DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

ITA 7840/DEL/2025Status: DisposedITAT Delhi20 March 2026AY 2020-21Bench: SHRI SATBEER SINGH GODARA (Judicial Member), SHRI NAVEEN CHANDRA (Accountant Member)1 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal partly allowed the assessee's appeal by directing a lump-sum disallowance at 5% of the remaining disputed purchases, considering the business activity was admitted and books were not rejected. The Revenue's appeals were dismissed.

What were the facts?

The Assessing Officer disallowed the assessee's entire purchases of ₹8,86,36,574/-, treating them as bogus. The CIT(A) partly upheld this addition to the extent of ₹13,52,382/- and deleted an addition of ₹40,18,132/- made under Section 69A. The assessee sought to delete the remaining purchase disallowance, while the Revenue sought to uphold it and the Section 69A addition.

What were the issues?

Whether purchases can be disallowed solely based on statements recorded during a search, especially when retracted, and whether additions under Section 69A are justified.

Which sections of the Income-tax Act were involved?

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

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Cases cited in this judgment(30)Show list

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IN THE INCOME TAX APPELLATE TRIBUNAL IN THE INCOME TAX APPELLATE TRIBUNAL IN THE INCOME TAX APPELLATE TRIBUNAL IN THE INCOME TAX APPELLATE TRIBUNAL DELHI DELHI BENCH ‘ DELHI DELHI BENCH ‘ BENCH ‘F’ : NEW DELHI BENCH ‘ ’ : NEW DELHI ’ : NEW DELHI ’ : NEW DELHI

BEFORE SHRI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER BEFORE SHRI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER SATBEER SINGH GODARA, JUDICIAL MEMBER AND SATBEER SINGH GODARA, JUDICIAL MEMBER AND AND AND SHRI NAVEEN CHANDRA SHRI NAVEEN CHANDRA, , , , ACCOUNTANT MEMBER SHRI NAVEEN CHANDRA SHRI NAVEEN CHANDRA ACCOUNTANT MEMBER ACCOUNTANT MEMBER ACCOUNTANT MEMBER

ITA ITA No ITA ITA No Nos. No s. s.5515 to 5521/Del/2025 s. 5515 to 5521/Del/2025 5515 to 5521/Del/2025 along with ITA Nos.7838 to 5515 to 5521/Del/2025 along with ITA Nos.7838 to along with ITA Nos.7838 to along with ITA Nos.7838 to 7844/Del/2025 7844/Del/2025 7844/Del/2025 7844/Del/2025 Assessment Year Assessment Years : 2018 Assessment Year Assessment Year s : 2018 s : 2018-19 to 2024 s : 2018 19 to 2024 19 to 2024-25 19 to 2024 25 25 25

M/s Vestige Marketing M/s Vestige Marketing Vs. Vs. Deputy Commissioner of Deputy Commissioner of M/s Vestige Marketi

The order continues below.

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