The Assessee runs a proprietorship. On information received from investigation wing, the AO treated the purchase made by the Assessee as bogus and proceeded to disallow the purchases and made an addition. CIT(A) confirmed the addition. On appeal for A.Y. 2013-2014, the Tribunal observed that the AO has accepted the sales declared by the Assessee and only proceeded to disallow purchases. Hence, the Tribunal held that the AO cannot proceed to disallow only the purchases in isolation and the Tribunal disallowed the purchases at 12.5%. On appeal for A.Y. 2014-15, the Tribunal observed that the Assessee had only made payments towards purchases from previous year, hence the addition for A.Y. 2014-15 was unjustified. (AY. 2013-2014,2014-2015)
Manak Chand Daga v. ITO (2025) 233 TTJ 11 (UO) (Delhi)(Trib)
S. 69C : Unexplained expenditure-Information from Invetsigation wing-The AO cannot proceed to disallow only the purchases in isolation and the Tribunal disallowed the purchases at 12.5%. On appeal for A.Y. 2014-15, the Tribunal observed that the Assessee had only made payments towards purchases from previous year, hence the addition for A.Y. 2014-15 was unjustified. [S. 147, 148]
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