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Income Tax Appellate Tribunal, DELHI BENCH: “SMC” NEW DELHI
Before: SHRI SATBEER SINGH GODARA
Date of hearing 29.10.2025 Date of pronouncement 29.10.2025 ORDER This assessee’s appeal for assessment year 2018-19, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s DIN and order no. ITBA/NFAC/S/250/2025-26/1078825894(1), dated 23.07.2025 involving proceedings under section 147 r.w.s. 144 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’). Case called twice. None appears at the assessee’s behest. It is accordingly proceeded ex-parte.
Learned departmental representative vehemently argues during the course of hearing that both the lower authorities herein have rightly disallowed the assesee’s entire purchases sourced from an accommodation entry provider entity M/s. Balaji Trading Company as per the GST department’s information gathered during the course of search in the latter’s case. He therefore seeks to confirm the entire purchases addition of Rs.40,84,187/- as bogus as per both the learned lower authorities’ respective findings.
I have considered the assessee’s stand all along and the Revenue’s foregoing vehement contentions. I find no reason to express my concurrence with the either party’s foregoing stands in entirety. This is for the precise reason that not only the assessee’s business activities i.e. trading in waste paper products stands accepted in principle but also its corresponding sales figures have not been disputed by both the learned lower authorities. The fact also remains that the assessee has not successfully proved the impugned purchases sourced from M/s. Balaji Trading Company as genuine all along. Be that as it may, it is thus deemed appropriate in the larger interest of justice that a lumpsum disallowance of 10% of the assessee’s foregoing purchases claimed
2 | P a g e to have been sourced from M/s. Balaji Trading Company is deemed as just and proper with a rider that the same shall not be treated as a precedent. Necessary computation shall follow as per law. All other remaining pleadings between the parties stand rendered academic.