Dhirajlal Popatlal Shah v. ITO (2021) 92 ITR 647 (Surat)(Trib.)

S. 69 : Unexplained investments-Bogus purchases-Purchase and sale of diamonds-Report of investigation wing-Addition of 100 percent of total transactions was deleted, only addition of Rs. 20,000 was confirmed. [S. 143(3)]

Held that the authorities had not discarded the documentary evidence furnished by the assessee and had solely relied upon the report of the Investigation Wing and had made addition of 100 per cent. of purchase without making any independent investigation.  Tribunal held that to avoid the possibility of revenue leakage, the disallowance of an amount of Rs.20,000 would meet the ends of justice. (AY. 2009-10)