DCIT Vs Sunder Das Sonkiya Flat Sonkia Bhawan (ITAT Jaipur)
ITAT Jaipur held that CIT(A) rightly deleted the addition towards bogus purchases by considering profit declared by the assessee as 13.05%. Accordingly, appeal filed by the revenue dismissed.
Facts- The assessee is an Individual and is engaged in export of gems & jewellery after purchasing it from local market under the name & style of M/s S Naveen Jewellers. The return was processed u/s 143(1) and no notice u/s 143(2) was issued. Thereafter AO after approval from competent authority-initiated reassessment proceedings by issue of notice u/s 148 on 28-032019 after recording reasons. As the assessee has inflated his purchases by Rs. 1,73,34,424/- by way of introducing non-genuine/unverifiable/bogus purchases in his books of account from the entry providers it can easily be concluded that the assessee has also reduced his taxable business profit to the extent of Rs. 1,73,34,424. Therefore, there exist escapement of income and proceeding u/s. 148 was initiated.
The reassessment u/s 143 (3)/147 completed by the AO at an income of Rs. 43,57,610/- by taking total income at 24,000 as per return filed and by disallowing 25% of said purchases of Rs. 1,73,34,424/- amounting to Rs 43,33,606 holding them as non- genuine purchases and added the same as income of the assessee.
