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ITAT found AO's calculation of undisclosed income from alleged bogus share purchases to be incorrect. While the broker's contract note was suspended by NSE, no allegations were made against sale transactions or declared profits. The CIT(A)'s deletion of excess addition was upheld. Following precedent from jurisdictional HC in similar cases where 12.5% of bogus purchases was deemed reasonable, ITAT determined the addition confirmed by CIT(A) was unwarranted. The assessee's appeal was allowed, resulting in complete deletion of the disputed addition. The tribunal emphasized that when sales and profits are accepted, merely questioning purchase transactions without substantial evidence is insufficient for sustaining additions.
ITAT found AO's calculation of undisclosed income from alleged bogus share purchases to be incorrect. While the broker's contract note was suspended by NSE, no allegations were made against sale transactions or declared profits. The CIT(A)'s deletion of excess addition was upheld. Following precedent from jurisdictional HC in similar cases where 12.5% of bogus purchases was deemed reasonable, ITAT determined the addition confirmed by CIT(A) was unwarranted. The assessee's appeal was allowed, resulting in complete deletion of the disputed addition. The tribunal emphasized that when sales and profits are accepted, merely questioning purchase transactions without substantial evidence is insufficient for sustaining additions.
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