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2023 (10) TMI 211 - HC - Income TaxEstimation of income - Bogus purchases - CIT(A) partly allowed the appeal restricting the disallowance to 5% of the impugned purchases - as per ITAT considering overall facts and circumstances of the present case, disallowances @ 6% of impugned purchases / disputed purchases would be sufficient to meet the possibility of revenue leakage - HELD THAT:- The entire issue was decided based on appreciation of facts where it was found that the assesses had obtained the bill from M/s. Rajan Gems and M/s. Rajat Diamond Pvt. Ltd. which were Shri Gautam Jain and group concerns without actually getting the material. This was nothing but an accommodation entry. The finding of the Tribunal essentially are findings of facts. No substantial question of law is involved.
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