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Where purchases are obtained through accommodation-entry...
Bogus-purchase additions are limited to embedded profit where corresponding sales are accepted, while accommodation-entry information can support reassessment.
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Where purchases are obtained through accommodation-entry providers but corresponding sales remain undisputed, taxation is confined to the profit element embedded in those purchases rather than the entire purchase value. In comparable bogus-purchase transactions, an addition of 15% of the impugned purchases was sustained. Reassessment based on accommodation-entry information is valid where the Assessing Officer supplies recorded reasons, disposes of objections, and possesses prima facie material with a live link to the belief that income escaped assessment. At the reopening stage, the material need not be conclusive; its sufficiency is not examined.
Where purchases are obtained through accommodation-entry providers but corresponding sales remain undisputed, taxation is confined to the profit element embedded in those purchases rather than the entire purchase value. In comparable bogus-purchase transactions, an addition of 15% of the impugned purchases was sustained. Reassessment based on accommodation-entry information is valid where the Assessing Officer supplies recorded reasons, disposes of objections, and possesses prima facie material with a live link to the belief that income escaped assessment. At the reopening stage, the material need not be conclusive; its sufficiency is not examined.
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