MAYANK VISHNUBHAI PATEL,BHARUCH vs. INCOME TAX OFFICER, WARD 2(1), , BHARUCH

ITA 59/SRT/2026Status: DisposedITAT Surat27 July 2026AY 2019-207 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal upheld the addition of unexplained expenditure, stating that the assessee failed to discharge its initial onus to prove the genuineness of the transactions. Consequently, the penalty was also confirmed.

What were the facts?

The assessee claimed purchases of Rs. 25,43,938/- which were treated as bogus by the Assessing Officer based on a survey conducted on another entity. The assessee failed to provide supporting evidence for these purchases.

What were the issues?

Whether the addition for unexplained expenditure is justified when the assessee fails to prove the genuineness of purchases and whether the penalty is sustainable.

Which sections of the Income-tax Act were involved?

Section 69C,Section 147,Section 148A,Section 148,Section 133A,Section 133(6),Section 143(3),Section 271AAC

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, SURAT BENCH SMC, SURAT

Before: Shri T. R. Senthil Kumar & Shri Ratnesh Nandan Sahay&

For Appellant: Shri Vinod Goyal, C.A
For Respondent: Shri Ajay Uke, Sr. DR
Hearing: 30/04/2026Pronounced: 27/07/2026

PER: RATNESH NANDAN SAHAY, AM:

1.

These are the appeals filed by the assessee against the separate orders of the National Faceless Appeal Centre (NFAC), Delhi [In short, ‘the ld. CIT(A)’] both dated 15/11/2025 for the assessment year (AY) 2019-20. Both the appeals are interconnected, therefore, both appeals were clubbed and heard together and being decided by this common order. ITA No. 58/Srt/2026 for the A.Y. 2019-20 being the quantum appeal, wherein the assessee has raised following grounds of appeal:

"

1.

The Ld. CIT (A) has erred in law and on facts in confirming the additions of Rs.25,43,938/- made u/s 69 C for alleged unexplained expenditure by trea

The order continues below.

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