PARDEEP KUMAR,PANIPAT vs. ITO WARD -1, PANIPAT

This assessee’s appeal for Assessment Year 2018-19, arises against the CIT(A)/NFAC, Delhi’s DIN & order No.
ITBA/NFAC/S/250/2025-26/107937854(1) dated 29.07.2025, in proceedings u/s 147 r.w.s. 144B of the Income Tax Act, 1961
(in short “the Act”).
2. Heard both the parties at length. Case file perused.
3. Case called twice but none appeared. At assessee’s behest it is accordingly proceeded exparte.
4. It next emerges with the able assistance from Revenue’s side that both the learned lower authorities have disallowed the assessee’s purchases as sourced from alleged entry providers to the tune of Rs.27,32,625/- followed by estimation of 2%
commission expenditure to the tune of Rs.2603/-, as upheld in the lower appellate discussion.
Pardeep Kumar
2
5. Learned Departmental Representative vehemently argues in this factual matrix that supplier herein Sh. Rajesh Mittal had got recorded his statement before the GST authorities and admitted himself as an accommodation entry provider only. He could hardly dispute that both the lower authorities have neither rejected the assessee’s corresponding business sales nor his books of account all along. The necessary inference which would arise in such instance is that the assessee had actually sourced his purchases from unlisted dealers and availed accommodation entries from entry operators. It is thus deemed appropriate in larger interest of justice that a lump sum disallowance of 10% on the assessee’s foregoing purchases would be just and proper with a rider that the same would not be treated as a precedent. Necessary computation shall follow as per law.

Judicial Member

Dated: 13/10/2025
*NEHA, Sr. PS*