GOLYAN EXIM PRIVATE LIMITED,DELHI vs. INCOME TAX OFFICER, DELHI

This assessee’s appeal for Assessment Year 2012-13 arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre (for short, ‘CIT(A)/NFAC’), Delhi’s DIN & order No. ITBA/NFAC/S/250/2024-25/1066772978(1), dated 16.07.2024, involving proceedings u/s 143(3) r.w.s. 147 of the Income Tax Act, 1961; hereinafter referred to as, “the Act”. Heard both the parties at length. Case file perused.

2 3. It is in this factual backdrop that we proceed to deal with the assessee’s aforesaid solitary substantive ground. It is made clear that there is no dispute at all between the parties that the assessee had declared total mobile sales trading receipts amounting to Rs. 20,70,95,352/- wherein the sole issue herein before us is that of the foregoing sales made to M/s Krishna Sales Corporation only. The assessee has admittedly failed to prove identity, genuineness and creditworthiness thereof all along. All this leads us to a conclusion that although it has declared sales receipts coming from the aforesaid party, the same could not be substantiated before both the learned lower authorities. Meaning thereby that this is an instance of the assessee’s sales outside books wherein a further GP estimation @ 3% thereof would meet the end of justice as against 2.6% already declared at its behest. We thus direct the learned Assessing Officer to finalize the necessary computation as per law. This assessee’s sole substantive ground is partly accepted in very terms therefore.

Sd/- Sd/- (KRINWANT SAHAY) (SATBEER SINGH GODARA) ACCOUNTANT MEMBER JUDICIAL MEMBER Dated: 07.08.2026 *Pooja Mittal, Sr. PS* Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(Appeals) 5. DR: ITAT ASSISTANT REGISTRAR