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2020 (10) TMI 877 - AT - Income TaxNon–genuine purchases - CIT- A restricted addition to 12.5% - HELD THAT:- We fully agree with Commissioner (Appeals) that under the given facts and circumstances, the entire purchases made by the assessee could not be disallowed but only the profit element embedded in such purchases can be considered for addition. No hesitation in upholding the decision of the learned Commissioner (Appeals) in restricting the disallowance to 12.5% of the alleged non–genuine purchases. As rightly observed by Commissioner (Appeals), the purchases worth ₹ 39,88,556, made from Sharp Print having been proved through confirmation and supporting evidences, cannot be treated as bogus. Accordingly, we uphold the decision of learned Commissioner (Appeals) by dismissing the grounds raised by the Revenue.
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