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2021 (9) TMI 210 - AT - Income TaxEstimation of income - Bogus purchases - Commissioner (Appeals) restricted the disallowance to 12.5% of the alleged non–genuine purchases - HELD THAT:- As assessee was unable to furnish complete evidences to conclusively prove the source of purchases, however, the fact that the assessee had purchased the goods, possibly from unverified sources, has not been disputed by the Assessing Officer since he has accepted that the disputed goods representing such purchases were in possession of the assessee. Therefore, instead of disallowing the entire purchases, he has restricted the disallowance to gross profit rate declared by the assessee. Whereas, learned Commissioner (Appeals) has restricted such disallowance to 12.5% of non–genuine purchases. The decision of Commissioner (Appeals) in restricting the disallowance to 12.5% of the non–genuine purchases is fair and reasonable, hence, deserves to be upheld.
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