STRATEGIC DESIGNS PRIVATE LIMITED,DELHI vs. ITO WARD 24 (1), DELHI
What did the Tribunal hold?
The Tribunal acknowledged that the business involved unorganized activities with potential cash turnover and that sales receipts were not questioned. Considering divergent judicial views on bogus purchases, a lumpsum disallowance of 5% of the alleged bogus purchases was deemed just and proper.
What were the facts?
The assessee challenged the lower authorities' action of treating purchases of Rs. 1,09,90,926/- from M/s. Hari Om Enterprises as bogus under Section 69C of the Income Tax Act. The disallowance was restricted to Rs. 13,73,865/-.
What were the issues?
Whether purchases from a specific vendor were bogus and the extent of disallowance for such purchases.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, DELHI BENCH: “SMC” NEW DELHI
Before: SHRI SATBEER SINGH GODARA
IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: “SMC” NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER ITA No.4744/Del/2026 Assessment Year: 2018-19 Strategic Designs Pvt. Ltd., Vs. Income Tax Officer, C/O- M/s. S.B.G. & Co., Ward – 24(1), House No. 9, Attar Ur Delhi Rehman Lane, Civil Lines, Delhi - 11054 PAN: AABCS2612L (Appellant) (Respondent) Assessee by None Department by Sh. Manoj Kumar, Sr. DR
Date of hearing 02.06.2026 Date of pronouncement 02.06.2026 ORDER This assessee’s appeal for assessment year 2018-19, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s DIN & order no. ITBA/NFAC/S/250/2025-26/1086649075(1), dated 27.02.2026 involving proceedings under section 147 of the Income- tax Act, 1961 (hereinafter referred to as ‘the Act’). Case called twice. None appears at the assessee’s behest. It is accordingly proceeded ex-parte.
ITA No.4744/Del/2026
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 its purchases of Rs.1,09,90,926/- sourced from M/s. Hari Om Enterprises as bogus ones under section 69C of the Act, which was restricted to Rs.13,73,865 (being 12.5% of total purchases of Rs.1,09,90,926/- ) in the assessment order dated 24.03.2023, and upheld in the lower appellate discussion. 3. Learned departmental representative vehemently argues that the lower authorities have rightly treated the impugned purchases as bogus one. 4. I wish to make it clear that there is no dispute in principle that the assessee is engaged in the business of manufacturing and sales of digital prints & trading of textile. all along where possibility of cash turnover in such an unorganized activity could not be altogether ruled out. And that its corresponding receipts and sales therefrom have also not been 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
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ITA No.4744/Del/2026
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 decided the instant issue of bogus purchases with divergent views i.e. both accepting or partly allowing or rejecting the same in entirety; as the case may be. 5. 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.1,09,90,926/- in 2018-19, would be just and proper with a rider that the same shall not be treated as a precedent. The assessee’s book entries to this effect are hereby rejected to the very extent. Necessary computation(s) shall follow as per law. No other ground or argument has been pressed. 6. This assessee’s appeal is partly allowed in above terms. Order pronounced in the open court on 2nd June, 2026 Sd/- (SATBEER SINGH GODARA) JUDICIAL MEMBER Dated: 8th July, 2026. RK/- Copy forwarded to: 1. Appellant 3 | P a g e
ITA No.4744/Del/2026
Respondent 3. CIT 4. CIT(A) 5. DR Asst. Registrar, ITAT, New Delhi
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More judgments on Section 69C
- Madhusudhan Gade, Nizamabad vs ITO., Ward-1, NizamabadITA 379/HYD/2025[2017-18]Status: Disposed28 Oct 2026AY 2017-18
- Jitendrakumar Bhikhabhai Shrimali, Mehsana vs ITO Ward 1, MehsaanaITA 1290/AHD/2026[2017-18]Status: Disposed21 Oct 2026AY 2017-18
- Sonu Jain, Agra vs ITO WD(1)(1)(2), AgraITA 671/AGR/2026[2024-25]Status: Disposed16 Oct 2026AY 2024-25
- Mritunjay Singh, Kudra vs AO, SasaramITA 454/PAT/2026[2017-2018]Status: Disposed16 Oct 2026AY 2017-2018
- Shantilal Mafaji Kachchhava, Banaskantha vs ITO WD 1 Palanpur, PalanpurITA 2256/AHD/2026[2023-24]Status: Disposed16 Oct 2026AY 2023-24
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