The assessee made purchases from certain parties later found to be accommodation entry providers. The AO added the entire amount of such purchases to income since notices issued under section 133(6) were returned unserved. The CIT(A) restricted addition to 12% of purchases considering profit element, while the Tribunal further reduced it to 8%, observing that purchases were made, payments were through account payee cheques, and assessee had already disclosed 7.5% GP. The High Court upheld the Tribunal’s finding. (AY. 2010-11)
PCIT v. Hiren C. Parekh [2023] 153 taxmann.com 470 (Bom)(HC)
S. 69C : Unexplained expenditure-Bogus purchases-Tribunal justified in restricting addition to 8% GP on impugned purchases, as purchases were genuine and paid by cheque. [S. 133(6),
260A]