Transfer fee demand on leasehold land transfer by statutory corporation challenged; petition dismissed for fact suppression and inapplicable IBC Secti...
Addition under s.69C for alleged bogus purchases was unsustainable because the precondition for s.69C is proof of a genuinely incurred expenditure whose source remains unexplained. Since the assessee's books were not rejected under s.145(3), the purchases were recorded in regular books, and bank statements evidenced sufficient balances and payments, the source of the purchase expenditure was not in dispute. Consequently, s.69C could not be invoked, and the estimated disallowance/profit element addition at 12.5% of purchase value was deleted; the appeal was allowed. - ITAT
Addition under s.69C for alleged bogus purchases was unsustainable because the precondition for s.69C is proof of a genuinely incurred expenditure whose source remains unexplained. Since the assessee's books were not rejected under s.145(3), the purchases were recorded in regular books, and bank statements evidenced sufficient balances and payments, the source of the purchase expenditure was not in dispute. Consequently, s.69C could not be invoked, and the estimated disallowance/profit element addition at 12.5% of purchase value was deleted; the appeal was allowed. - ITAT
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