Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2021 (2) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2021 (2) TMI 779 - ITAT MUMBAIEstimation of income - bogus purchases - assessee failed to prove the genuineness of the transaction to the satisfaction of the AO - CIT (A) after hearing the assessee restricted the addition to 12.5% of the total amount of bogus purchases - HELD THAT:- AO has not rejected the sales of the assessee. Since there can be no sale without purchases, the Ld CIT(A) has rightly concluded that the assessee had purchases the material from the parties other than the parties mentioned in its books of account. Under these circumstances, the Ld. CIT (A) has rightly restricted the addition to 12.5%, keeping in view the profit element embedded in the transactions in question. In our considered view, the findings of the Ld. CIT (A) are well reasoned and based on the law laid down in SIMIT P SHETH [2013 (10) TMI 1028 - GUJARAT HIGH COURT] no reason to interfere with the findings of the Ld. CIT (A) - Decided against revenue.
|