2024 (3) TMI 1074

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.... PER AMIT SHUKLA (J.M): The aforesaid appeal has been filed by the Revenue against order dated 28/06/2023 passed by NFAC, Delhi for the quantum of assessment passed u/s. 143(3) for the A.Y. 2010-11. 2. In the grounds of appeal, the Revenue has challenged the action of the ld. CIT(A) in restricting the disallowance to 12.5% of the purchases instead of addition made by the ld. AO for the entir....

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....entire amount of Rs. 14,90,401/- u/s. 69C. 5. The ld. CIT (A) has restricted the addition while estimating the GP rate of 12.5% on the total bogus purchases from various parties. 6. After hearing the ld. DR and on perusal of the impugned order, we find that AO has made addition on account of entire purchases which is wholly unjustified, because once the source of purchases have been debited ....