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2017 (4) TMI 571 - AT - Income TaxUnexplained purchase u/s 69C - addition of the peak of financial transaction - Held that:- The books of accounts of appellant are not maintained on account of any regular business activity but merely it records make-believe transactions that existed only on paper, to build a reservoir of bogus stock earnings in crores which could be transacted on paper so as to explain the introduction of unaccounted cash in the other actual running business of the group or of others. Therefore, the entries were bereft of reality and are prepared only to escape any negative observations of the auditors and authorities. Further, as the total amount invested by the assessee company in the above transaction will properly be taxed if the peak amount is taken as income of the assessee which Ld. CIT appeal has adjudicated, with which we also agree. In view of this we do not find any infirmity in the order of the Ld. CIT appeal in restricting the addition on account of bogus purchases and bogus administrative expenses of ₹ 8517740/– and ₹ 346294/– to the extent of ₹ 1392364/– on the peak basis. - Decided against revenue
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