https://www.taxtmi.com/caselaws?id=752529 The ITAT Surat upheld the AO's reopening of assessment under Section 147 regarding bogus purchases. Following the SC precedent in A.L.A. Firm v. CIT, the tribunal found that specific information from investigation wing about entry operators providing bogus entries to the assessee satisfied the twin conditions for valid reassessment. The AO had reason to believe income escaped assessment based on credible sources indicating non-genuine purchases. However, the tribunal limited the disallowance to 6% of disputed purchases, following Pankaj K. Choudhary precedent that only the income component, not the entire transaction, should be taxed to prevent revenue leakage. en-us Mon, 06 May 2024 00:00:00 +0530 Sat, 11 May 2024 12:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=752529 The ITAT Surat upheld the AO's reopening of assessment under Section 147 regarding bogus purchases. Following the SC precedent in A.L.A. Firm v. CIT, the tribunal found that specific information from investigation wing about entry operators providing bogus entries to the assessee satisfied the twin conditions for valid reassessment. The AO had reason to believe income escaped assessment based on credible sources indicating non-genuine purchases. However, the tribunal limited the disallowance to 6% of disputed purchases, following Pankaj K. Choudhary precedent that only the income component, not the entire transaction, should be taxed to prevent revenue leakage. Case-Laws Income Tax Mon, 06 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=752529