JORSS BULLION PVT LTD,MUMBAI vs. DY COMMISSIONER OF INCOME TAX -CENTRAL CIRCLE 7(1), MUMBAI

ITA 4758/MUM/2025Status: DisposedITAT Mumbai04 March 2026AY 2017-1825 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that the CIT(A) erred in rejecting the assessee's books of account and making an estimated addition for commission income. The Tribunal found that the CIT(A)'s findings were contradictory and not supported by evidence.

What were the facts?

The Revenue appealed against the deletion of an addition of ₹39,36,03,084 made under Section 69C for bogus purchases. The assessee also appealed against an addition of ₹28,88,464 made by estimating commission income.

What were the issues?

Whether the CIT(A) erred in deleting the addition for unexplained expenditure and in estimating commission income without proper evidence. The key issue is the validity of rejecting books of account and making additions based on assumptions.

Which sections of the Income-tax Act were involved?

Section 69C,Section 145(3),Section 115BBE

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Cases cited in this judgment(10)Show list

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Income Tax Appellate Tribunal, F BENCH MUMBAI

Before: HON’BLE SHRI SANDEEP GOSAIN& SHRI OMKARESWAR CHIDARA

For Appellant: Shri Satyaprakash Singh
For Respondent: Shri Vivek Perampurna, CIT DR
Hearing: 01.12.2025Pronounced: 04.03.2026

Heard together (2 matters)

ITA No. 4004/Mum/2025
ITA No. 4758/Mum/2025

Read from the judgment's own cause title. This page is filed under one of them.

PER SANDEEP GOSAIN, JM: and assessee against the common order dated 28.03.2025 passed by the National Faceless Appeal Centre, Delhi / Ld. CIT(A) Mumbai, for the A.Y 2017-18.

Since all the issues involved in these two appeals are

The order continues below.

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