Disallowance Cut to 5% Since AO Failed to Prove Entire Sales Were Unexplained

ITO Vs Ruptex Mineral Water Pvt. Ltd. (ITAT Delhi) Bogus Sales Allegation Cut to Nominal Margin: ITAT Restricts Addition to 5% of Turnover in Accommodation Entry Case AO made addition of ₹1.27 crore u/s 69A alleging accommodation entry sales based on survey statements of third parties, without rejecting books u/s 145(3) or disputing corresponding purchases. CIT(A) held that 100% addition of alleged bogus sales was unjustified where purchases were accepted & restricted addition to profit element by applying GP rate of 13.45%, sustaining addition of ₹17.15 lakh. Tribunal noted that both ...