Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
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...
The Tribunal held that sales to the assessee's partnership firm were genuine because the alleged bogus-sales finding rested only on third-party statements, while GST returns, Form 26AS, ledger accounts and bank evidence consistently supported the transactions. It noted that corresponding purchases were accepted, stock reduced on sale, and no defect was found in the documentary records or any incriminating material in search. In the absence of material showing the transactions were sham, the Revenue could not estimate commission or profit at 8% on assumptions and conjecture. The addition based on alleged bogus sales was deleted and the appeal was partly allowed.
The Tribunal held that sales to the assessee's partnership firm were genuine because the alleged bogus-sales finding rested only on third-party statements, while GST returns, Form 26AS, ledger accounts and bank evidence consistently supported the transactions. It noted that corresponding purchases were accepted, stock reduced on sale, and no defect was found in the documentary records or any incriminating material in search. In the absence of material showing the transactions were sham, the Revenue could not estimate commission or profit at 8% on assumptions and conjecture. The addition based on alleged bogus sales was deleted and the appeal was partly allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4811 
Join Channel 
