Bhartiya International Ltd. v. Dy. CIT (2024)112 ITR 207/227 TTJ 897 (Delhi)(Trib)

S. 69C : Unexplained expenditure-Bogus purchases-Sales accepted-Disallowance of purchases are deleted.[S. 37(1)]

Held, that the additions made by the Assessing Officer were not only erroneous but was also contrary to the directions of the Dispute Resolution Panel. While the Assessing Officer had cast doubt on propriety of purchases of fabric made from Sun Gold Trade P. Ltd (STPL)    on the basis of assessment order passed in the hands of the supplier, the Assessing Officer had accepted the corresponding sale transactions. The exclusion of purchases from the trading results was not permissible without corresponding exclusion of the sales in such trading activity for arriving at a fair and balanced view. The action of the Assessing Officer patently was contrary to the rudimentary principles of accounting. Addition is deleted. (AY. 2017-18)