PADAM KUMAR AGARWAL,AGRA vs. ITO, CIRCLE 1(1)(1), AGRA, AGRA

ITA 307/AGR/2026Status: DisposedITAT Agra16 September 2026AY 2022-2314 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that the fresh evidence provided by the assessee, which was not examined by the AO, required factual verification. Therefore, the matter was restored to the AO for fresh assessment.

What were the facts?

The assessee claimed purchases of Rs. 1,43,82,973/- from Amrapali Industries Limited. The Assessing Officer (AO) disallowed this amount as the supplier's initial response to a notice indicated lower sales. The assessee later provided a clarification from the supplier stating an omission in their initial reply.

What were the issues?

Whether the disallowance of purchases was justified when the supplier later clarified an omission, and whether the assessee was given a proper opportunity to present this evidence.

Which sections of the Income-tax Act were involved?

Section 37,Section 133(6),Section 250

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, AGRA(DB

Before: SUNIL KUMAR SINGHBRAJESH KUMAR SINGH

For Appellant: Shri Rajesh Malhotra, CA
Hearing: 08.07.2026Pronounced: 16.09.2026

PER:BRAJESH KUMAR SINGH, A.M.

This appeal is directed against the impugned order dated 09.02.2026 passed in appeal No NFAC/2021-22/10368054 by the NFAC (hereinafter referred to as the Commissioner of Income Tax), u/s. 250 of the Income Tax

ITA 307/Agr/2026

Act, 1961 (hereinafter referred to as the “Act”) for the A.Y. 2022-23, wherein ld. CIT (A) has dismissed assessee’s appeal.

2.

Brief facts the case: The assessee e-filed its return of income for the AY 2022-23 on 26.09.2022 vide acknowledgement no. 540959641260922 declaring a gross total income of Rs. 18,92,150/-. The case was selected for complete scrutiny under CASS for the following issues:

(i) Large turnover from the Gems and Jewellery

The order continues below.

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