RSWM LIMITED,RAJASTHAN vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-31, DELHI

ITA 4876/DEL/2025Status: DisposedITAT Delhi11 March 2026AY 2012-13Bench: SHRI CHALLA NAGENDRA PRASAD (Judicial Member), SHRI M. BALAGANESH (Accountant Member)6 pages
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What did the Tribunal hold?

The Tribunal held that the Assessing Officer relied solely on the Investigation Wing's report without conducting independent enquiries. The statement from the vendor was not confronted to the assessee. The assessee provided sufficient documentary evidence to prove the genuineness of the purchases.

What were the facts?

The assessee, RSWM Ltd, appealed against the disallowance of purchases amounting to Rs. 30,56,706/-. The purchases were alleged to be bogus accommodation entries, based on information from an Investigation Wing report.

What were the issues?

Whether purchases from M/s. Arunoday Cotton Corporation were bogus, and if so, whether the disallowance made by the AO was justified.

Which sections of the Income-tax Act were involved?

Section 147,Section 143(3),Section 37,Section 139(1),Section 132,Section 153A,Section 148,Section 142(1),Section 145(3)

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Income Tax Appellate Tribunal, DELHI BENCH “C”: NEW DELHI

For Appellant: Shri Satyajeet Goyal, CA
For Respondent: Shri Om Prakash, Sr. DR
Hearing: 13/01/2026Pronounced: 11/03/2026

PER M. BALAGANESH, A. M.:

1.

The appeal in ITA No.4876/Del/2025 for AY 2012-13, arises out of the order of the ld Commissioner of Income Tax (Appeals)-31, New Delhi [hereinafter referred to as ‘ld. CIT(A)’, in short] dated 28.07.2025 against the order of assessment passed u/s 147 r.w.s. 143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) dated 13.12.2019 by the Assessing Officer, ACIT, Central Circle-31, New Delhi (hereinafter referred to as ‘ld. AO’).

2.

Ground No. 1 raised by the assessee was stated to be not pressed by the ld AR at the time of hearing. The same is reckoned as a statement made from the Bar and accordingly dismissed as not pressed.

3.

Ground Nos. 3 and 4 raised by the assessee are general in nature and does not require any

The order continues below.

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