What is Balaji Textiles Industries Pvt Ltd. v. ITO authority for?

When an assessee demonstrates corresponding sales, it establishes that goods must have been purchased, and therefore, a complete disallowance of purchases solely based on doubts about supplier genuineness is generally not warranted.

How many judgments cite Balaji Textiles Industries Pvt Ltd. v. ITO?

53 judgments on BharatTax cite Balaji Textiles Industries Pvt Ltd. v. ITO (49 ITD 177), spanning 2016 to 2026.

Which sections of the Income Tax Act does Balaji Textiles Industries Pvt Ltd. v. ITO come up under?

It is most often cited in judgments turning on Section 147, Section 37(1), Section 143(3), Section 69C, Section 132(4), Section 133(6).

Balaji Textiles Industries Pvt Ltd. v. ITO (49 ITD 177)

Deputy Commissioner of Income Tax, Delhi vs. M/S Vestige Marketing Private Limited, Delhi

ITA 7842/DEL/2025[2022-23]Status: DisposedITAT Delhi20 Mar 2026AY 2022-23

Bench: Shri Before Shri Satbeer Singh Godarabefore Shri Before Shri Satbeer Singh Godarasatbeer Singh Godara & Satbeer Singh Godara & And & Shri Naveen Chandra Shri Naveen Chandra, , , Shri Naveen Chandra Shri Naveen Chandra

For Appellant: Shri Amit Goel and Shri Pranav Yadav, Advocate

Section 132Section 143(3)Section 147Section 37Section 37(1)Section 69A

…n the represented by corresponding sales or those items were lying in the represented by corresponding sales or those items were lying in the closing stock closing stock. closing stock closing stock 7.6 In the case of BALAJI TEXTILES INDUSTRIES (P) LTD.[1994] 49 ITD 177 BALAJI TEXTILES INDUSTRIES (P) LTD.[1994] 49 ITD 177 BALAJI TEXTILES INDUSTRIES (P) LTD.[1994] 49 ITD 177 BALAJI TEXTILES INDUSTRIES (P) LTD.[1994] 49 ITD 177 (Bom) (Bom) disallowance of purchases was made. The Hon’ble ITAT deleted (Bom) (Bom) the disallowance of purchases holding that no sales were likely to be no sales were likely to be no sales…

Deputy Commissioner of Income Tax, Delhi vs. M/S Vestige Marketing Private Limited, Delhi

ITA 7840/DEL/2025[2020-21]Status: DisposedITAT Delhi20 Mar 2026AY 2020-21

Bench: Shri Before Shri Satbeer Singh Godarabefore Shri Before Shri Satbeer Singh Godarasatbeer Singh Godara & Satbeer Singh Godara & And & Shri Naveen Chandra Shri Naveen Chandra, , , Shri Naveen Chandra Shri Naveen Chandra

For Appellant: Shri Amit Goel and Shri Pranav Yadav, Advocate

Section 132Section 143(3)Section 147Section 37Section 37(1)Section 69A

…n the represented by corresponding sales or those items were lying in the represented by corresponding sales or those items were lying in the closing stock closing stock. closing stock closing stock 7.6 In the case of BALAJI TEXTILES INDUSTRIES (P) LTD.[1994] 49 ITD 177 BALAJI TEXTILES INDUSTRIES (P) LTD.[1994] 49 ITD 177 BALAJI TEXTILES INDUSTRIES (P) LTD.[1994] 49 ITD 177 BALAJI TEXTILES INDUSTRIES (P) LTD.[1994] 49 ITD 177 (Bom) (Bom) disallowance of purchases was made. The Hon’ble ITAT deleted (Bom) (Bom) the disallowance of purchases holding that no sales were likely to be no sales were likely to be no sales…

Deputy Commissioner of Income Tax, Delhi vs. M/S Vestige Marketing Private Limited, Delhi

ITA 7838/DEL/2025[2018-19]Status: DisposedITAT Delhi20 Mar 2026AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Shri Amit Goel andFor Respondent: Ms. Monika Singh, CIT-DR

Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

…ases were not only supported by entries in books of accounts and stock registers but all such material purchase was represented by corresponding sales or those items were lying in the closing stock. 7.6 In the case of BALAJI TEXTILES INDUSTRIES (P) LTD.[1994] 49 ITD 177 (Bom) disallowance of purchases was made. The Hon'ble ITAT deleted the disallowance of purchases holding that no sales were likely to be effected if there were no purchases. A sale can be made only the goods are available with the seller. 7.7 In the case of INCOME TAX OFFICER VS. PERMANAND ITAT, JODHPUR BENCH - (2007) –addition under s.69 was made…

Vestige Marketing Pvt Ltd, Delhi vs. DCIT Central Circle -05, Delhi

ITA 5521/DEL/2025[2024-25]Status: DisposedITAT Delhi20 Mar 2026AY 2024-25

Bench: Shri Before Shri Satbeer Singh Godarabefore Shri Before Shri Satbeer Singh Godarasatbeer Singh Godara & Satbeer Singh Godara & And & Shri Naveen Chandra Shri Naveen Chandra, , , Shri Naveen Chandra Shri Naveen Chandra

For Appellant: Shri Amit Goel and Shri Pranav Yadav, Advocate

Section 132Section 143(3)Section 147Section 37Section 37(1)Section 69A

…n the represented by corresponding sales or those items were lying in the represented by corresponding sales or those items were lying in the closing stock closing stock. closing stock closing stock 7.6 In the case of BALAJI TEXTILES INDUSTRIES (P) LTD.[1994] 49 ITD 177 BALAJI TEXTILES INDUSTRIES (P) LTD.[1994] 49 ITD 177 BALAJI TEXTILES INDUSTRIES (P) LTD.[1994] 49 ITD 177 BALAJI TEXTILES INDUSTRIES (P) LTD.[1994] 49 ITD 177 (Bom) (Bom) disallowance of purchases was made. The Hon’ble ITAT deleted (Bom) (Bom) the disallowance of purchases holding that no sales were likely to be no sales were likely to be no sales…

Vestige Marketing Pvt Ltd, Delhi vs. DCIT, Central Circle-05, Delhi

ITA 5520/DEL/2025[2023-24]Status: DisposedITAT Delhi20 Mar 2026AY 2023-24

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

…ases were not only supported by entries in books of accounts and stock registers but all such material purchase was represented by corresponding sales or those items were lying in the closing stock. 7.6 In the case of BALAJI TEXTILES INDUSTRIES (P) LTD.[1994] 49 ITD 177 (Bom) disallowance of purchases was made. The Hon'ble ITAT deleted the disallowance of purchases holding that no sales were likely to be effected if there were no purchases. A sale can be made only the goods are available with the seller. 7.7 In the case of INCOME TAX OFFICER VS. PERMANAND ITAT, JODHPUR BENCH - (2007) –addition under s.69 was made…

Deputy Commissioner of Income Tax, Delhi vs. S S Pulses Manufacturing Pvt Ltd, Delhi

In the result, the appeal is partly allowed

ITA 2384/DEL/2024[2012]Status: DisposedITAT Delhi09 Dec 2025

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: NoneFor Respondent: Shri Manish Gupta, Sr. DR

Section 143(3)Section 147Section 148Section 69C

…und that there was no genuine transaction between the parties, a pure paper transaction could not have entitled the assessee to claim benefit under the law. Similarly, the Hon’ble Mumbai Tribunal held in the case of Balaji Textiles Industries Pvt Ltd Vs. ITO (49 ITD 177) that issue of bills by the alleged suppliers was not a conclusive proof. On the same facts, in the case of ITO Vs. Sunsteel (92 TTJ 126), the Hon’ble Ahmedabad Tribunal upheld 10% of the purchase price as Page 5 of 16 DCIT Vs. S.S. Pulses [A.Y 2012-13] inflated amount where suppliers were found to be nonexistent and did not respond to the notic…

Deputy Commissioner of Income Tax-1(1), Raipur vs. Shanta Techno Private Limited, Raipur

ITA 155/RPR/2025[2018-19]Status: DisposedITAT Raipur18 Jun 2025AY 2018-19

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 155/Rpr/2025 (िनधा"रण वष" Assessment Year: 2018-19)

For Appellant: NoneFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 142(1)Section 147Section 148Section 250Section 69C

…n the parties, a pure paper transaction could not have entitled the assessee to claim benefit under the law. 5 DCIT-1(1) vs. Shanta Techno Private Limited Similarly, the Hon'ble Mumbai Tribunal held in the case of Balaji Textiles Industries Pvt Ltd Vs. ITO (49 ITD 177) that issue of bills by the alleged suppliers was not a conclusive proof. On the same facts, in the case of ITO Vs. Sunsteel (92 TTJ 126), the Hon'ble Ahmedabad Tribunal upheld 10% of the purchase price as inflated amount where suppliers were found to be non-existent and did not respond to the notices issued by the Department. There are number of…

ITO-19(3)(1), Mumbai vs. Thana Ram Mangi Lal Choudhary, Mumbai

In the result, the appeal is partly allowed

ITA 2698/MUM/2024[2009-10]Status: DisposedITAT Mumbai29 Aug 2024AY 2009-10

Bench: Shri Amarjit Singh, Hon’Ble & Shri Anikesh Banerjee, Hon’Bleassessment Year: 2009-10 Ito-19(3)(1), Mumbai Thana Ram Mangi Lal Choudhary Vs 33/36, Prabhu Shree Ram Mandir, 4Th Kumbharwada, Maharashtra-400004. Pan: Afepc 1898 P (Appellant) (Respondent)

For Appellant: NoneFor Respondent: Shri P.D. Chougule Addl. CIT/ Sr. DR

Section 142(1)Section 145(3)Section 147Section 148

…nd that there was no genuine transaction between the parties, a pure paper transaction could not have entitled the assessee to claim benefit under the law. Similarly, the Hon’ble Mumbai Tribunal held in the case of Balaji Textiles Industries Pvt Ltd Vs. ITO (49 ITD 177) that issue of bills by the alleged suppliers was not a conclusive proof. On the same facts, in the case of ITO Vs. Sunsteel (92 TTJ 126), the Hon’ble Ahmedabad Tribunal upheld 10% of the purchase price as inflated amount where suppliers were found to be nonexistent and did not respond to the notices issued by the Department. There are number of d…

Harisons Steel Limited, Wada Thane vs. Dy CIT 12(2)(2), Mumbai

In the result, the appeal of the assessee vide ITA No

ITA 3957/MUM/2023[2013-14]Status: DisposedITAT Mumbai10 Jun 2024AY 2013-14

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhail

For Appellant: Mani JainFor Respondent: Biswanath Das

Section 143(3)Section 147Section 148

…und that there was no genuine transaction between the parties, a pure paper transaction could not have entitled the assessee to claim benefit under the law. Similarly, the Hon'ble Mumbai Tribunal held in the case of Balaji Textiles Industries Pvt Ltd Vs. ITO (49 ITD 177) that issue of bills by the alleged suppliers was not a conclusive proof On the same facts, in the case of ITO Vs. Sunsteel (92 TTJ 126), the Hon'ble Ahmedabad Tribunal upheld 10% of the purchase price as inflated amount where suppliers were found to be non-existent and did not respond to the notices issued by the Department Similarly, the Hon'ble…

Harisons Steel Ltd, Wada Thane vs. DCIT 12(2)(2), Mumbai

In the result, the appeal of the assessee vide ITA No

ITA 3943/MUM/2023[AY 2011-12]Status: DisposedITAT Mumbai10 Jun 2024

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhail

For Appellant: Mani JainFor Respondent: Biswanath Das

Section 143(3)Section 147Section 148

…und that there was no genuine transaction between the parties, a pure paper transaction could not have entitled the assessee to claim benefit under the law. Similarly, the Hon'ble Mumbai Tribunal held in the case of Balaji Textiles Industries Pvt Ltd Vs. ITO (49 ITD 177) that issue of bills by the alleged suppliers was not a conclusive proof On the same facts, in the case of ITO Vs. Sunsteel (92 TTJ 126), the Hon'ble Ahmedabad Tribunal upheld 10% of the purchase price as inflated amount where suppliers were found to be non-existent and did not respond to the notices issued by the Department Similarly, the Hon'ble…

Bhartiya International Ltd, New Delhi vs. DCIT, Circle-4(2), New Delhi

In the result, the appeal of the assessee is partly allowed

ITA 2109/DEL/2022[2017-18]Status: DisposedITAT Delhi02 Jan 2024AY 2017-18

Bench: Shri Saktijit Dey & Shri Pradip Kumar Kedia

For Appellant: Shri Amit Goel, AdvFor Respondent: Shri Rajesh Kumar, CIT-DR

Section 143(3)Section 144BSection 144C(13)Section 14ASection 156

…3) 355 ITR 290 (Guj.) to observe that since the impugned purchases have been sold and the sales have been accepted, there is no rationale for disallowing the purchases. The DRP also referred to judgment in the case of Balaji Textiles Industries P. Ltd. (1994) 49 ITD 177 (Mum.) providing similar view. The DRP accordingly expressed a view that there cannot be any sale without purchases in any business transaction as the accounting is complete only by taking I.T.A. No.2109/Del/2022 15 into account both the sides of the transactions. The sale and purchase transactions are thus requires to be simultaneously consider…