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2023 (7) TMI 285 - HC - Income TaxEstimation of income - bogus purchases - Tribunal reducing the addition to 8% of the value of the tainted purchases as against 12% of the same as held by the CIT(A) - HELD THAT:- What is sufficient reason would vary from case to case, we are satisfied that what has weighed in the mind of ITAT is that assessee had already declared 7.5% as gross profit. Of course, assessee had taken a stand that deference between 12% and 7.5% should be sustained and gross profit of 4.5% be applied. It is this proposal, we feel, made ITAT come to a mid figure of 8%. These are all calculations arrived at on the basis of the facts before ITAT and what is argued before the ITAT. What would be actual profit margin in the business that the assessee was carrying on and the matter of calculation before the concerned authority, whether the purchases were bogus and the parties from whom such purchases were allegedly made were bogus are essentially questions of fact for which evidence will have to be led. No substantial question of law arises.
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