Accra Pac (India) Pvt. Ltd. v. Dy. CIT (2022) 100 ITR 30 (SN) (Ahd)(Trib)

S. 69C : Unexplained expenditure-Unable to identify the purchasers-Sale of finished goods subject to tax-Entire purchases cannot be disallowed-Addition was restricted to 10% of purchases-Income from undisclosed sources-Fixed deposit in bank-Matter remanded. [S. 68, 26AS]

Tribunal held that though the assessee is unable to identify the  purchasers, sale of finished goods was  subject to tax, therefore entire purchases cannot be disallowed. Addition was  restricted to 10% of purchases. Difference between fixed deposit shown by assessee and investments shown in annual information. Matter remanded to Assessing Officer for verification. (AY.2011-12)