bank accounts based on
peak theory applied by the ld. CIT(A). In AY 2013-14, the sole ground
of appeal relates to addition ... account of deposits
in his bank account ignoring the peak theory applied by the ld. CIT(A)
in the preceding assessment year
regards confirmation of addition by Ld. CIT(A) on peak theory
basis qua the bogus purchases thereby upholding the order of
Assessing officer (hereinafter called ... made by the
AO under section 69C of the Act on peak theory basis in respect
of bogus purchases.
4. The facts in brief
addition is made, the same
shall be made by applying peak theory for which a working has been submitted.
On careful consideration of facts ... account. Presently, the issues which requires
consideration are as to whether peak theory can be applied in case of appellant and whether the
fact that
accordingly submitted that the Bench's finding that of
peak theory does not apply in this assessment year, therefore, the
directions given ... concerned and basis that, the Bench
has directed application of peak theory in all the three years including AY
2011-12. Hence, the contention
tune of Rs. 10,72,944/-
is based on the peak theory as against Rs. 30,01,930/-
disallowance of bogus purchases made ... extent of
Rs. 10,72,944/- calculated on the basis of peak theory which
comes approximately to 35.75% of the total purchases
The Acit, (Central)-Ii, Bhopal vs M/S. Indus Holidays & Tours India ... on 28
were
similar and in directing the Learned AO to apply the peak theory for A.Y.
2010-11 as well whereas such benefit of peak
year duly accepted by the Revenue
and also ignoring the 'Peak Theory' of the Bank Deposits. Thus the
appeal order so passed
unexplained deposit in the Bank Account,
adopting the peak theory whereas the assessee
had failed to produce any evidence to explain the
source of deposit
erred in rejecting the theory of peak credit and erred in not
allowing the benefit of telescoping, recycling and rotation of funds ... erred in rejecting the theory of peak credit and erred in not
allowing the benefit of telescoping, recycling and rotation of funds.
6. The assessee
