The AO made addition of 25% of unverifiable purchases. The CIT (A) restricted the addition to 15 per cent. of the unverifiable or bogus purchases. The Tribunal confirmed the order passed by the CIT (A) The assessee filed an application for rectification of mistake which was dismissed. On writ dismissing the petition the Court held that the view taken by the appellate authorities was correct.
Lunawat Gems Corporation v .CIT (2020)423 ITR 171 (Raj)(HC)
S. 254(2): Appellate Tribunal-Rectification of mistake apparent from the record –Bogus purchases —Statement by Investigation Wing- Disallowance of 15% of unverifiable purchases – Order of Tribunal is affirmed – Rejection of rectification is held to be justified [ S. 69C , 132 ,147 , 148, Art , 226 ]