MERCHANDISERS (P) LTD,MATTANCHERRY vs. DCIT.CORPORATE CIRCLE-2(1), KOCHI

ITA 601/COCH/2025Status: DisposedITAT Cochin29 October 2025AY 2016-17Bench: SHRI INTURI RAMA RAO (Accountant Member), SHRI ANIKESH BANERJEE (Judicial Member)1 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal noted that the assessee denied any transaction with the company providing the alleged bogus entries and asserted its total purchases were only Rs. 23,13,615/-. The Tribunal also noted the appellant's submission that it does not deal in garments.

What were the facts?

The assessee, engaged in trading raw-rubber, filed a return disclosing a loss. The AO initiated reassessment proceedings under section 147 based on information about bogus accommodation entries, leading to an addition of Rs. 1,45,91,304/-. The CIT(A) confirmed the AO's action.

What were the issues?

Whether the addition made on account of alleged bogus purchases is justified without proper verification, especially when the assessee denies transactions and the business profile does not match.

Which sections of the Income-tax Act were involved?

Section 143(1),Section 148,Section 147,Section 144B,Section 153BBE

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, COCHIN BENCH

Before: SHRI INTURI RAMA RAO, AM & SHRI ANIKESH BANERJEE, JM

For Appellant: Shri Thomson Thomas, CA
For Respondent: Smt. Leena Lal, Sr. D.R
Hearing: 27.10.2025Pronounced: 29.10.2025

Per: Inturi Rama Rao, AM This appeal filed by the assessee is directed against the order of the National Faceless Appeal Centre, Delhi (NFAC) dated 06.08.2025 for Assessment Year (AY) 2016-17. 2. Brief facts of the case are that the appellant is a private limited company engaged in the business of trading in raw-rubber. The return of income for AY 2016-17 was filed on 17.10.2016 disclosing loss of Rs. 3,79,128/-. The said return of income was processed u/s. 143(1) of the Income Tax Act, 1961 (the Act) accepting the returned

2 Merchandisers (P) Ltd. loss. Subsequently, the AO issued notice u/s. 148 of the Act based on the statement recorded from one Shri Joginder Pal Gupta during the course of search and seizure operation in his case on 23.12.2

The order continues below.

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