Prime Steel Industries (P.) Ltd. v. Dy. CIT (2025) 123 ITR 107 / 174 taxmann.com 547 (Chd.)(Trib.)

S. 69C: Unexplained expenditure-Bogus purchases-Books of account accepted by Commissioner (Appeals)-Purchases at prevailing market rates-No profit embedded-Addition deleted.[S.133(6) 145(3)]

The Assessing Officer, on the basis of information received from the GST Department regarding cancellation of registration of certain suppliers, treated purchases made from those parties as bogus, rejected the books of account under section 145(3) and estimated the profit embedded in such purchases at 12.5 per cent. The Commissioner (Appeals) accepted the books of account and restricted the addition to the declared gross profit rate of 5.94 per cent. The Tribunal held that once the books of account had been accepted and the purchases were found to have been made at rates comparable to or lower than other purchases, there was no basis to presume any additional profit. The entire addition was therefore deleted. (AY. 2021-22).

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