AJAY LOOMTEX PRIVATE LIMITED,NEW DELHI vs. ITO-WARD 2(1), DELHI/, NEW DELHI

IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘H’ NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI KRINWANT SAHAY, ACCOUNTANT MEMBER ITA Nos.9008 & 9009/Del/2025 Assessment Years: 2018-19 & 2019-20 M/s. Ajay Loomtex Pvt. Ltd., Vs. Income Tax Officer, C/o- B-50, LGF, Ward-2(1), South Extension-II, Delhi New Delhi PAN: AAICA2949K (Appellant) (Respondent) Assessee by Sh. Shaantanu Jain, Adv. Ms. Jahanvi Khanna, Adv. Department by Sh. Sudip Majumdar, Sr. DR Date of hearing 08.07.2026 Date of pronouncement 08.07.2026 ORDER PER SATBEER SINGH GODARA, JM These assessee’s twin appeals ITA Nos.9008 & 9009/Del/2025 for assessment years 2018-19 and 2019-20, arise against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s orders, both dated 21.11.2025, having DINs and orders no. ITBA/NFAC/S/250/2025-26/1082860573(1) & 1082860702(1) ,

ITA Nos.9008 & 9009/Del/2025

involving proceedings under section 147 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’). Heard both the parties. Case file perused. 2. It emerges during the course of hearing that the assessee presses for his sole substantive ground on merits challenging both the learned lower authorities’ action treating his purchases amounting to Rs.41,82,848/- in AY 2018-19 and Rs.26,19,125/- in AY 2019-20 sourced from M/s. Radha Kanheya Exports, M/s. Rameshwaram International, M/s. Shree Balaji, M/s. Geeta Yarn and M/s. Manish Wooltex, as bogus one under section 69C of the Act, in the respective assessment orders, as upheld in the lower appellate discussion. 3. That being the case, both the parties vehemently reiterate their respective stands against and in support of the impugned bogus purchases disallowance. We wish to make it clear that there is no dispute in principle that the assessee is engaged in the business of manufacturing and trading of blankets all along wherein possibility of assessee sourcing its purchases from unregistered dealers per se could not be altogether ruled out as well. And that his corresponding sales have nowhere been

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questioned in both the lower proceedings. Various judicial precedents (2025) 173 taxmann.com 592 (Guj.) Ravjibhai Becharbhai Dhamelia vs. ACIT; (2024) 160 taxmann.com 110 (Bom) PCIT Vs. Hitesh Mody (HUF), (2024) 160 taxmann.com 93 (Del) PCIT Vs. Forum Sales (P) Ltd.; (2025) 172 taxmann.com 283 (Bom) PCIT Vs. Kanak Impex (India) Ltd; (2025) 178 taxmann.com 424 (Del. – Trib.) DCIT Vs. Kohinoor Foods Ltd.; and (2025) 177 taxmann.com 836 (Delhi-trib.) DCIT Vs. Tirupati Matsup (P.) Ltd. have recently decided the instant issue of bogus purchases with divergent views as well. 4. Faced with these peculiar facts, it is thus deemed appropriate in the larger interest of justice that a lumpsum disallowance @ 5% of the assessee’s alleged bogus purchases amounting to Rs.41,82,848/- in AY 2018-19 and Rs.26,19,125/- in AY 2019-20; respectively, would be just and proper with a rider that the same shall not be treated as a precedent. The same shall also take care of any alleged commission expenditure, if any, as well. The assessee’s book entries are hereby rejected to the very extent. Necessary computation shall follow as per law. No other ground or argument has been pressed.

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