the search or not? - HELD THAT:- This issue has been decided by the Ld. CIT(A) against the assessee. Since the findings of the Ld. CIT(A) remain uncontroverted by the assessee, we decline to interfere and endorse the findings of the Ld. CIT(A). This ground is rejected.

Estimation of income - bogus purchases - inflation of purchase price so as to suppress true profits - HELD THAT:- Here are evidences to support the contention of the AR that the corresponding material was received and consumed and the corresponding job-work was job done. As such AO has not adversely commented on this aspect. In fact, the AO has not found any fault with the books of accounts which are audited. It is also an important fact that GP ratio of this assessment year works out to be 15.28% whereas much lower GP ratio (12.56%) has been accepted in the A.Y. 2012-13. Not having doubted the consumption/sales, the motive behind obtaining bogus bills thus, appears to be inflation of purchase price so as to suppress true profits.There is nothing in the order of the Ld. CIT(A) requiring our intervention. Accordingly, we reject these grounds of the assessee in all the AYs involved.