ITAT Mumbai Restricts Bogus Diamond Purchase Addition to 3%, Upholds Consistency Principle

Trustar Diamond Vs ACIT (ITAT Mumbai) These cross-appeals were filed by the assessee, Trustar Diamond, and the Revenue against a common appellate order dated February 24, 2023, passed by the National Faceless Appeal Centre (NFAC), Delhi, for the Assessment Year (A.Y.) 2012-13. The appeals concerned an addition made on account of alleged bogus purchases. Factual Background The assessee, a partnership firm engaged in the business and export of diamonds, declared a total income of ₹70,23,920/- for A.Y. 2012-13. The case originated from a search and survey action conducted on October 3, 2013, in...