INCOME TAX OFFICER, DELHI vs. MEENAKSHI CHAUHAN, DELHI
What did the Tribunal hold?
The Tribunal acknowledged divergent judicial opinions on bogus purchases. It decided to allow a lumpsum disallowance of 5% of the alleged bogus purchases, stating it would not be treated as a precedent.
What were the facts?
The Assessing Officer disallowed the assessee's entire bogus purchases of Rs. 13,32,456/-. The CIT(A)/NFAC deleted this disallowance. The Revenue appealed this deletion.
What were the issues?
Whether the CIT(A)/NFAC erred in deleting the disallowance of bogus purchases. The issue of how to treat alleged bogus purchases when substantial documentation is lacking.
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.4684/Del/2026 Assessment Year: 2020-21 Income Tax Officer, Vs. Meenakshi Chauhan, New Delhi 351/A, Gali No.12, Laxmi Nagar, East Delhi, New Delhi PAN: AURPC8459Q (Appellant) (Respondent) Assessee by None Department by Sh. Manoj Kumar, Sr. DR Date of hearing 01.06.2026 Date of pronouncement 01.06.2026 ORDER This Revenue’s appeal for assessment year 2020-21, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s DIN and order no. ITBA/NFAC/S/250/2025-26/1087339456(1), dated 13.03.2026 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/respondent’s behest. She is accordingly proceeded ex-parte. 2. Learned departmental representative vehemently argues during the course of hearing that the CIT(A)/NFAC has erred in law
ITA No.4684/Del/2026
and on facts in deleting the Assessing Officer’s action disallowing the assessee’s entire bogus purchases of Rs.13,32,456/- u/s 69C sourced from M/s Sai Trading Company of Rs.3,57,540/-, M/s Vidhata Enterprises of Rs.4,01,436/- and from M/s V.K. Industries amounting to Rs.5,73,480/- as no substantial documents have been brought on record regarding the above bogus purchases. 3. That being the clinching factual position, learned counsel appearing for both the parties could hardly dispute that 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 opinions as well. It is thus deemed appropriate in the larger interest of justice that lumpsum disallowance/addition @ 5% of the assessee’s alleged bogus purchases of Rs.13,32,456/-, would be just and proper with a rider that the same shall not be
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ITA No.4684/Del/2026
treated as a precedent. Necessary computation shall follow as per law. 4. This Revenue’s appeal is partly allowed. Order pronounced in the open court on 1st June, 2026 Sd/- (SATBEER SINGH GODARA) JUDICIAL MEMBER Dated: 29th June, 2026. RK/- Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(A) 5. DR Asst. Registrar, ITAT, New Delhi
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