G N FASHION PRIVATE LIMITED,MUMBAI vs. INCOME TAX OFFICER WARD 7(1)(1), MUMBAI, MUMBAI

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “G” MUMBAI

BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND SHRI PAWAN SINGH (JUDICIAL MEMBER)

ITA No. 432/MUM/2026 Assessment Year: 2019-20

GN Fashion Private Limited, Income Tax Officer Ward 7(1)(1), 406A, Room No.16/17, Wagh Aayakar Bhawan, Mumbai – Wadi, Kalbadevi Road, Vs. 400020, Maharashtra. Kalbadevi H.O, Mumbai . PAN NO. AACCL 0334 M Appellant Respondent

Assessee by : Shri Mani Jain, CA & Shri Prateek Jain, CA. Revenue by : Shri Basavaraj Hiremath – CIT DR a/w Shri Rajgopal Parthasarathi – SR DR.

Date of Hearing : 15/07/2026 : 27/07/2026 Date of pronouncement

ORDER u/s 254(1) of Income Tax Act, 1961 PER: OM PRAKASH KANT, AM

This appeal by the assessee is directed against the order dated 21.11.2025 passed by the learned Commissioner of Income-tax (Appeals), National Faceless Appeal Centre, Delhi [hereinafter referred to as "the Ld. CIT(A)"] for the Assessment Year 2019-20. By way of the present appeal, the assessee has challenged both the validity of the reassessment proceedings as well as the addition of

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₹7,33,92,455/- made on account of alleged bogus purchases by invoking the provisions of section 69C read with section 115BBE of the Income-tax Act, 1961 ("the Act"). For reference, the grounds raised by the assessee are reproduced as under: “1. On the facts and circumstances of the Appellant's case and in law the ld. CIT(A) erred in confirming the action of ld. AO in reopening the case of the appellant which is bad in law, without jurisdiction and deserves to be quashed. 2. On the facts and circumstances of the Appellant's case and in law the Id. CIT (A) erred in confirming the action of Id. A.O. in holding the purchase transaction as non-genuine, merely on the basis of third party's statement, for reasons stated in the impugned order or otherwise. 3. On the facts and circumstances of the Appellant's case and in law the ld. CIT (A) erred in confirming the action of Id. AO in making addition of Rs. 7,33,92,455/-on account of alleged bogus purchases made from M/s Rathi Styles and Textile Pvt. Ltd. & M/s SVG Styles and Textiles Company Pvt. Ltd., for reasons stated in the impugned order or otherwise. 4. On the facts and circumstances of the Appellant's case and in law the Id. CIT(A) erred in confirming the action of Id. AO in making an addition of Rs. 7,33,92,455/-on account of purchases by treating the same as bogus purchases, by invoking the provisions of section 69C r.w.s. 115BBE of the Act, for the reasons mentioned in the impugned order or otherwise.”

1.1 The grounds raised by the assessee, give rise to two principal issues for our adjudication. The first relates to the legality of the reassessment proceedings initiated under sections 147/148 of the Act. The second concerns the sustainability of the addition of ₹7,33,92,455/- representing purchases alleged to have been made from M/s Rathi Styles & Textile Pvt. Ltd. and M/s SVG Styles & Textiles Company Pvt. Ltd., which, according to the Revenue, were entities engaged merely in providing accommodation bills without actual supply of goods.

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2.1 During the course of reassessment proceedings, the Assessing Officer called upon the assessee to substantiate the genuineness of the impugned purchases. In response, the assessee furnished extensive documentary evidence, inter alia, comprising copies of purchase invoices, E-way Bills generated through the Government portal, transporter's bills, purchase and sales registers, audited financial statements, ledger accounts of the suppliers duly confirmed by them, quantitative stock records and bank statements

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evidencing payment through normal banking channels. The consistent stand of the assessee before the Assessing Officer was that the purchases were genuine, the goods had actually been received and subsequently sold in the ordinary course of business, and the entire transaction stood duly recorded in the regular books of account.

2.2 The Assessing Officer, however, was not persuaded by the explanation furnished. According to him, certain discrepancies were noticed in the supporting documents, particularly with regard to the addresses reflected in the purchase invoices and the corresponding E-way Bills. According to him the address mentioned in the tax invoice for delivery of the goods is Opp, Neelkamal Hotel, Kalbadevi Road, Mumbai – 27, whereas address mentioned in the E-way Bill for delivery of goods is, Bhiwandi, Maharashtra. More importantly, reliance was placed upon the information received from the Investigation Wing, Mumbai, including the statement recorded under section 131 of the Act from Shri Gopal Bhattar, who was stated to be controlling the affairs of the two supplier companies. In the said statement, Shri Gopal Bhattar allegedly admitted that the aforesaid concerns were merely paper entities floated for issuing accommodation invoices without carrying out any genuine trading activity and that no actual movement or delivery of goods ever took place.

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2.3 Proceeding primarily on the basis of the said statement and the investigation report, the Assessing Officer concluded that the purchases shown by the assessee were not genuine and merely represented accommodation entries obtained for inflating expenditure. He accordingly treated the entire amount of ₹7,33,92,455/- as unexplained expenditure under section 69C of the Act. The relevant finding of Ld. AO is reproduced as under:-

“As well, it is evidenced that purchases shown by the assessee from these companies are only accommodation entries in the form of bogus purchases for the year under consideration.

In excess of, contention of assessee regarding providing copy of full statement of Sh. Gopal Bhattar is also not found acceptable due to reason that the relevant documents/information had already been provided to the assessee during the proceedings u/s 148A of the IT Act, 1961 by issuance of notice 148A(b) of the IT Act, 1961 dated 02.03.2023. Thus, the initiation of assest nent proceedings u/s 147 of the IT Act, 1961 is correct and as per law. The above pleas taken by the assessee is afterthought only for escaping its undisclosed income from taxation

From the above discussion, it has been clearly evidenced that the assessee has taken accommodation entry in the shape of bogus purchases from M/s Style and Textiles Company Pvt. Ltd of Rs. 3,10,60,605/- & M/s Rathi Styles and Textile Pvt. Ltd. of Rs. 4,23,31,850/- totaling to Rs.7,33,92,455/- during the year under consideration as there is no actual supply/movement of goods. The paper entity namely M/s Style and Textiles Company Pvt. Ltd. & M/s Rathi Styles and Textile Pvt. Ltd. were involved in practice of only issuing invoices/bills to recipients without actual movement of goods so that the assessee had booked bogus expenses in the form of fictitious purchase which are required to be disallowed and added back to the total income of the assessee in light of the provisions of section 69C of the Income Tax Act, 1961 for the year under consideration.

Considering to the above fact and circumstances of the case, the show cause notice was issued to the assessee on 07.02.2024 for furnishing the reply on or before 12.02.2024. In the aforesaid show cause notice, the assessee was required to show cause as to why the aforesaid purchases of Rs.7,33,92,455/- made from the above concerns should not be treated as bogus purchases and not to be added back to the total income of the assessee light of provisions of the Income tax Act, 1961 for the year under consideration?"

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In compliance to the above show cause notice, no reply was filed by the assesssee in stipulated time. Non-compliance by the assessee to statutory notices clearly shows that he has nothing to say in this regard and also agreed to the fact narrated in the show cause notice. It is also mention here that the reasonable, speaking and fullest natural justice has been followed by the Faceless Assessing Officer, but it is the assessee who has not availed any chances for the reasons best known to him. Therefore, the bar of 'natural justice' has been breached by the assessee for the reasons known to him.

In view of the above fact and in the interest of natural justice and also in the interest of Revenue, purchase shown by the assessee has been established as bogus purchase in light of the provisions of section 69C of the IT Act, 1961 for decreasing of its profit, therefore, the same is hereby added back to the total income of the assessee on account of unexplained expenditure u/s 69C r.w.s. 115BBE of the IT Act, 1961 in form of fictitious purchases from the above paper concerns for the year under consideration.

Accordingly, penalty proceedings u/s 271AAC(1) of the IT Act, 1961 are also initiated separately for the income determined u/s 69C r.w.s 15BBE of the I.T. Act, 1961 for the year under consideration ”

2.4 Before the learned CIT(A), the assessee assailed both the validity of the reassessment proceedings and the addition made on merits. Elaborating its challenge to the addition, the assessee contended that the Assessing Officer had ignored overwhelming documentary evidence establishing the genuineness of the purchases. It was submitted that every purchase transaction was duly supported by tax invoices, E-way Bills generated through the Government portal, transporter's bills, quantitative stock records, ledger confirmations issued by the suppliers, GST records and bank statements evidencing payment through regular banking channels. It was further contended that the goods so purchased formed part

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of the regular trading stock, were duly reflected in the books of account and were subsequently sold to various customers, resulting in corresponding sales which had never been disputed by the Revenue.

2.5 The assessee further submitted that the addition had been founded almost exclusively on the statement of Shri Gopal Bhattar without conducting any independent enquiry and without confronting the assessee with the complete material relied upon. According to the assessee, the source of payment for the purchases had never been questioned by the Assessing Officer, and therefore invocation of section 69C of the Act, which deals with unexplained expenditure, was legally misconceived. It was argued that even assuming, without admitting, that the purchases were doubtful, the provisions of section 69C could not be invoked where the source of expenditure stood fully explained through disclosed banking transactions.

2.6 The learned CIT(A), however, was not persuaded by the aforesaid submissions. After referring extensively to the statement of Shri Gopal Bhattar recorded under section 131 of the Act, the learned CIT(A) observed that Shri Gopal Bhattar had categorically admitted that M/s SVG Styles & Textiles Company Pvt. Ltd. and M/s Rathi Styles & Textile Pvt. Ltd. were merely paper concerns floated for issuing accommodation invoices without carrying on any genuine business activity. Particular emphasis was laid upon the

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answers given by Shri Gopal Bhattar to Questions Nos. 10 to 13, wherein he is stated to have admitted that the aforesaid concerns neither maintained any stock nor undertook any transportation or physical delivery of goods and that the banking transactions were merely intended to lend an appearance of genuineness to otherwise fictitious transactions. Proceeding on the premise that the controlling person himself had admitted the non-genuine nature of the business carried on by the supplier concerns, the learned CIT(A) concluded that the documentary evidence produced by the assessee lost its evidentiary value and was insufficient to establish the genuineness of the purchases.

2.7 The learned CIT(A) further observed that the Assessing Officer had noticed certain inconsistencies in the supporting documents furnished by the assessee. According to the appellate authority, the addresses reflected in the purchase invoices and the corresponding E-way Bills were not identical. The learned CIT(A) was further of the view that the existence of corresponding sales or the fact that payments had been made through banking channels could not, by themselves, establish the genuineness of the purchases. According to him, where the Investigation Wing had unearthed a systematic arrangement of accommodation billing and the person controlling the supplier concerns had admitted that the banking trail was merely a device to impart legitimacy to fictitious transactions, the payment through banking channels lost much of its evidentiary

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significance. The learned CIT(A.) accordingly held that the assessee had failed to establish actual physical receipt of goods from the impugned suppliers by producing reliable and independent evidence.

2.8 In support of his conclusions, the learned CIT(A) referred to various judicial precedents dealing with bogus purchase transactions and observed that the Income-tax authorities are entitled to examine the substance of a transaction rather than its mere form. Relying upon the decisions cited in the appellate order, it was observed that where the surrounding circumstances indicate that documentary evidence has been created merely to give a colour of genuineness to fictitious transactions, the authorities are not precluded from piercing the apparent façade and determining the true nature of the transaction. The learned CIT(A.) also referred to judicial precedents wherein additions on account of bogus purchases had either been sustained in full or partly sustained depending upon the facts of the individual case.

2.9 Although the learned CIT(A.) accepted the assessee's contention that section 69C ordinarily contemplates a case where the source of expenditure remains unexplained, he nevertheless held that, having regard to the peculiar facts of the present case and the ratio of certain judicial precedents, particularly the decision of the Hon'ble Bombay High Court in PCIT v. Kanak Impex (India) Ltd. (supra), the provisions of section 69C read with section 115BBE were correctly

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invoked by the Assessing Officer. According to the learned CIT(A.), once the supplier concerns themselves had been found to be non- genuine and the assessee had failed to establish the actual receipt of goods through independent evidence, the addition representing the entire amount of purchases was liable to be sustained.

2.10 On the aforesaid reasoning, the learned CIT(A.) rejected the contentions advanced by the assessee, upheld the finding of the Assessing Officer that the impugned purchases were non-genuine, confirmed the addition of ₹7,33,92,455/-, and dismissed the appeal on merits.

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3.1 The learned counsel further submitted that the Assessing Officer neither rejected the books of account maintained by the assessee nor disputed the quantitative records or the corresponding sales. It was argued that once the trading results and sales have been accepted, the purchases giving rise to such sales cannot be rejected merely on the basis of a generalized statement recorded from a third party, particularly in the absence of any independent enquiry establishing that the documentary evidence produced by the assessee was fabricated or false.

3.2 The learned counsel further submitted that the entire controversy is squarely covered by the decision of the Coordinate Bench of the Tribunal in M/s Patodia Filaments Private Limited, in ITA No. 5696 and 5698/Mum/2024 for AY 2016-17 and 2018- 19, wherein, on substantially identical facts involving the very same supplier concerns, namely M/s Rathi Styles & Textile Pvt. Ltd. and M/s SVG Styles & Textiles Company Pvt. Ltd., the additions made on account of alleged bogus purchases had been deleted after examining identical documentary evidence. The said decision has been further followed by the Coordinate Bench in ITA No. 3067 /Mum/2016 for AY 2019-20 in the case of same assessee. It was contended that the Revenue has neither pointed out any distinguishing feature in the present case nor brought to our notice any contrary decision of a superior judicial forum. Therefore, in accordance with the well-settled principle of judicial discipline, the

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decision of the Coordinate Bench deserves to be followed. It was also submitted that the statement of Shri Gopal Bhattar neither refers to the assessee nor contains any allegation that accommodation bills had specifically been issued to the assessee without actual delivery of goods. Moreover, despite repeated requests made during the reassessment proceedings, the complete statement was never furnished to the assessee nor was any opportunity afforded to cross-examine the deponent. Consequently, the reliance placed upon such statement, without complying with the elementary requirements of natural justice, is wholly unsustainable in law.

3.3 The learned Departmental Representative, on the other hand, strongly relied upon the findings recorded by the Assessing Officer and the learned CIT(A.). It was submitted that the Investigation Wing had unearthed a well-organised network of shell companies engaged in issuing accommodation invoices and that Shri Gopal Bhattar had categorically admitted that the supplier concerns were not carrying on any genuine business activity. It was further argued that certain discrepancies noticed in the transportation documents and stock records cast serious doubt upon the genuineness of the purchases and that the authorities below were justified in treating the impugned purchases as non-genuine.

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authorities below. The controversy essentially centres around the question whether the documentary evidence produced by the assessee is sufficient to establish the genuineness of the purchases or whether such evidence stands eclipsed solely on account of the statement of Shri Gopal Bhattar and the investigation report relied upon by the Revenue.

4.1 At the outset, it deserves to be noticed that the assessee has produced a complete chain of primary documentary evidence in support of the impugned purchases. The purchase invoices are accompanied by corresponding E-way Bills generated through the statutory portal. The transporter's bills contain particulars of transportation, including vehicle registration numbers, which correspond with the vehicle numbers reflected in the E-way Bills. The ledger accounts of the suppliers stand duly confirmed and the payments have admittedly been made through regular banking channels. The quantitative stock register has also been produced showing receipt and issue of goods in the normal course of business. Significantly, none of these documents has been found to be fabricated or false by any independent enquiry conducted by the Revenue.

4.2 On our independent examination of the sample invoices and the accompanying transportation documents placed before us, we find that the transporter's name, vehicle registration number and destination of delivery mentioned in the invoices substantially

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correspond with the particulars reflected in the E-way Bills and transport documents. The Revenue has not undertaken any enquiry either from the transporters, the vehicle owners or any other independent agency to establish that the goods were never transported or that the documents relied upon by the assessee were fictitious. Equally, no material has been brought on record to demonstrate that the E-way Bills generated through the Government portal were manipulated or otherwise invalid.

4.3 In our considered opinion, once the assessee produces contemporaneous documentary evidence evidencing purchase, transportation, payment and accounting of the goods, the initial burden cast upon it stands duly discharged. Thereafter, the burden shifts upon the Revenue to rebut such evidence by bringing on record cogent material demonstrating that the apparent state of affairs does not represent the real transaction. Mere suspicion, however grave, cannot substitute legal proof. The conclusion of non-genuineness must necessarily rest upon objective evidence and not merely upon conjectures arising from a general investigation report.

5 We further find that the entire edifice of the Revenue's case rests substantially upon the statement of Shri Gopal Bhattar. Undoubtedly, the said statement may constitute a relevant piece of information for initiating enquiry. However, by itself, it cannot constitute conclusive evidence against every purchaser whose name

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may appear in the books of the alleged accommodation entry providers. It is pertinent to note that nowhere in the statement relied upon by the Revenue has Shri Gopal Bhattar specifically identified the present assessee as a beneficiary of accommodation bills issued without supply of goods. The statement merely describes the alleged modus operandi adopted by the supplier concerns in general terms.

5.1 It is a settled principle that a general statement recorded from a third party cannot automatically displace specific documentary evidence produced by an assessee unless the Revenue establishes a direct nexus between such statement and the transactions under consideration. In the present case, apart from the generalized statement, no corroborative material has been brought on record establishing that the goods covered by the impugned invoices were never delivered to the assessee.

5.2 Another aspect which cannot be overlooked is that the assessee has consistently maintained that the complete statement of Shri Gopal Bhattar was never supplied during the reassessment proceedings despite repeated requests. Although the Assessing Officer has observed that the relevant material had been furnished during proceedings under section 148A(b), no contemporaneous record has been produced before us evidencing service of the complete statement upon the assessee. The principles of natural justice require that where an addition is substantially founded

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upon the statement of a third party, the assessee must be supplied the material sought to be relied upon and afforded an effective opportunity to rebut the same. Failure to observe these safeguards materially diminishes the evidentiary value of such statement, particularly where the assessee has simultaneously produced substantial documentary evidence supporting the genuineness of the transactions.

5.3 We also find considerable merit in the contention of the assessee that neither the books of account nor the quantitative trading results have been rejected. The Revenue has accepted the corresponding sales disclosed by the assessee. No discrepancy has been pointed out in the overall trading results or gross profit declared during the relevant previous year. It is difficult to conceive that sales could be accepted as genuine while the corresponding purchases, duly supported by quantitative records and transportation documents, are treated as entirely non-existent without any independent evidence establishing suppression of stock or inflation of purchases. The surrounding circumstances, viewed in their entirety, do not support the conclusion reached by the authorities below. On the contrary, the documentary evidence produced by the assessee constitutes a consistent and uninterrupted chain supporting the genuineness of the transactions.

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5.4 Apart from the foregoing discussion, we find that the controversy involved in the present appeal stands squarely covered by the decision of the Coordinate Bench in M/s Patodia Filaments Private Limited (supra), wherein identical purchases from the very same supplier concerns were examined. After considering substantially similar documentary evidence, including invoices, E- way Bills, transport documents, bank payments and quantitative records, the Coordinate Bench held that the purchases could not be disbelieved merely on the basis of the statement of Shri Gopal Bhattar in the absence of any independent material establishing that the transactions were fictitious. The relevant finding of the Coordinate Bench of the Tribunal in ITA No. 3067/Mum/2026 is reproduced as under:-

“8. Heard the parties and perused the material available on record. Admittedly, the Assessee, by producing the aforesaid documentary evidences, duly discharged the primary onus cast upon it to establish the genuineness of the impugned purchases. It is also an admitted position that the Ld. AO neither disputed nor controverted the documentary evidences furnished by the Assessee. Likewise, the corresponding sales effected out of the impugned purchases have also not been doubted by the Revenue. 9. Further, we find that the Coordinate Bench of the Tribunal, in the Assessee's own case for A.Ys. 2016-17 and 2018-19 vide common order dated 31.12.2024 ITA Nos. 5696/Mum/2024 and 5698/Mum/2024, while dealing with an identical issue, has held as under:- "7. We have heard both the parties and also perused the relevant finding given in the impugned orders. First of all, it is not in dispute that assessee had disclosed the source of all the purchases from its books and the quantitative details of the purchases and the sales have not been disputed. It is for this reason Id. AO had applied GP rate of 12.5% on the purchases. The Id. CIT (A) following the judgment of the Hon'ble Bombay High Court held that the GP rate on purchases which have been accepted to be genuine is to be applied on alleged bogus purchases. From the

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perusal of the material placed on record and the submissions made before the Id. CIT

(A), it is seen that assessee is dealing in the business of manufacturing of fabrics as well as trading in fabrics. It had made fabric purchases of more than Rs.49.80 Crores. The only purchases made from these two parties have been doubted on which GP rate has been applied. The assessee to prove the genuineness of the purchases made from both the parties has produced the following documents:-

 Copy of the Invoices received on account of purchases made.  Copy of the Ledger Account of M/s SVG Style and Textile  Company in the books of appellant.  Corresponding to the purchases made, payment made through the bank alongwith the copy of the bank statement.  Details of o of corresponding sales on such purchases including quantity wise sales and purchases.  Copy of delivery challans of the purchases made

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effectively rebutting the observation of the Ld. AO that there was no evidence regarding actual delivery of goods. 11. In view of the aforesaid factual position and respectfully following the decision of the Coordinate Bench in the Assessee's own case, we find no infirmity in the order of the Ld. Commissioner deleting the impugned addition. Thus, the impugned order is affirmed.”

5.5 The Revenue has not demonstrated any distinguishing feature warranting a different view. Judicial discipline and the principle of consistency require that, in the absence of any contrary decision of a superior forum or distinguishing factual feature, a Coordinate Bench should ordinarily follow an earlier decision rendered on identical facts. We are, therefore, in respectful agreement with the view taken by the Coordinate Bench and see no reason to depart therefrom.

5.6 We are also unable to endorse the reasoning adopted by the learned CIT(A) regarding the applicability of section 69C of the Act. Section 69C contemplates a situation where an assessee is found to have incurred expenditure and either offers no explanation regarding the source thereof or the explanation offered is found to be unsatisfactory. In the present case, there is no dispute whatsoever regarding the source from which the payments for the purchases were made. The payments admittedly emanated from disclosed bank accounts and stood duly reflected in the regular books of account. The dispute raised by the Revenue is not with regard to the source of expenditure but with regard to the

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genuineness of the underlying purchases. Therefore, even assuming for the sake of argument that doubts existed regarding the genuineness of the suppliers, the provisions of section 69C could not have been mechanically invoked in the absence of any finding that the source of expenditure itself remained unexplained. The statutory conditions precedent for invoking section 69C are, therefore, conspicuously absent.

5.7 In view of the foregoing discussion, we hold that the authorities below were not justified in treating the purchases aggregating to ₹7,33,92,455/- as non-genuine or in making the impugned addition under section 69C read with section 115BBE of the Act. The addition has been sustained principally on presumptions arising from a generalized third-party statement without rebutting the substantial documentary evidence produced by the assessee. Such an approach cannot be sustained in law. Accordingly, the impugned order of the learned CIT(A) on this issue is set aside and the Assessing Officer is directed to delete the addition of ₹7,33,92,455/-.

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of the reassessment open to be considered in an appropriate case, without expressing any opinion thereon.

Order pronounced in the open Court on 27/07/2026.

Sd/- Sd/- (PAWAN SINGH) (OM PRAKASH KANT) JUDICIAL MEMBER ACCOUNTANT MEMBER

Mumbai; Dated: 27/07/2026 M. Ranganath Vittal , Sr. P.S.

Copy of the Order forwarded to : 1. The Appellant 2. The Respondent. 3. CIT 4. DR, ITAT, Mumbai 5. Guard file.

BY ORDER, //True Copy// (Assistant Registrar) ITAT, Mumbai