INVENTUM ENGINEERING COMPANY PRIVATE LIMITED,MUMBAI vs. INCOME TAX OFFICER 10(1)(2), MUMBAI

The captioned appeal by assessee for Assessment Year [AY] 2011-12 contest the order of Ld. Commissioner of Income-Tax (Appeals)-17 [CIT(A)], Mumbai, Appeal No.CIT(A)-17/IT-103/10159/17- 18 dated 22/01/2018 qua confirmation of certain additions on account of alleged bogus purchases. The assessment for impugned AY was framed ITA.No.1836/Mum/2018 Inventum Engineering Company Pvt.Ltd Assessment Year- 2011-12 by Ld. Income Tax Officer-10(1)(2), Mumbai [AO] u/s 143(3) read with Section 147 of the Income Tax Act,1961 on 29/06/2016 wherein the income of the assessee has been determined at Rs.7,36,730/- after certain additions as against returned income of Rs.5,45,720/- e-filed by the assessee on 29/09/2011 which was processed u/s 143(1). The only issue involved under appeal is estimated addition against certain alleged bogus purchases. 2.1 The reassessment proceedings were initiated upon receipt of certain information from Sales Tax Department, Maharashtra regarding dealers indulging in bogus purchase bills and it was noted that the assessee stood beneficiary of such bogus purchase bills to the tune of Rs.1,91,007/- from three such entities, the details of which has been extracted in para-4.1 of the quantum assessment order. Consequently, statutory notice u/s 148 dated 28/03/2016 was issued to the assessee which was followed by notices u/s 143(2) and 142(1). During impugned AY, the assessee being resident corporate assessee was engaged in the business of manufacturing of engineering goods. 2.2 The assessee defended the purchases made by him and submitted documentary evidences to substantiate the same. However, notices issued u/s 133(6) to all the entities elicited no satisfactory response. The assessee expressed inability to produce the parties for confirmation of accounts. Finally, not convinced with assessee’s submissions, Ld. AO treated these purchase as bogus purchases and added the same to the income of the assessee. 3. Aggrieved, the assessee contested the same without any success before Ld. CIT(A) vide impugned order dated 22/01/2018 where Ld.