2024 (6) TMI 335

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.... ORDER PER BIJAYANANDA PRUSETH, AM: This appeal by the assessee emanates from the order passed under section 250 of the Income-tax Act, 1961 (in short, 'the Act') dated 24.11.2023 by the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [in short, 'Ld. CIT(A)'] for the Assessment Year (AY) 2014-15. 2. The grounds of appeal raised by the assessee ....

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....al income of Rs. Nil on 24.09.2014. The case was selected for scrutiny in CASS. During the course of assessment proceedings, the Assessing Officer noticed that the assessee has made transactions with the entities of Bhanwarlal Jain group. The Assessing Officer was in possession of information that a search and seizure action was carried out by the Investigation Wing, Mumbai on the Bhanwarlal Jain ....

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....e assessee went in appeal before the Ld. CIT(A). The Ld. CIT(A) observed that the Assessing Officer made the impugned addition based on the information received from DGIT, Mumbai in a group of cases indulging in providing bills and entries for inflating the purchases. The Assessing Officer made addition at the rate of 100% of bogus purchases. The ld. CIT(A) has confirmed the addition on bogus purc....

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....y taking decision to sustain the addition at the rate of 6% of bogus purchases. Without prejudice to the primary argument, the Ld. AR argued that the addition may be sustained up to 6% of bogus purchases. 7. On the other hand, Learned Senior Departmental Representative (Ld. Sr. DR) for the Revenue submitted that addition made by the Assessing Officer may be sustained as the assessee made bogus ....