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Facts
The appeals concern two assessees, Amrit Supply Company Limited and Mayur Roller Flour Mills (P) Ltd., for various assessment years. Amrit Supply's appeal related to an addition for cash deposits during the demonetization period. Mayur Roller Flour Mills' appeals involved additions for bogus purchases amounting to ₹26,41,17,433/-, identified through information from a search action against another party. Both assessees failed to cooperate and provide evidence at all stages of the proceedings before the AO, CIT(A), and the Tribunal.
Held
The Tribunal upheld the additions made by the lower authorities for both unexplained cash deposits during demonetization and bogus purchases. The decision was based on the assessees' complete non-cooperation in providing any explanation or evidence to controvert the findings of the lower authorities. Consequently, all appeals were dismissed.
Key Issues
Validity of additions for unexplained cash deposits during demonetization and for bogus purchases; the impact of the assessee's non-cooperation during assessment and appellate proceedings on the outcome.
Sections Cited
Section 147, Section 148, Section 132(4), Section 144
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, “A” BENCH, KOLKATA
Before: SHRI RAJESH KUMAR, AM & SHRIMANOMOHAN DAS, JM
As the facts and circumstances are identical in all the appeals of two different assessee’s, hence, these are being decided and disposed by this consolidated order for the sake of brevity. We will take for A.Y. 2017-18 first and decide the issue accordingly.
ITA No.144/GTY/2025 A.Y. 2017-18
3. The case was heard on 16.05.2025 and Shri S.K. Pransukhaka, authorized representative of the assessee appeared on behalf of the assessee and Shri Kaushik Roy, JCIT appeared on behalf of the Revenue.Both the sides argued the case at length. The counsel of the assessee was directed to file certain details as regards purchases and sales in support of his arguments concerning the alleged cash deposit during the demonetization. The counsel was asked to furnish certain details comprising bills, vouchers, invoices of the proof of payments, transport lorry receipts, weigh receipts, etc. and tally receipts etc. However, the counsel thereafter never turned up. The case was again fixed for clarification on 07.11.2025. However, no one appeared on behalf of the assessee despite being informed specifically on telephone. Therefore, we have no option but to dispose off these appeals on the basis of materials available before us with the help of ld. Departmental Representative. Pertinent to state that these appeals were decided ex-parte when the assessee did not respond to the various opportunities before the respective authorities below. Before us also the assessee is totally non-cooperative and is not 5. The only issue raised by the assessee is against the order of ld. CIT (A) confirming the addition of ₹26,41,17,433/- as made by the ld. AO on account of bogus purchases.
5.1. The facts in brief are that the assessee filed the return of income on 31.03.2015 of ₹26,15,750/-. The assessee was stated to be engaged in the business of trading in Guwahati. The case of the assessee was reopened u/s 147 of the Act and notice u/s 148 of the Act was issued on 27.03.2021. The assessee has not filed any return of income and thereafter, the detailed questionnaire was issued to the assessee which was not complied with by the assessee. The ld. AO upon perusal of information received from DCIT Central Circle 4(1), Kolkata, regarding survey and search operation conducted in the case of Shri Sanjeev Kejriwal, where during the course of recording statement u/s 132(4) of the Act, Kejriwal had accepted that his group concerns namely; Rajputana General commercial Corporation Pvt. Ltd. , Arvind Trading Co. and Shri Krishna Trading
5.2. In the appellate proceedings, there was no compliance to various notices issued to the assessee. Finally, the ld. CIT (A) upheld the order of the ld. AO after discussing the issue in para no.6.3 of the appellate order and affirmed the order of the ld. AO.
5.3. After hearing the rival contentions and perusing the materials available on record, we find that the assessee though made representation on 16.05.2025 before us and requested some more time to prepare and place the evidences on record for the purchase, however, till date of hearing i.e. 07.11.2025, no details were filed and even today when the case of the assessee was called for hearing there was no representation on behalf of the assessee and accordingly, we are deciding the appeal with the assistance of ld. DR on the basis of records available before us.
5.4. We find that the department has cogent and sufficient evidences in its possession that assessee had made bogus purchases to the tune of ₹26,41,17,433/- from Rajputana General Commercial Corporation Pvt. ltd. during the year for which no evidences were filed before the ld. AO as well as before the ld. CIT (A). Since, there 02. The issue raised in these appeals are similar to one as decided by us in ITA No. 145/GTY/2024. Accordingly, our decision would, mutatis mutandis, apply to these appeals of assessee in & 150/GTY/2024 as well. Hence, these appeals of assessee are dismissed.
In the result, all the appeals of the assessee are dismissed.
Order pronounced in the open court on 17.11.2025.