https://www.taxtmi.com/caselaws?id=425787 In circular trading without physical delivery of goods, only the profit element embedded in bogus purchases can be taxed, not the entire purchase value; the Tribunal also found that estimating that element must be confined to the tainted transactions themselves, and not extended by applying a business-wide gross profit rate or section 44AD. For alleged unexplained expenditure linked to share price manipulation, an addition under section 69C could not survive without cogent evidence that the assessee company actually incurred or benefitted from the expenditure. The profit-element addition was sustained in principle, while the section 69C deletion was upheld. en-us Wed, 27 Jul 2022 00:00:00 +0530 Mon, 01 Aug 2022 09:33:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=425787 In circular trading without physical delivery of goods, only the profit element embedded in bogus purchases can be taxed, not the entire purchase value; the Tribunal also found that estimating that element must be confined to the tainted transactions themselves, and not extended by applying a business-wide gross profit rate or section 44AD. For alleged unexplained expenditure linked to share price manipulation, an addition under section 69C could not survive without cogent evidence that the assessee company actually incurred or benefitted from the expenditure. The profit-element addition was sustained in principle, while the section 69C deletion was upheld. Case-Laws Income Tax Wed, 27 Jul 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=425787