On review of searches related to the Bhanwarlal Jain Group, the Revenue treated all purchase transactions as bogus, resulting in a 100% disallowance by the AO. However, the CIT(A) limited this disallowance to 6%, a decision upheld by the Tribunal. The Court dismissed Revenue’s appeals for assessment years 2011-12 and 2013-14, affirming that only the income component of bogus purchases should be taxed.(AY. 2011-12) (AY. 2013-14)
PCIT v. Mohit Pukhraj Kawdiya (No. 1) (2025) 481 ITR 310 / 181 taxmann.com 712 (Guj.) (HC) PCIT v. Mohit Pukhraj Kawdiya (No. 2).(2025) 481 ITR 318 / taxmann.com 712 (Guj)(HC)
S. 69C : Unexplained expenditure-Bogus purchases-Accommodation entries from Bhanwarlal Jain Group-Addition restricted to 6 per cent of bogus purchases is fair and reasonable. [S. 147, 148, 260A]
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