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2019 (3) TMI 1130 - AT - Income TaxReopening of assessment u/s 147 - Disallowance of bogus purchases - addition u/s 69 - HELD THAT:- since the books of accounts of the assessee are unreliable by rejecting the same and invoking the provisions of section 145 (2) AO completed the assessment in the manner provided u/s 144 - HELD THAT:- Assessee could not produce any material evidence of the parties/ intermediaries from whom the purchase from M/S Arihant Exports was made which could be verifiable. Under the above facts and circumstances, we find no infirmity in the order passed by the authorities below. Thus the ground raised by the assessee stands dismissed. Addition of commission expenditure in order to obtain such accommodation entries - assessment year 2014-15 - HELD THAT:- The assessee had obtained accommodation entries of ₹.75,789/- from M/s. Sun Diam, Surat for which commission was paid to the accommodation provider. Since the very nature of business of the accommodation entry provider was to earn ‘commission income’ from the beneficiaries, who had obtained accommodation entries from them, we are of the considered opinion that the Assessing Officer has reasonably estimated the commission of ₹.10,000/- for two bogus bills obtained by the assessee @ ₹.5,000/- per bill, which was rightly confirmed by the ld. CIT(A). - Decided against assessee
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