KAMAL KISHORE SONI,MUMBAI vs. INCOME TAX OFFICER 2(3)(7), SURAT

ITA 1164/SRT/2025Status: DisposedITAT Surat16 September 2026AY 2011-127 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal upheld the CIT(A)'s decision to restrict the addition to 6% of the bogus purchases. This was based on previous decisions in the assessee's own case and other similar cases, including those upheld by the High Court and Supreme Court.

What were the facts?

The assessee, engaged in diamond business, was found to have made bogus purchases of Rs. 6,39,80,972/- during AY 2011-12. The AO made an addition of 100% of these bogus purchases, which the CIT(A) reduced to 6% of the purchases.

What were the issues?

Whether the addition sustained by the CIT(A) at 6% of bogus purchases is justified, considering the assessee's claim of lower profit margins and the revenue's reliance on judicial precedents.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 147

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, SURAT BENCH, SURAT

Before: MS. SUCHITRA KAMBLE & SHRI B.M. BIYANI

For Appellant: Shri Vimal Punmiya, AR
For Respondent: Shri Ravi Kant Gupta, CIT(DR)
Hearing: 23.06.2026Pronounced: 16.09.2026

Per B.M. Biyani, A.M.:

Feeling aggrieved by the order of first appeal dated 04.09.2025 passed by learned Commissioner of Income-Tax (Appeals)-4, Surat [“CIT(A)”], which in turn arises out of the assessment-order dated 19.12.2018 passed by learned ITO, Ward-2(3)(7), Surat [“AO”] u/s 143(3) r.w.s. 147 of Income-tax Act, 1961 [“the Act”] for Assessment-Year [“AY”] 2011-12, the assessee has filed this appeal on the grounds as raised in Form No. 36 (Appeal Memo).

2.

The background facts leading to present appeal are as under:

Kamal Kishore Soni ITA No. 1164/SRT/2025 – AY 2011-12 (i) The assessee-individual is engaged

The order continues below.

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