PCIT v. Dhondiram Narayan Limbhore (2023) 153 taxmann.com 539 (Bom)(HC) Editorial : SLP of revenue dismissed, PCIT v. Zahira R. Khatun (2025) 304 Taxman 514 (SC)

S. 69C : Unexplained expenditure-Bogus purchases-No discrepancy between purchases and sales shown -Entire purchase cannot be added-Order of High Court dismissed the appeal of the revenue is affirmed.[S. 260A]

Assessing Officer added  certain purchases made by assessee were bogus. He,  added said amount to assessee’s taxable income. Tribunal deleted the addition.  On appeal the Court  following the ratio in Pr. CIT v. Mohommad Haji Adam & Co. (2019) 103 taxmann.com 459 (Bom)(HC) held that where there was no discrepancy between purchases shown by assessee and sales declared, entire amount of bogus purchases could not be treated as income of assessee and addition was to be limited to extent of bringing gross profit rate on purchases at same rate as applied in other genuine purchases.   

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