PCIT v. Deepak Banwarilal Agarwal (2025) 478 ITR 572 (Guj)(HC) PCIT v. Dilkhush Babel (2025) 478 ITR 611 (Guj)(HC) PCIT v. Enviro Control Pvt. Ltd (2025) 478 ITR 683 (Guj)(HC)

S. 69C : Unexplained expenditure-Bogus purchases-Accommodation entries-Business of import and export and trading of diamonds-Information from Investigation Wing-Tribunal restricting disallowance to six per cent. based on assessee’s turnover and net profit justified-No question of law arose.[S. 147, 260A]

The assessee was in the business of import and export and trading of diamonds. On the basis of information received from the Investigation Wing that the assessee had received accommodation entries of bogus purchases, the Assessing Officer disallowed the entire alleged bogus purchases. The Commissioner (Appeals) restricted the addition to five per cent. of the unverified purchases. The Tribunal held that the Assessing Officer was not justified in disallowing the 100 per cent. of purchases in the absence of proper investigation of such purchases and that the assessee had shown total turnover of Rs.186.96 crores and a net profit at 0.0051 per cent., which was extremely on the lower side and restricted the addition to six per cent. On appeal High  Court affirmed the order of the Tribunal.(AY.2013-14) (AY. 2008-09) (AY. 2011-12)

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