GARUDA CONSTRUCTION AND ENGINEERING LIMITED,MUMBAI, MAHARASHTRA vs. DEPUTY COMMISSIONER OF INCOME TAX, AAYAKAR BHAVAN, MUMBAI, MAHARASHTRA

This appeal filed by the assessee is directed against the order dated 18.02.2026 passed by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [“Ld. CIT(A)”], under section 250 of the Income-tax Act, 1961 (“the Act”), arising from the assessment order dated 16.03.2024 passed under section 147 read with section 144B of the Act for Assessment Year 2018-19.

The assessee has challenged the validity of the reassessment proceedings and the confirmation of addition of ₹10,57,30,578 made under section 69C read with section 115BBE of the Act in respect of purchases from M/s Artlink Vintrade Ltd.

When the appeal was called for hearing, none appeared on behalf of the assessee nor was any application seeking adjournment filed. On the earlier date of hearing, i.e. 01.07.2026, also none had appeared on behalf of the assessee. We, therefore, proceed to dispose of the appeal after hearing the learned Departmental Representative and perusing the material available on record.

Briefly stated, the assessment was reopened on the basis of information received from the Investigation Wing that M/s Artlink Vintrade Ltd. was a shell entity engaged in providing accommodation entries and that the assessee had entered into transactions aggregating to ₹10,57,30,578 with the said entity. The Assessing Officer treated the purchases as unexplained expenditure and made an addition under section 69C read with section 115BBE of the Act.

The Ld. CIT(A), after considering the assessment order, written submissions and material on record, observed that the supplier did not respond to the notice issued under section 133(6) of the Act and was not found at its stated address during physical verification. The assessee had also failed to furnish reliable evidence regarding actual movement and delivery of goods. The Ld. CIT(A) further noted the inconsistent stand taken by the assessee regarding the transactions and, accordingly, confirmed the addition.

The learned Departmental Representative relied upon the orders of the authorities below.

We have considered the material available on record. The Ld. CIT(A) has passed a speaking order and has dealt with the contentions of the assessee point-wise. The assessee has neither appeared before us nor placed any material to controvert the specific findings recorded by the Ld. CIT(A). In these circumstances, we find no infirmity in the impugned order warranting our interference. Accordingly, the grounds raised by the assessee are dismissed.

In the result, the appeal filed by the assessee is dismissed.