The Tax Publishers2020 TaxPub(DT) 3751 (Pune-Trib)

INCOME TAX ACT, 1961

Section 69C

Since restriction of addition to 3% made by CIT(A) of alleged bogus purchases in dispute was fair and reasonable and there was no justifiable reasons to interfere with same. Accordingly order of CIT(A) giving relief to assessee on said issue was upheld and appeal of revenue was dismissed.

Income from undisclosed sources - Addition under section 69C - Addition of entire bogus purchases when corresponding sales were accepted by revenue -

AO made addition on allegation of bogus purchases under section 69C for purchases allegedly made by assessee from concerned Hawala parties as unexplained expenditure. However, on appeal, CIT(A) restricted addition to 3%. Held: There being corresponding sales made by assessee out of the purchases alleged to be bogus by AO as established by assessee on basis of quantitative details, entire purchases could not be treated as bogus. Disallowance of 3% made by CIT(A) of purchases in dispute was fair and reasonable and there was no justifiable reasons to interfere with same. Accordingly, order of CIT(A) giving relief to assessee on said issue was upheld and appeal of revenue was dismissed.

REFERRED :

FAVOUR : In assessee's favour

A.Y. :



INCOME TAX ACT, 1961

Section 69C

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