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2012 (2) TMI 277 - ITAT DELHIAssessee exporting human hair - Cash purchases - AO: disallowed 25% cash & cheque purchases - CIT(A) restricted disallowance upto 20% - Held That:- Quantitative details cannot be accepted to be true and correct because internally prepared purchase memos are not reliable at all in absence of name, address and signature of the vendors. What is surprising is that even signature or thumb impression has not been taken on any memo, which leads to the conclusion that some or all of them have been prepared by the assessee at its convenience. CIT(A) was correct in disallowing 20%. All details were provided for cheque purchases thus no disallowance required. Addition on account of purchases from director - CIT(A): Purchases were made by cheques and duly accounted in stock register - Purchases at Rs.2806/- per kg. as against overall average purchase price of Rs.3233 per kg. - Held That:- When relevant material were on record, additions cannot be made. On the above factual matrices, purchases cannot be disallowed.
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