https://www.taxtmi.com/caselaws?id=464014 ITAT Surat upheld reopening under section 147 based on investigation information, finding the AO justified in treating purchases as accommodation entries. The rejection of books under section 145 was sustained, as account-payee cheques alone did not establish genuineness. While CIT(A) had restricted additions to 5% of disputed purchases, ITAT assessed that a 6% disallowance on impugned purchases was sufficient to guard against revenue leakage. Result: revenue's appeal partly allowed; assessee's appeal dismissed. en-us Wed, 13 Apr 2022 00:00:00 +0530 Wed, 24 Sep 2025 14:31:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=464014 ITAT Surat upheld reopening under section 147 based on investigation information, finding the AO justified in treating purchases as accommodation entries. The rejection of books under section 145 was sustained, as account-payee cheques alone did not establish genuineness. While CIT(A) had restricted additions to 5% of disputed purchases, ITAT assessed that a 6% disallowance on impugned purchases was sufficient to guard against revenue leakage. Result: revenue's appeal partly allowed; assessee's appeal dismissed. Case-Laws Income Tax Wed, 13 Apr 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=464014