PRAKASH CORPORATES, RAIPUR,RAIPUR vs. ACIT, CIRCLE 1(1), RAIPUR, RAIPUR

ITA 673/RPR/2025Status: HeardITAT Raipur05 August 2026AY 2018-198 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal held that adding the entire bogus sales was not justified as the purchases were accepted and the books of account were not rejected. It directed that only the profit element embedded in the bogus sales should be added.

What were the facts?

The assessee, a partnership firm engaged in iron and steel trading, was found to have made bogus sales amounting to Rs. 1,63,59,266/-. The Assessing Officer added this entire amount as undisclosed income, which was upheld by the CIT(A).

What were the issues?

Whether the entire amount of bogus sales can be added as income, or only the profit element embedded therein, especially when purchases were accepted and books of account were not rejected.

Which sections of the Income-tax Act were involved?

Section 68,Section 139(1),Section 147,Section 148,Section 142(1),Section 151,Section 115BBE

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, RAIPUR BENCH, RAIPUR

Before: JUSTICE (RETD.) SHRI C. V. BHADANG & SHRI R. K. PANDA

For Appellant: Shri G.S. Agrawal, CA
For Respondent: Shri Piyush Tripathi, Sr.DR

PER R.K. PANDA, VP:

This appeal filed by the assessee is directed against the order dated 01.08.2025 of the Ld. CIT(A) / NFAC, Delhi relating to assessment year 2018- 19. 2

2.

Facts of the case, in brief, are that the assessee is a partnership firm and engaged in the business of Iron and Steel trading. It filed its return of income u/s 139(1) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) on 18.10.2018 declaring total income of Rs.71,58,680/-. As per specific information received it was noticed that the assessee has made bogus sale of Rs.65,55,422/- to Rajendra Ispat and Rs.98,03,844/- to Pratyush Steels. Thus, the total bogus sales were Rs.1,63,59,266/-. As per information, Pratyush Steels and Raj

The order continues below.

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