PCIT v. Amit Tarachand Jain (2025) 476 ITR 74 (Guj) (HC)

S. 69C : Unexplained expenditure-Bogus purchases-Only income component of disputed purchases taxable-Restriction of disallowance by Tribunal to six per cent. justified. [S. 132, 143(3) 147, 260A]

Held, dismissing the appeal, that the Tribunal was justified in estimating the disallowance of the alleged bogus purchases at six per cent. relying on the decision in Mayank Diamonds Pvt. Ltd. v. ITO, (2014) 11 TMI 812 (Guj) against the 100 per cent. disallowance of the purchases made by the Assessing Officer.(AY. 2013-14)

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