2012 (4) TMI 617

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..... ng to assessment year 2006-07. 2. Only issue in appeal of the assessee is against confirming the addition of ₹ 4,79,175/- by rejecting the books of account under section 145(3) on account of unverifiable purchases. 3. Brief facts of the case are that assessee derived income from salary, house property, other sources and from business and profession, mainly from his proprietary concern, .....

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..... ld. CIT (A) that accounts of the assessee are duly audited under section 44AB. Confirmations of the parties were filed. Payments were made through proper banking channel. Therefore, the AO was not justified in rejecting the books of account. It was further submitted that trading result shown by assessee are better as compared to earlier year. After considering the submissions and perusing the mate .....

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..... of provisions of section 145(3). 4.1. The Jaipur Benches of the Tribunal are also taking consistent view that where certain purchases remain unverifiable, addition by invoking section 145(3) should not be made @ 25% of unverifiable purchases but addition should be made after taking into consideration the past history of the case and current events of the case. Past history of the case is that .....

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