Accommodation Entry Additions Limited to Profit Element, Not Entire Transaction Value in Bogus Transactions

The ITAT held that in cases of accommodation entries, additions should be limited to the profit element embedded in the bogus transactions rather than the entire transaction value. The Tribunal found the Assessing Officer's addition of 10% on total sales and purchases unjustified, as it was made without proper investigation and solely based on the Verification Unit's report, which wasn't provided to the assessee. Following precedent from the Surat Bench in similar cases, the ITAT restricted the addition to 6% of the purchase amount (3,11,75,748) and 0.5% of sales amount (6,20,94,701), acknowledging that only real income after expense set-off can be taxed, not the substantial part of transactions. .....

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