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2016 (7) TMI 912 - GUJARAT HIGH COURTDisallowance on account of unverifiable purchases - Held that:- Assessing Officer has disallowed 10% of the purchases on an ad-hoc basis, whereas the Commissioner (Appeals) has deemed it proper to reduce the disallowance to 2% after considering the gross profit rate and net profit rate. In either case, the disallowance is based on an estimate. While there is no basis for the estimate adopted by the Assessing Officer, there is some basis in the estimate adopted by the Commissioner (Appeals). Under the circumstances, it cannot be said that the impugned order passed by the Tribunal whereby it has upheld the order passed by the Commissioner (Appeals), suffers from any legal infirmity so as to give rise to a question of law, much less, a substantial question of law, warranting interference. - Decided against revenue.
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