DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, LUDHIANA, LUDHIANA vs. M/S FORTUNE METALS LTD., LUDHIANA

ITA 961/CHANDI/2025Status: DisposedITAT Chandigarh19 March 2026AY 2022-23Bench: SHRI LALIET KUMAR (Judicial Member), SHRI MANOJ KUMAR AGGARWAL (Accountant Member)9 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal upheld the CIT(A)'s decision to estimate the Gross Profit rate at 6% on the alleged bogus purchases, affirming that documentation was provided but complete onus was not discharged. Regarding the Rs. 12.60 Lacs addition, the Tribunal confirmed its deletion by the CIT(A), finding no corroboration or evidence linking the WhatsApp chat between two independent parties to the assessee.

What were the facts?

The assessee, engaged in manufacturing TMT bars/MS pipes, faced additions by the AO for alleged bogus purchases of Rs. 222.12 Lacs and unexplained cash expenditure of Rs. 12.60 Lacs based on a WhatsApp chat found during a search. The CIT(A) restricted the bogus purchase addition to 6% of the gross profit element and deleted the addition related to the WhatsApp chat. Both the revenue and the assessee (via cross-objection) appealed the CIT(A)'s order.

What were the issues?

1. Whether the CIT(A) was justified in restricting the addition for bogus purchases to a 6% Gross Profit rate. 2. Whether the addition of unexplained cash expenditure based on a WhatsApp chat, without corroboration, was justified.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 69C,Section 132,Section 145(3),Section 251(2),Section 133(6)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “A” BENCH, CHANDIGARH

Before: HON’BLE SHRI LALIET KUMAR, JM & HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM

Heard together (2 matters)

ITA No.961/Chandi/2025
CO. No.36/Chandi/2025

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

Manoj Kumar Aggarw

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 69C

All 8,217 judgments and leading authorities on Section 69C →

Latest GST High Court judgments

Search GST case law →