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Facts
The appeals involve two assessees. Amrit Supply Company Limited appealed against additions for unexplained cash deposits during demonetization. Mayur Roller Flour Mills (P) Ltd. challenged additions made for bogus purchases amounting to ₹26,41,17,433/-, where the supplier was found to be providing accommodation entries. In both cases, the assessees failed to provide necessary explanations or evidence despite multiple opportunities.
Held
The tribunal dismissed all appeals. It found the assessees to be non-cooperative and that they failed to provide any explanation or evidence to support their claims regarding cash deposits or purchases, thereby upholding the findings of the lower authorities.
Key Issues
Whether additions for cash deposits during demonetization were justified due to lack of explanation/evidence; whether additions for bogus purchases were justified given the assessee's non-compliance and information regarding accommodation entries.
Sections Cited
147, 148, 132(4), 144
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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 5.1. 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 ,147,149,150/GTY/2024 02. The issue raised in these appeals are similar to one as decided by us in . 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.