J J S ENGINEERS (INDIA) PRIVATE LIMITED,DELHI vs. INCOME TAX OFFICER, WARD 13(1), DELHI

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ITA 6732/DEL/2026Status: DisposedITAT Delhi18 August 2026AY 2019-203 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal acknowledged that while the assessee deals in industrial chemicals and sourcing from unregistered dealers is possible, the book entries for the disputed purchases were rejected. A lumpsum disallowance of 6% of the alleged bogus purchases was deemed just and proper, without setting a precedent.

What were the facts?

The assessee's appeal concerns assessment year 2019-20, challenging the disallowance of purchases treated as bogus. These purchases, amounting to Rs. 16,00,201/-, were found during a search operation and declared as such under Section 69C of the Act.

What were the issues?

The primary issue was the validity of disallowing purchases treated as bogus and accommodation entries. The Tribunal also considered the possibility of sourcing from unregistered dealers and the divergent judicial views on similar issues.

Which sections of the Income-tax Act were involved?

Section 69C,Section 147

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH: “SMC” NEW DELHI

Before: SHRI SATBEER SINGH GODARA

Hearing: 05.08.2026Pronounced: 05.08.2026

IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: “SMC” NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER ITA No.6732/Del/2026 Assessment Year: 2019-20 Vs. Income Tax Officer, J J S Engineers (India) Private Limited., Ward- 13(1), 39, Nalanda Apartments, C.R Building, I.P.Estate, New Vikas Puri, New Delhi- Delhi- 02 110018 PAN: AACCJ6428J (Appellant) (Respondent) Assessee by None Department by Sh. Manoj Kumar, Sr. DR

Date of hearing 05.08.2026 Date of pronouncement 05.08.2026 ORDER This assessee’s appeal for assessment year 2019-20, arises against the Commissioner of Income Tax (Appeals)-24 [in short, the “CIT(A)”], New Delhi’s order no. NFAC/2018-19/10478560, dated 20.04.2026 involving proceedings under section 147 of the Income- tax Act, 1961 (hereinafter referred to as ‘the Act’).

Case called twice. None appears at the assessee’s behest. It has accordingly proceeded ex-parte.

2.

It emerges during the course of hearing that the assessee presses for his sole substantive ground on merits challenging both

ITA No. 6732/Del/2026 the learned lower authorities’ action treating its purchases/accommodation entries of Rs. 16,00,201/- in AY 2019- 20, found during search and seizure operation carried out on 26.10.2020 in 29 premises of Sanjay Jain, Girdhari Lal Mehta Constructions Private Limited, Inderjit Mehta Constructions Pvt Ltd, BCC Cement Pvt Ltd. and declared as bogus ones under section 69C of the Act, in the assessment order dated 21.03.2025, and 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. I wish to make it clear that there is no dispute in principle that the assessee is engaged in the business of wholesale of industrial chemical 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 recent 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) 2 | P a g e

ITA No. 6732/Del/2026 Ltd; (2025) 178 taxmann.com 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.

5.

Faced with these peculiar facts, it is thus deemed appropriate in the larger interest of justice that a lumpsum disallowance @ 6% of the assessee’s alleged bogus purchases amounting to Rs. 16,00,202/-, 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.

No other ground or argument has been pressed.

6.

This assessee’s appeal is partly allowed in above terms. Order pronounced in the open court on 03.08. 2026.

Sd/- (SATBEER SINGH GODARA) JUDICIAL MEMBER Dated: 18.08.2026 Pooja Mittal/- Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(A) 5. DR Asst. Registrar, ITAT, New Delhi

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