NISHA RANI,C/O SAHAY ENTERPRISES vs. THE INCOME TAX OFFICER, WARD -1(2), AAYAKAR BHAWAN,

ITA 434/GTY/2025Status: DisposedITAT Guwahati13 March 2026AY 2020-2021Bench: SHRI DUVVURU RL REDDY (Vice President), SHRI RAJESH KUMAR (Accountant Member)6 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal held that while the purchases might be bogus, the entire amount could not be disallowed, especially when sales were not doubted and accounts were not rejected. The Tribunal directed the Assessing Officer to estimate the income at 3% on the bogus purchases, considering it as reasonable profit earned.

What were the facts?

The assessee filed a return of income, and the case was reopened based on information that the assessee made fictitious purchases of Rs. 45,36,000/- from M/s Tradewell Enterprises, identified as a bogus accommodation entry provider. Despite the assessee furnishing supporting documents, the Assessing Officer added the entire purchase amount to the income as unexplained expenditure.

What were the issues?

Whether the entire amount of alleged bogus purchases can be added to the assessee's income, or if only a notional profit should be estimated.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 148A,Section 142(1),Section 69C,Section 144,Section 144B,Section 145(3)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘GAUHATI BENCH’, GUWAHATI

For Appellant: Shri Vishesh Surana, FCA
For Respondent: Shri Santosh Kumar Karnani, Addl
Hearing: 09/03/2026Pronounced: 13/03/2026

PER: BENCH

This is an appeal preferred by the assessee against the order of the National Faceless Appeal Centre, Delhi (hereinafter referred to as the “Ld. CIT(A)”] dated 29.10.2025 for the AY 2020-21. 2. The only issue raised by the assessee in the various grounds of appeal is against the order of the ld. CIT(A) in upholding the addition of Rs. 45,36,000/- as made by the Assessing Officer under Section 69C of the Income Tax Act, 1961 (in short, the Act) on account of bogus purchases by the assessee.

2

3.

The facts of the case, in brief, are that the assessee filed return of income declaring total income of ₹ 45,50,680/-. The case of the assessee was reopened under Section 147 of the Act by issuing notice under Section 1

The order continues below.

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