Bogus Purchase: Disallowance may be restricted to the extent of profit embedded in such purchases

Advertisement ITO Vs Shree Deepak Banwarilal Agarwal (ITAT Surat) We find that during the assessment the AO made addition of 100% of purchases shown by the assessee from four parties which were managed by “PK Jain” and his group. The AO made addition on the basis of report of Investigation Wing about the search & seizure made at the ‘PK Jain’ group and the statement recorded therein by taking view that there was clinching evidence collected by Investigation agency that the assessee is beneficiary of the accommodation entry. The AO rejected the contention of assessee is that they...