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2021 (10) TMI 3 - AT - Income TaxEstimation of income - bogus purchases - CIT-A estimated at 12.5% of the aggregate value of the impugned purchases - HELD THAT:- CIT(A) had rightly concluded that as the sales could not have been carried out de hors the corresponding purchases thus, it could safely be concluded that the assessee had purchased the goods in question though not from the aforementioned hawala parties, but at a discounted value from the open/grey market - CIT(A) in our considered view had rightly restricted the addition to the extent of the profit embedded in procuring of the impugned goods at a discounted value from the dealers operating in the open/grey market. We concur with the view taken by the CIT(A) that the addition in the hands of the assessee was liable to be restricted only to the extent of the profit element embedded in the impugned purchases in question. Also, we subscribe to the quantification of the said profit element by the CIT(A) at 12.5% of the aggregate value of the impugned purchases. - Decided against revenue.
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