RUDRAKSH ENTERPRISES,JODHPUR vs. ITO WARD-1(2), JODHPUR

ITA 774/JODH/2025Status: DisposedITAT Jodhpur12 August 2026AY 2020-215 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal set aside the CIT(A)'s order, remanding the matter for fresh adjudication. The assessee is to substantiate the source of payments, banking channels used, and correlation with sales and trading results.

What were the facts?

The assessee, engaged in coal and pet coke trading, faced additions for purchases treated as unexplained expenditure based on information about accommodation invoice providers. The Assessing Officer added the entire purchase amount, which the CIT(A) confirmed due to non-compliance by the assessee.

What were the issues?

Whether purchases treated as unexplained expenditure can be added in full, and if not, whether the addition should be restricted to a gross profit element, requiring fresh verification of source of funds and correlation with sales.

Which sections of the Income-tax Act were involved?

Section 69C,Section 115BBE,Section 147,Section 144,Section 144B

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, JODHPUR BENCH, JODHPUR

For Respondent: DR (Physical)

PER BENCH: The present appeal has been filed by the assessee against the impugned order passed by the learned CIT(A), arising out of the assessment order dated 17.03.2025 passed under section 147 read with sections 144 and 144B of the Income-tax Act, 1961 for A.Y. 2020-21. The assessee is mainly aggrieved by the addition of ₹3,45,19,051 made under section 69C read with section 115BBE by treating the entire purchases made from M/s Khavas Impex and M/s Sunstar International as unexplained expenditure.

2 Asst. Year: 2020-21

2.

The brief facts are that the assessee is engaged in the business of trading in coal and pet coke. Based on information received from the Investigation Wing regarding certain entities allegedly engaged in providing accommodation invoic

The order continues below.

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