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2021 (10) TMI 652 - ITAT MUMBAIEstimation of income - bogus purchases - CIT(A) worked out the profit element embedded in the impugned purchases at 15% of the value of such purchases - HELD THAT:- The impugned purchases formed part of the sales/contract receipts of the assessee had not been dislodged by the A.O, therefore, it can safely be gathered that the assessee had procured the impugned material not from the aforementioned hawala parties but from the open/grey market. After giving a thoughtful consideration to the observations of the CIT(A), we do not find any infirmity in the view taken by him that the addition qua the impugned purchases claimed by the assessee to have been made from the aforementioned party was liable to be restricted only to the extent of the profit which the assessee would have made by procuring such goods at a discounted value from the open/grey market. Quantification of the aforesaid profit element we are of the considered view that the CIT(A) had taken the GP rate of the assessee for the last eight years i.e. AY 2007-08 to AY 2014-15 of 15.88% as a yardstick and on the said reasoned basis restricted the addition to 15% of the value of the impugned bogus purchases of ₹ 2,12,513/-. Accordingly, backed by our aforesaid deliberations we find no merit in the appeal of the revenue and dismiss the same. The Grounds of appeal dismissed.
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