VESTIGE MARKETING PVT LTD,DELHI vs. DCIT, CENTRAL CIRCLE-05, DELHI

ITA 5520/DEL/2025Status: DisposedITAT Delhi20 March 2026AY 2023-2476 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal noted that additions cannot be made solely on the basis of retracted statements, especially when the assessee provides documentary evidence and the suppliers have filed returns. The Tribunal also acknowledged the evidentiary value of statements recorded under Section 132(4) but highlighted that retractions must be supported by strong evidence.

What were the facts?

The Assessing Officer disallowed the assessee's entire purchases treating them as bogus based on statements recorded during a search. The CIT(A) partly upheld this disallowance and deleted an addition made under Section 69A. Both the assessee and revenue have filed appeals against the CIT(A)'s order.

What were the issues?

Whether additions can be made based on retracted statements recorded during a search, and the evidentiary value of such statements when supported by documentary evidence and supplier compliance.

Which sections of the Income-tax Act were involved?

Section 37(1),Section 69A,Section 132(4),Section 133(6)

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Income Tax Appellate Tribunal, DELHI BENCH F: NEW DELHI

Before: SHRI SATBEER SINGH GODARA & SHRI NAVEEN CHANDRA

For Appellant: Shri Amit Goel, Shri Pranav Yadav, Advocates
For Respondent: Ms. Monika Singh, CIT-DR
Hearing: 24.02.2026Pronounced: 20.03.2026

PER BENCH These assessee's and the Revenue's seven cross-appeals each i.e., ITA Nos.5515 to 5521/Del/2025 and ITA Nos.7838 to 7844/Del/2025 for assessment years 2018-19 to 2024-25, arise against the CIT(A)-24, New Delhi orders; all dated 1st September, 2025, in proceedings under Section 147 read with Section 143(3) of the Income- tax Act, 1961 (hereinafter referred to as ‘the Act'), as the case may be, respectively.

2.

Heard both the parties. Case files perused.

3.

We advert to the “lead” assessment year 2018-19 involv

The order continues below.

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