DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1, RAIPUR, NAWA RAIPUR vs. SUNIL KUMAR AGRAWAL LLP, RAIGARH
Facts
The Revenue appealed against the CIT(A)'s order which deleted a significant portion of the addition made by the AO on account of bogus purchases. The AO had taxed the entire purchases of Rs. 5,05,15,186/- after the assessee surrendered Rs. 2,71,50,000/-. The CIT(A) restricted the addition to 12.5% of the bogus purchases.
Held
The Tribunal held that the CIT(A) was not justified in making a partial disallowance and deleting the addition of Rs. 2,33,65,186/-. The assessee failed to prove the genuineness of the purchases with corroboratory evidence.
Key Issues
Whether the CIT(A) was justified in deleting the addition on account of bogus purchases and restricting it to a profit element, despite the assessee's failure to prove genuineness.
Sections Cited
Section 132, Section 147, Section 148, Section 250
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, RAIPUR BENCH, RAIPUR
Before: SHRI PARTHA SARATHI CHAUDHURY, JM & SHRI AVDHESH KUMAR MISHRA, AM
Per Avdhesh Kumar Mishra, AM: This appeal for Assessment Year (‘AY’) 2021-22 filed by the Revenue is directed against the order dated 27.03.2026 of Commissioner of Income Tax (Appeals), [‘CIT(A)’], Raipur-3 passed under section 250 of the Income Tax Act, 1961 (‘Act’).
The following grounds have been taken by the Revenue:
“1. Whether on the facts and circumstances of the case and
The order continues below.
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