Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Bogus purchase additions based on estimated profit were deleted where the assessee produced GST-linked purchase records, quantitative stock statements, movement details and payment evidence, and none of those books or results were found defective. In the absence of rejection of books or any finding that the disclosed gross profit was unreasonable, an 8% profit estimate on alleged bogus purchases was impermissible. The addition for alleged cessation of liability was also deleted because the ledger balance was supported by invoices and bank payments, and no adverse factual finding displaced that documentary evidence.
Bogus purchase additions based on estimated profit were deleted where the assessee produced GST-linked purchase records, quantitative stock statements, movement details and payment evidence, and none of those books or results were found defective. In the absence of rejection of books or any finding that the disclosed gross profit was unreasonable, an 8% profit estimate on alleged bogus purchases was impermissible. The addition for alleged cessation of liability was also deleted because the ledger balance was supported by invoices and bank payments, and no adverse factual finding displaced that documentary evidence.
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