TaxTMI 
TaxTMI 
TaxTMI 
2025 (5) TMI 1584
X X X X Extracts X X X X
X X X X Extracts X X X X
....d Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre (NFAC), Delhi ["Ld. CIT(A)", for short] dated 30.01.2024 for the Assessment Year 2012-13. 2. Brief facts of the case are, assessee filed its return of income declaring income of Rs. 4,85,670/- for AY 2012-13 on 27.09.2012. Subsequently, AO received information from DDIT (Inv.), Unit 6 (2) that assessee has taken accommodation ....
X X X X Extracts X X X X
X X X X Extracts X X X X
....commodation entries 3. Aggrieved with the above order, assessee preferred an appeal before the ld. CIT (A) and before ld. CIT (A), the assessee has not complied to various notices issued. The assessee has not submitted any new material or any additional evidences to support his case. Therefore, ld. CIT (A) has confirmed the additions made by the AO. 4. Aggrieved assessee is in appeal before us r....
X X X X Extracts X X X X
X X X X Extracts X X X X
....s relied upon by the AO and NFAC." 5. At the time of hearing, ld. AR of the assessee submitted that based on the submission of third party in the survey proceedings, the additions were made in the hands of the assessee. He submitted that the case of the assessee was already subjected to regular assessment and AO has accepted the return of income. He submitted that ld. CIT (A) has sustained the ad....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ever, I observed that Hon'ble High Court has considered similar issues and they held that in case of bogus purchases, only certain percentages has to be sustained as income of the assessee considering the actual benefit earned by the assessee in such transactions. I observed that assessee has already declared GP rate of 6.89% in its return of income. Therefore, in my considered opinion, in the cas....