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2021 (12) TMI 51 - ITAT PUNERevision u/s 263 by CIT - Bogus purchases - disallowance at 20% of such bogus purchases - HELD THAT:- As in the facts and situation wherein bogus purchases were made and they were consumed, the Hon’ble Jurisdictional High Court has held 10% addition of such bogus purchases to be reasonable, whereas, in this case, the AO in the assessment order has made disallowance at 20% of such bogus purchases which is more than that held by M/S. PARAMSHAKTI DISTRIBUTORS PVT. LTD. [2019 (7) TMI 838 - BOMBAY HIGH COURT]. In such scenario, there should not be any grievance of the Revenue and revisionary jurisdiction assumed by the Ld. Pr. Commissioner of Income Tax u/s.263 of the Act is therefore uncalled for. Accordingly, we hold that the order passed by the Ld. Pr. Commissioner of Income Tax u/s.263 of the Act is not valid in law under the given circumstances. Hence, we allow the appeal of the assessee.
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