BHARAT TRADING CORPORATION,MUMBAI vs. DCIT- 19(1), PIRAMAL CHAMBERS
Facts
The assessee, a diamond trading firm, had its assessment reopened based on information about accommodation entries. The Assessing Officer disallowed purchases aggregating to Rs. 5,31,20,779/- treating them as non-genuine.
Held
The Tribunal held that while the purchases were not fully genuine, a 100% disallowance was not justified as corresponding sales were accepted. The addition was restricted to 10% of the impugned purchases to represent the profit element.
Key Issues
Whether the reassessment proceedings were validly initiated and whether the entire amount of non-genuine purchases could be disallowed when corresponding sales were accepted.
Sections Cited
Section 37, Section 147, Section 144B, Section 148A, Section 149
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, MUMBAI BENCHES, MUMBAI
Before: SMT. BEENA PILLAI, HON’BLE & SMT. RATNA DASGUPTA, HON’BLE
PER SMT. BEENA PILLAI, JUDICIAL MEMBER:
Present appeal filed by assessee arises out of the order dated 23/02/2026 passed by NFAC, Delhi [hereinafter referred to as “Ld.CIT(A)”] for A.Y. 2013-14, on the following ground/s of appeal:-
“1) Ground 1 - The NATIONAL FACELESS APPEAL CENTRE (NFAC) failed to appreciate that the AO had not followed the procedure prescribed under section 148A
The order continues below.
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