RITIKA ISPAT PRIVATE LIMITED,ROURKELA vs. ACIT, SAMBALPUR

ITA 194/CTK/2026Status: DisposedITAT Cuttack23 June 2026AY 2019-202042 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that statements recorded under section 132(4) are crucial evidence and cannot be discarded without proper justification, especially when not retracted promptly. The addition under section 69C for unexplained expenditure is valid even without rejecting the books of account under section 145(3) if the purchases are found to be non-genuine.

What were the facts?

The assessee company's premises were searched, and during the search, it was found that the company was allegedly obtaining accommodation entries for bogus purchases from fictitious entities. The assessee failed to provide satisfactory explanations or evidence to substantiate these purchases.

What were the issues?

The primary issues were the validity of assessment under section 153A in the absence of incriminating material and the addition of alleged bogus purchases under section 69C based on third-party statements and investigation reports without cross-examination.

Which sections of the Income-tax Act were involved?

Section 153A,Section 69C,Section 132(4),Section 145(3)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, CUTTACK BENCH, CUTTACK

For Appellant: Shri Ambika Prasad Mohanty, AR
For Respondent: Shri Rajesh Mishra, CIT-DR
Hearing: 27.04.2026Pronounced: 23.06.2026

PER LAXMI PRASAD SAHU, ACCOUNTANT MEMBER

These two appeals were filed by the assessee against the separate order passed u/s 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) by the Ld. Commissioner of Income Tax (Appeals), Bhuwaneswar-2 [hereinafter referred to as “the Ld. CIT(A)] dated 31.12.2025, DIN & order No. ITBA/APL/S/250/2025- 26/1084255919(1) for AY 2019-20 and order dated 02.01.2026 ITBA/APL/S/250/2025-26/1084381935(1).

2.

The assessee has raised following grounds of appeal in ITA No. 194/CTK/2026:

“Ground 1 That the learned CIT A erred in law and on facts i

The order continues below.

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