Separate speaking orders on reopening objections are mandatory; deciding them within reassessment invalidates jurisdiction and precludes revival of st...
Compulsorily convertible debentures remain debt before conversion, preventing transfer-pricing and interest-deduction disallowances on the stated fact...
Estimation of income - bogus purchases - The Tribunal considered the facts surrounding the alleged bogus purchases. Despite the inability of the assessee to establish the identity of the parties and the genuineness of the transactions, the Tribunal deliberated on whether the Assessing Officer was justified in adding the entire amount of bogus purchases or only the profit margin. Referring to a precedent set by the Hon’ble Gujarat High Court, the Tribunal concluded that once it is determined that the amount represents alleged bogus purchases from bogus suppliers, it is not necessary to restrict the disallowance. Thus, the Tribunal upheld the addition of 100% of the alleged bogus purchases.
Estimation of income - bogus purchases - The Tribunal considered the facts surrounding the alleged bogus purchases. Despite the inability of the assessee to establish the identity of the parties and the genuineness of the transactions, the Tribunal deliberated on whether the Assessing Officer was justified in adding the entire amount of bogus purchases or only the profit margin. Referring to a precedent set by the Hon’ble Gujarat High Court, the Tribunal concluded that once it is determined that the amount represents alleged bogus purchases from bogus suppliers, it is not necessary to restrict the disallowance. Thus, the Tribunal upheld the addition of 100% of the alleged bogus purchases.
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