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ITAT allowed the assessee's appeal regarding bogus purchase additions. The assessee joined M/s. Gauri Construction as partner in AY 2011-12 when it converted from proprietorship to firm. Commercial tax authorities subsequently identified bogus transactions of M/s. Gauri Construction for AY 2010-11, which were incorrectly tagged to the assessee's PAN despite occurring before partnership formation. CIT(A) correctly determined that since all evidence related to M/s. Gauri Construction's transactions, the AO lacked justification for making adverse inferences against the assessee personally. ITAT upheld CIT(A)'s decision to delete the addition, finding no basis for attributing pre-partnership transactions to the individual assessee.
ITAT allowed the assessee's appeal regarding bogus purchase additions. The assessee joined M/s. Gauri Construction as partner in AY 2011-12 when it converted from proprietorship to firm. Commercial tax authorities subsequently identified bogus transactions of M/s. Gauri Construction for AY 2010-11, which were incorrectly tagged to the assessee's PAN despite occurring before partnership formation. CIT(A) correctly determined that since all evidence related to M/s. Gauri Construction's transactions, the AO lacked justification for making adverse inferences against the assessee personally. ITAT upheld CIT(A)'s decision to delete the addition, finding no basis for attributing pre-partnership transactions to the individual assessee.
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