https://www.taxtmi.com/caselaws?id=448086 The ITAT Surat allowed the assessee's appeal partly in a bogus purchase case. The AO had added 25% of alleged inflated purchases based on seized excel sheets from a search under section 132, but proceeded under section 147 instead of 153A. The Tribunal found no evidence of stock discrepancies, adverse seller statements, or comparable industry GP rates. While staff statements during search accepted inflated purchases (later retracted), the Tribunal noted the assessee's declared income of Rs. 10.87 crores was higher than previous years, with GP at 8.68% compared to 7.69% earlier. Considering only profit element should be taxed in bogus purchases, the Tribunal increased GP to 9.00% instead of the AO's 7.5% addition on Rs. 36.05 crores, finding the latter excessive. en-us Thu, 28 Dec 2023 00:00:00 +0530 Thu, 11 Jan 2024 09:24:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=448086 The ITAT Surat allowed the assessee's appeal partly in a bogus purchase case. The AO had added 25% of alleged inflated purchases based on seized excel sheets from a search under section 132, but proceeded under section 147 instead of 153A. The Tribunal found no evidence of stock discrepancies, adverse seller statements, or comparable industry GP rates. While staff statements during search accepted inflated purchases (later retracted), the Tribunal noted the assessee's declared income of Rs. 10.87 crores was higher than previous years, with GP at 8.68% compared to 7.69% earlier. Considering only profit element should be taxed in bogus purchases, the Tribunal increased GP to 9.00% instead of the AO's 7.5% addition on Rs. 36.05 crores, finding the latter excessive. Case-Laws Income Tax Thu, 28 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=448086