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2023 (6) TMI 929 - AT - Income TaxEstimation of income - Bogus purchases - amount already surrendered by the assessee - HELD THAT:- Assessee against the amount of bogus purchases, unutilized surrender was adjusted by the AO towards the addition, meaning thereby that the addition to that extent got confirmed and adjusted against the amount already surrendered by the assessee, leaving the net amount of disallowance. The amount of set off represents 85% of the amount of bogus purchases. AR submitted that the assessee had profit margin of 22.83%. Addition confirmed and adjusted at 85% of the bogus purchases is far in excess of the gross profit margin on such accommodation entries. This proves that the amount of addition sustained is not called for. The same is directed to be deleted. This ground is allowed.
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