Section 69C Not Applicable to Recorded Purchases: ITAT Delhi Deletes 12.5% Estimation

Vinod Kumar Goyal Vs NFAC (ITAT Delhi) Section 69C Can’t Be Used for Recorded Purchases: No 145(3), No Disallowance—ITAT Delhi Deletes 12.5% Estimation Assessee, engaged in trading of iron & steel, faced addition of ₹1.03 crore by estimating profit @12.5% of purchases, invoking s.69C on the allegation of bogus purchases, merely because notices u/s 133(6) issued to suppliers were not complied with. AO accepted sales, did not reject books u/s 145(3), and brought to tax only the so-called “profit element”. NFAC confirmed the addition without independent findings. ITAT Delhi allowed ...