HIDESQUARE EXPO LLP,NOIDA, UTTAR PRADESH vs. ASSESSING OFFICER, GAUTAM BUDDH NAGAR, NOIDA

PDF · subscribers
ITA 3393/DEL/2026Status: DisposedITAT Delhi08 September 2026AY 2020-213 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal rejected the assessee's book entries to the extent of the impugned purchases. A lumpsum Gross Profit addition of Rs. 1 lakh was made to the assessee's income.

What were the facts?

The assessee's purchases of Rs. 10,00,010/- were treated as bogus by the lower authorities. The assessee is in the business of manufacturing and supplying leather goods, and their sales were not questioned.

What were the issues?

Whether the purchases treated as bogus by the revenue authorities are indeed bogus, and if so, what is the appropriate addition to be made to the assessee's income.

Which sections of the Income-tax Act were involved?

Section 69C

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH: ‘A’ NEW DELHI

Before: SHRI SATBEER SINGH GODARA & SHRI NAVEEN CHANDRA

Hearing: 29.07.2026Pronounced: 29.07.2026

IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘A’ NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER ITA No.3393/Del/2026 Assessment Year: 2020-21 M/s. Hidesquare Expo LLP, Vs. Assessing Officer, B-53, II Floor, Sector-67, Circle-5(1)(1), Gautam Buddha Nagar, Gautam Buddha Nagar, Noida Noida PAN: AAIFH7650P (Appellant) (Respondent) Assessee by Sh. Arvind Kumar Raj, CA Department by Sh. Balkishan Gopal, Sr. DR Date of hearing 29.07.2026 Date of pronouncement 29.07.2026 ORDER PER SATBEER SINGH GODARA, JM This assessee’s appeal for assessment year 2020-21, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s DIN and order no. ITBA/NFAC/S/250/2025-26/1085267144(1), dated 29.01.2026 involving proceedings under section 147 r.w.s. 144 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’). Heard both the parties. Case file perused.

ITA No.3393/Del/2026

2.

It emerges during the course of hearing that the assessee presses for his sole substantive ground on merits challenging both the learned lower authorities’ action treating its purchases of Rs.10,00,010/-, as bogus ones under section 69C of the Act, in the assessment order dated 26.03.2025, as upheld in the lower appellate discussion. 3. That being the case, both the parties vehemently reiterate their respective stands against and in support of the impugned bogus purchases disallowance. We wish to make it clear that there is no dispute in principle that the assessee is engaged in the business of manufacturing and supply of leather garments, bags and accessories all along wherein possibility of assessee sourcing its purchases from unregistered dealers per se could not be altogether ruled out as well. And that his corresponding sales have nowhere been questioned in both the lower proceedings. Various judicial precedents (2025) 173 taxmann.com 592 (Guj.) Ravjibhai Becharbhai Dhamelia vs. ACIT; (2024) 160 taxmann.com 110 (Bom) PCIT Vs. Hitesh Mody (HUF), (2024) 160 taxmann.com 93 (Del) PCIT Vs. Forum Sales (P) Ltd.; (2025) 172 taxmann.com 283 (Bom) PCIT Vs. Kanak Impex (India) Ltd; (2025) 178 taxmann.com

2 | P a g e

ITA No.3393/Del/2026

424 (Del. – Trib.) DCIT Vs. Kohinoor Foods Ltd.; and (2025) 177 taxmann.com 836 (Delhi-trib.) DCIT Vs. Tirupati Matsup (P.) Ltd. have recently decided the instant issue of bogus purchases with divergent views as well. 4. Faced with these peculiar facts, it is thus deemed appropriate in the larger interest of justice that a lumpsum GP addition of Rs.1 lakh in the assessee’s hands, would be just and proper with a rider that the same shall not be treated as a precedent. The assessee’s book entries are hereby rejected to the very extent. Necessary computation shall follow as per law. 5. This assessee’s appeal is partly allowed in above terms. Order pronounced in the open court on 29th July, 2026

Sd/- Sd/- (NAVEEN CHANDRA) (SATBEER SINGH GODARA) ACCOUNTANT MEMBER JUDICIAL MEMBER Dated: 8th September, 2026. RK/- Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(A) 5. DR Asst. Registrar, ITAT, New Delhi

3 | P a g e

More judgments on Section 69C

All 8,217 judgments and leading authorities on Section 69C →

Recent GST High Court judgments

Search GST case law →