Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
The assessing officer (AO) made additions to the assessee's income based on alleged bogus purchases and unexplained investments. The key points are: Addition of Rs. 209.82 lacs under 'others' category was rightly deleted by CIT(A) due to lack of proper findings. Out of total purchases, Rs. 5,11,56,526 were from 4 entirely bogus parties, while Rs. 5,35,20,325 were partially bogus from 15 parties. Since the assessee offered Rs. 5,53,25,652 as additional income, and considering 10% leakage on partially bogus purchases, the net addition sustained is Rs. 11,82,906. Disallowance of sub-contractor's expenses of Rs. 157 lacs was upheld, as the assessee admitted only Rs. 140.18 lacs, and the GST component was adjusted against output liability. Addition of unexplained investment u/s 69, based solely on loose excel sheets found during search, was deleted following the ITAT's decision in Kranti Impex case, which held that undated, unsigned papers cannot be the sole basis for determining undisclosed income.
The assessing officer (AO) made additions to the assessee's income based on alleged bogus purchases and unexplained investments. The key points are: Addition of Rs. 209.82 lacs under 'others' category was rightly deleted by CIT(A) due to lack of proper findings. Out of total purchases, Rs. 5,11,56,526 were from 4 entirely bogus parties, while Rs. 5,35,20,325 were partially bogus from 15 parties. Since the assessee offered Rs. 5,53,25,652 as additional income, and considering 10% leakage on partially bogus purchases, the net addition sustained is Rs. 11,82,906. Disallowance of sub-contractor's expenses of Rs. 157 lacs was upheld, as the assessee admitted only Rs. 140.18 lacs, and the GST component was adjusted against output liability. Addition of unexplained investment u/s 69, based solely on loose excel sheets found during search, was deleted following the ITAT's decision in Kranti Impex case, which held that undated, unsigned papers cannot be the sole basis for determining undisclosed income.
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