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2023 (12) TMI 213 - ITAT MUMBAIEstimation of income - Bogus purchases - HELD THAT:- We find force in the contention of the assessee that the CIT(A) erred in sustaining the 100% disallowance of purchases from two concerns and thus, erred in confirming the addition u/s 69C of the Act. Therefore, as per the ratio laid down by the Hon’ble Courts, profit embedded in the transaction need to be brought to tax particularly when the tax authorities have not disturbed the sales declared by the assessee. We note that the assessee had himself offered profit element @ 6% from purchases from the named parties, thus AO is directed to restrict the addition @ 6% of the disputed purchases. Appeal of the assessee is partly allowed.
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