2021 (10) TMI 959

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....ared on behalf of assessee in spite of calls and even no application for adjournment was moved. On the other hand, Ld. DR is present in the court and is ready with arguments. Therefore, we have decided to proceed with the hearing of the case ex-parte with the assistance of the Ld. DR and the material placed on record. 3. Brief facts of the case are, the assessee is a firm engaged in the business of manufacturing and printing of packaging materials like cartons labels etc. which are mainly used in pharmaceutical industries. The assessee filed return of income for this assessment year 2009-10 on 02.09.2009 and declared total income at Rs. 8,14,180/-. The return was processed u/s 143(1) of the Act. Subsequently, the case was reopened by iss....

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.... will be reasonable to estimate the profit embedded in the accommodation entries of bogus purchases as undisclosed profit of the appellant. 6.3.17 The estimations of profit embedded in accommodation entries of bogus purchases transactions @ 12.5% out of purchase price accounted, through bogus invoices have been upheld as the fair profit rate out of the bogus purchases by the Hon'ble Courts and Tribunals. Under identical facts, the Hon'ble ITAT has upheld disallowance @12.5% of such purchases in the case is of M/s Packwell Service, in ITA No, 6544/Mum/2016 The Gross Profit Ratio of the appellant has it also increased from 17:63 % to 22.37 % during the year. The Net Profit Ratio has increased from 0.48% to 2.18 %. Therefore, ....

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....ture incurred on the purchases corresponding to the purchases recorded in the books of account, remains unexplained. Hence, the expenditure incurred on purchases shown from M/s Raj Traders Rs. 8,23,672/- M/s Nisha Enterprises, Rs. 8,22,219/- and M/s Bright Corporation Rs. 12,91,022/- are held as unexplained expenditure u/s 69C of the Act and consequently an addition of Rs. 29,36,913/- is sustained us 69C of the Act. Further, the profit embedded in the accommodation entries of 'balance amount bogus purchases amounting to Rs. 5,20,150/- from M/s Bright Corporation (The expenses claimed by the appellant on account of purchases from M/s Bright Corporation Rs. 18,11,172/- only, hence any disallowance has to be restricted to the extent of Rs.....