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2024 (6) TMI 335 - AT - Income TaxIssues involved: The judgment involves the confirmation of 100% disallowance of alleged purchases, restriction of purchase to the profit element, and the sustenance of addition at the rate of 6% of bogus purchases. Confirmation of 100% disallowance of alleged purchases: The assessee's appeal stemmed from an order under section 250 of the Income-tax Act, 1961, for the Assessment Year 2014-15. The Assessing Officer added Rs. 1,31,21,120/- as bogus purchases to the total income of the assessee based on information regarding accommodation entries from Bhanwarlal Jain group entities. The CIT(A) upheld the addition at 100% of total purchases. However, the ITAT Surat, citing a previous decision, confirmed the addition at 6% of bogus purchases, maintaining consistency and partly allowing the appeal. Restriction of purchase to the profit element: The assessee argued that genuine purchases were made and provided various documents to support the genuineness of the transactions. The sales of the assessee were not in question. The ITAT Surat had previously upheld additions in similar cases at a rate of 6% of bogus purchases. Considering this precedent, the ITAT confirmed the addition at 6% of bogus purchases, partially allowing the appeal. Sustenance of addition at the rate of 6% of bogus purchases: Both the assessee and the Revenue presented arguments regarding the addition made by the Assessing Officer for bogus purchases. The ITAT Surat referred to a previous decision where a similar addition was sustained at 6% of bogus purchases. Relying on this precedent and finding no change in facts, the ITAT confirmed the addition at 6% of bogus purchases, partially allowing the appeal. In conclusion, the ITAT Surat upheld the addition at the rate of 6% of bogus purchases, citing consistency with previous decisions, and partly allowed the appeal of the assessee.
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