INCOME TAX OFFICER, WARD-2(3)(6), SURAT, SURAT vs. GHEVARCHAND BHANWARLAL PAMECHA, SURAT

ITA 180/SRT/2025Status: DisposedITAT Surat06 August 202610 pages
AI SummaryPartly Allowed

What were the facts?

The Assessing Officer (AO) made additions for alleged bogus purchases based on confessional statements from a search operation. The assessee claimed these purchases were genuine and provided supporting documents.

What did the Tribunal hold?

The Tribunal, following the jurisdictional High Court's decision, held that while the purchases might be questionable, a 100% addition was not justified. The addition was restricted to 6% of the impugned purchases.

What were the issues?

Whether the entire amount of purchases from alleged bogus suppliers should be added to the assessee's income, or if a partial addition is warranted.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 69C,Section 145(2)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, SURAT BENCH, SURAT

Before: MS. SUCHITRA KAMBLE & SHRI B.M. BIYANI

For Appellant: Shri Rohit Vijayvargiya, CA
For Respondent: Shri J.K. Chandnani, CIT (DR)

Per B.M. Biyani, AM:

The captioned two (2) appeals are filed by revenue against two (2) separate orders of first-appeals, both dated 23.12.2024 and passed by learned Commissioner of Income-tax (Appeals), NFAC, Delhi [“Ld. CIT(A)”], which in turn arise out of respective assessment-orders dated 23.03.2016 and 16.12.2016 passed by learned ITO, Ward-2(3)(7), Surat [“Ld. AO”] u/s 143(3) of the Income-tax Act, 1961 [“the Act”] for Assessment-Year [“AY”] 2013-14 and 2014-15. Since these appeals relate to the same assessee and the ITA No.180 & 181/SRT/2025 Ghevarchand

The order continues below.

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