PR. COMMISSIONER OF INCOME TAX -GHAZIABAD vs. RAMA ALLIED PRODUCTS MARKETING PVT. LTD.

O R D E R %

ITA 777/2025 (i) Whether on the facts, circumstances and in law, the order of the ITAT is perverse as the appeal of revenue has been dismissed refuting each allegation which were based on the material on record and holding that all the allegations were unsustainable, ignoring the plethora of evidence which is bringing out that the fraudulent nature of the transactions of the assessee? (ii) Whether on the facts, circumstances and in law, ITAT has erred in deleting the additions made by the Assessing Officer on account of alleged bogus purchases from M/s Raghubir Singh Devindra Kumar without properly considering the crucial incriminatory statements from the proprietors of the seller concern, transporter owners, and key employees of the assessee such as Mr Sanjay Mudgal. These statements explicitly pointed towards manipulation and non-genuine nature of the transactions, which the ITAT failed to reconcile with the documentary evidence? (iii) Whether on facts and circumstances and in law, the ITAT has erred in relying on invoices, transport receipts, ledger details, and bank statements produced by the assessee to establish genuineness of purchases, which did not adequately address the material discrepancies and contradictions in the documents, including inconsistent transportation vehicle details and failure to maintain stock reconciliation, which are fundamental to verify actual receipt and consumption of goods? (iv) Whether on facts and circumstances and in law, the ITAT has erred in allowing the appeal filed by the Assessee by not This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 25/04/2026 at 12:54:15

ITA 777/2025 considering the facts that the payment through banking channel to the supplier does not ipso facto validate the genuineness of purchases, especially where the transport payments were made by the supplier being common modus operandi in bogus transactions designed to mislead the Revenue Authorities? (v) Whether on the facts, circumstances and in law, the ITAT has erred in failing to appreciating the reasoning adopted by the AO in making the addition of Rs. 12,94,429/- on account of un- reconciled turnover based on the data seized during the course of search and seizure operation by holding that the same relate to M/s Rush Unit Purchase A/c without any further verification? (vi) Whether on the facts, circumstances and in law, the ITAT has erred in deleting addition of Rs. 12,75,741/- made on account of different stock verified from the closing stock as appearing in the books of the assessee with the physical stock available on the date of survey, which was confirmed by CIT(A) overlooking the fact that the said, addition was made after proper reconciliation of stock at the time of survey and subsequently confirmed by the CIT(A)?

ITA 777/2025 found/recovered from assessee’s possession.

ITA 777/2025 interference of this Court in the limited jurisdiction under Section 260A of the Act of 1961. 12. Further, since the tax effect in the instant appeal falls below the limits prescribed in CBDT Circular No.5/2024 dated 15.03.2024 read with Circular No. 9/2024 dated 17.09.2024, the appeal is liable to be dismissed.