Prime Steel Industries (P) Ltd. v. Dy.CIT (2024) 232 TTJ 1026/ 38 NYPTTJ 1201 (Chd)(Trib)

S.69C: Unexplained expenditure-Alleged bogus purchases-Income from undisclosed sources-No justification in making addition at the rate of 12.5 percent.

AO made addition at the rate of 12.5 per cent on alleged bogus purchases.  CIT(A) has accepted that purchases were genuine (though made from unverifiable sources) because goods manufactured from such purchases were accepted by the AO and has also given his finding that the rates of procurement of such purchases by the assessee are either at par or even below the market rate on which the assessee has procured such alleged purchases-Accordingly, CIT(A) accepted the books of account of the assessee and calculated the profit @ 5.94 per cent, which is the GP rate declared by the assessee. No justification in making addition. (AY. 2021-22)

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