SUSHIL KUMAR BANSAL,DELHI vs. ITO WARD 34(5), DELHI, DELHI

For the reasons stated in the assessee’s condonation averments, delay of 39 days in filing of the instant appeal is

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. 13,00,871/- in AY 2018-19, sourced from entity M/s Balaji Trading as bogus ones under section 69C of the Act, in the assessment order dated 14.03.2024, and upheld in the lower appellate discussion.

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.; 2 | P a g e

Faced with these peculiar facts, it is thus deemed appropriate in the larger interest of justice that a lumpsum disallowance @ 5% of the assessee’s alleged bogus purchases amounting to Rs. 13,00,871/-, 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.

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: 17.08.2026 Pooja Mittal/- Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(A) 5. DR Asst. Registrar, ITAT, New Delhi