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“Section 133(6)”

Section References (mined)Section 133Section 133(6)6,687 judgments

The decision most relied on for Section 133(6) is CIT v. Simit P. Sheth (356 ITR 451), cited in 1,465 judgments on BharatTax.

Leading authorities on Section 133(6)

CIT v. Simit P. Sheth
356 ITR 451 · 2013 · High Court
1,465
citing judgments

Additions for alleged bogus purchases should be restricted to the profit element, not the entire turnover. The profit element is often estimated at 12.5% of the purported bogus purchases.

CIT v. Orissa Corporation Pvt. Ltd.
159 ITR 78 · 1986 · Supreme Court
897
citing judgments

When an assessee provides the identity and address of a creditor or investor for a cash credit or share capital under Section 68, the burden shifts to the Department to establish lack of genuineness or creditworthiness, requiring it to conduct further inquiries; mere non-compliance by third parties to summons cannot be the sole basis for an adverse inference against the assessee.

Raymond Woollen Mills Ltd. v. ITO
236 ITR 34 · 1999 · Supreme Court
862
citing judgments

For reassessment proceedings under Section 148, the Assessing Officer only needs prima facie material to have a reason to believe income has escaped assessment. Conclusive proof or evaluation of the sufficiency and correctness of such material is not required at the stage of issuing the notice.

CIT v. Lovely Exports (P) Ltd.
216 CTR 195 · 2008 · Supreme Court
854
citing judgments

If an assessee company receives share application money from alleged bogus shareholders and provides their details to the Assessing Officer, no addition can be made under Section 68 in the company's hands; the Department must proceed against the shareholders by reopening their individual assessments.

CIT v. Tata Elxsi Ltd.
349 ITR 98 · 2012 · High Court
818
citing judgments

When computing deduction under Section 10A, if communication or telecommunication expenses are excluded from export turnover, they must also be excluded from total turnover to maintain consistency and apply the ordinary meaning of 'turnover' in context.

CIT v. Bholanath Poly Fab. Pvt. Ltd.
355 ITR 290 · 2013 · High Court
712
citing judgments

If an assessee makes purchases from bogus parties, but the underlying goods are genuinely acquired and sold, only the profit margin embedded in such purchases, and not the entire value of the bogus purchases, should be added to the assessee's income.

(Central)-1 v. NRA Iron & Steel (P) Ltd.
103 Taxmann.com 48 · 2019 · Supreme Court
696
citing judgments

When assessing cash credits, share capital, or loans, the assessee bears the onus to prove the identity, creditworthiness, and genuineness of transactions. This burden is not discharged merely by documentary evidence if field inquiries reveal accommodation entries or dealings with paper/shell companies.

CIT v. Daulat Ram Rawatmull
87 ITR 349 · 1973 · Supreme Court
525
citing judgments

The onus to prove that an apparent transaction or explanation is not real lies with the person who claims it to be so. If an assessee provides a plausible explanation for a transaction, the revenue must establish that the apparent transaction is not genuine.

Judgments citing Section 133(6)

M/S Sapphire Fintech Private Limited, Mumbai vs. DCIT-3(3)(1), Mumbai

ITA 594/MUM/2023[2012-13]Status: DisposedITAT Mumbai02 Jan 2026AY 2012-13

Bench: Shri Sandeep Singh Karhailshri Prabhash Shankar

For Appellant: Shri Mahaveer Jain, AdvFor Respondent: Shri Swapnil Choudhary, Sr.AR
Section 133(6)Section 142(1)Section 143(2)Section 143(3)Section 14ASection 250Section 68

submit confirmation of the said parties and justification for ITA No.594/Mum/2023 (A.Ys. 2012-13) 3 paying such a huge premium, notice under section 133(6) of the Act was issued to these parties. Out of the total eight parties, notices issued to five parties were returned with the remark “left ... hand, the learned Departmental Representative (“learned DR") submitted that the AO made an independent inquiry during the assessment proceedings and issued notice under section 133(6) of the Act to the share applicants. However, either these notices were returned unserved, or the share applicants did not file a response

Assistant Commissioner of Income Tax, Central Circle-25, New Delhi, Delhi vs. Bans Aerosol Private Limited, Delhi

Appeal of the Revenue is dismissed being devoid of any merit

ITA 7127/DEL/2025[2018-19]Status: DisposedITAT Delhi02 Jan 2026AY 2018-19

Bench: Shri Vikas Awasthyआअसं.7127/धिल्ली/2025 (नि.व. 2018-19) Assistant Commissioner Of Income Tax, Central Circle-25, R.No 317, 3Rd Floor, Ara Centre, ...... अपीलार्थी/Appellant Jhandewalan Extn. Delhi 110055 बिाम Vs. Bans Aerosol P. Ltd., 3/110, Lalita Park, Laxmi Nagar, Delhi 110092 ..... प्रनिवादी/Respondent Pan: Aaccb-1901-C अपीलार्थी द्वारा/Appellant By : Shri Manoj Kumar, Sr. Dr प्रधििािीद्वारा/Respondent By : Shri Akash Ojha, Advocate (Through Vc) सुिवाई की निथर्थ/ Date Of Hearing : 15/12/2025 घोषणा की निथर्थ/ Date Of Pronouncement : 02/01/2026 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Revenue Is Directed Against The Order Of Commissioner Of Income Tax (Appeals)-29, Delhi [In Short ‘The Cit(A)’] Dated 07.07.2025, For Assessment Year 2018-19. 2. The Appeal Is Time Barred By 7 Days. The Revenue Has Filed An Application Citing Reasons For Delay In Filing Of Appeal. After Perusal Of Same, I Am Satisfied That Delay In Filing Of Appeal Is Not Intentional, The Delay Has Been Caused For The Reasons Stated In Application Which Appears To Be Bonafide. Considering The Explanation Furnished By The Department, Delay Of 7 Days In Filing Of Appeal Is Condoned & Appeal Is Taken Up For Adjudication On Merits.

For Appellant: Shri Manoj Kumar, Sr. DRFor Respondent: Shri Akash Ojha, Advocate (Through VC)
Section 133(6)Section 144BSection 147Section 148ASection 68Section 69C

आयकर अपीलीय अधिकरण धिल्ली पीठ “एस एम सी”, धिल्ली श्री धिकास अिस्थी, न्याधयक सिस्य IN THE INCOME TAX APPELLATE TRIBUNAL

Rameshbhai Makanbhai Bhakta, Surat vs. Income Tax Officer, Bardoli

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 413/SRT/2025[2017-18]Status: DisposedITAT Surat01 Jan 2026AY 2017-18

Bench: Shri Sanjay Gargshri Narendra Prasad Sinha

For Appellant: Shri Arjav Vidani, ARFor Respondent: Shri Ajay Uke, Sr. DR
Section 133(6)Section 143(3)

IN THE INCOME TAX APPELLATE TRIBUNAL SURAT BENCH, SURAT BEFORE SHRI SANJAY GARG, JUDICIAL MEMBER SHRI NARENDRA PRASAD SINHA, ACCOUNTANT

Maithan Ceramic Ltd., Kolkata vs. ACIT, Circle 7(1), Kolkata

ITA 1944/KOL/2025[2011-2012]Status: DisposedITAT Kolkata01 Jan 2026AY 2011-2012
For Appellant: Shri P.K.Himmatsinghka, ARFor Respondent: Shri Sandeep Lakra, Sr. DR
Section 142(1)Section 269S

produced its bank statements to substantiate the receipt of the loan. Further, the Assessing Officer initiated independent verification by issuing notice under Section 133(6) to the lender. In response, M/s. Nidhi Agro Pvt. Ltd., vide its letter dated 17.12.2013, confirmed the loan transaction, owned up the payment of loan ... Vista Dealcom Pvt. Ltd. was opened only on 01.11.2010, as confirmed by ICICI Bank in response to a notice issued under Section 133(6) by DCIT, Circle 7(1), Kolkata during the reassessment proceedings for A.Y. 2010- 11. In contrast, the assessee had taken a loan of ₹1 crore from

Chintan Harshad Kanakia, Mumbai vs. ITO Ward 42(1)(1), Mumbai

In the result, ground No.3 of appeal is allowed

ITA 2822/MUM/2025[2015-16]Status: DisposedITAT Mumbai01 Jan 2026AY 2015-16

Bench: Shri Pawan Singhsmt Renu Jauhriassessment Year: 2015-16 (Hybrid Hearing) Chintan Harshad Kanakia, Ito Ward 42 (1)(1) Room No. 103, Sacovar Apt., Sagar Complex, 703, Kautilya Bhavan, Vs. Saibaba Nagar, Borivali (W), Bkc, Mumbai -400051 Mumbai Pan – Agnpk6023E

Section 10(38)Section 132Section 143(2)Section 148Section 148ASection 151ASection 234BSection 254(1)Section 271(1)(c)

issuing Company. The AO never examined register of members of Parag Shilpa Investments Ltd. to verify actual transfer entries. No notice under Section 133(6) or summon under Section 131 was issued to Conquer Barter Pvt. Ltd. The action of AO is purely presumptive and not supported

Varshaben Chauhan, at Dudhai, Jodiya, Jamnagar vs. ITO Ward 2(10) Jamnagar, Jamnagar

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

ITA 689/RJT/2025[2020-21]Status: DisposedITAT Rajkot31 Dec 2025AY 2020-21

Bench: Dr. Arjun Lal Sainiआयकर अपीलसं./Ita No. 689/Rjt/2025 ("नधा"रणवष"/Assessment Year: (2020-21) Varshaben Chauhan Ito, Wd – 2(10) At Dudhal, Jodiya, Jamnagar (Guj)-363655 Vs. Jamnagar (Guj) - 361008 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Ccipc6181L (अपीलाथ"/Appellant) (""यथ"/Respondent) Appellant By : Shri Suresh Tejwani, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 03/12/2025 : 31/12/2025 Date Of Pronouncement

For Appellant: Shri Suresh Tejwani, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 133(6)Section 147Section 250Section 69A

During the assessment proceedings, the assessing officer noticed that as per the information available and received from the Saurashtra Gramin Bank –Jamdudhai, under section 133(6) of the Income Tax Act, it was noticed that credits of Rs. 18,68,419/- (excluding credits of bank interest) has been deposited

Murubhai Hardasbhai Vasara, Porbandar vs. ITO WD 2 (4), Porbandar

In the result, the appeal of the assessee is partly allowed in above terms

ITA 554/RJT/2025[2017-18]Status: DisposedITAT Rajkot31 Dec 2025AY 2017-18

Bench: Dr. Arjun Lal Sainiआयकर अपील सं./Ita No. 554/Rjt/2025 िनधा"रण वष" /Assessment Year: (2017-18) Murubhai Hardasbhai Vasara Income-Tax Officer, Ward-2(4), Porbandar-360550 17, Main Bazar, Village Rana बनाम /Vs. Kandorna, Ranavav, Porbandar- 360 550 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Adqpv 9119 C (Appellant) (Respondent)

For Appellant: Shri Suresh Tejwani, Ld. ARFor Respondent: Shri Gopi Nath Chaubey Ld. Sr. DR
Section 133(6)Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 250

आयकर अपीलीय अिधकरण,राजकोट "ायपीठ, राजकोट। IN THE INCOME TAX APPELLATE TRIBUNAL, “SMC” RAJKOT BENCH, RAJKOT BEFORE DR. ARJUN LAL

Ajaykumar Natwarlal Sheth, Rajkot vs. The DCIT, Circle 1(2) Rajkot, Rajkot

ITA 108/RJT/2025[2010-11]Status: DisposedITAT Rajkot31 Dec 2025AY 2010-11
Section 143(1)Section 143(3)Section 147Section 148Section 250

आयकर अपीलीय अधिकरण, राजकोट न्यायपीठ, राजकोट । IN THE INCOME TAX APPELLATE TRIBUNAL, RAJKOT “SMC” BENCH, RAJKOT BEFORE DR. ARJUN LAL

Sayed Mohammad Azam Naqvi, Lucknow vs. Income Tax Officer, Range-4(4), Lucknow

In the result, the appeal of the assessee stands allowed for statistical purposes

ITA 643/LKW/2025[2017-18]Status: DisposedITAT Lucknow31 Dec 2025AY 2017-18

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudharyassessment Year: 2017-18 Sayed Mohammad Azam Naqvi V. The Income Tax Officer E-2824, Rajaji Puram Range 4(4) Lucknow Lucknow Tan/Pan:Ahbpn4634P (Appellant) (Respondent) Appellant By: Shri Rohit Bhalla, C.A. Respondent By: Smt. Sonal Singh, D.R. O R D E R

For Appellant: Shri Rohit Bhalla, C.AFor Respondent: Smt. Sonal Singh, D.R
Section 115BSection 133(6)Section 143(3)Section 144Section 44ASection 69A

treated as the unexplained income of the assessee. However, there was still no response from the assessee. The AO, thereafter issued notice under section 133(6) of the Act to the Bank of Baroda, Sarojini Nagar, Lucknow and obtained bank account statements relating to the assessee. As per the bank

Santosh Kumar Gupta, Lucknow vs. The Assessment Unit, NFAC, Delhi/ITO-1(4), Lucknow

In the result, the appeal of the assessee stands allowed for statistical purposes

ITA 498/LKW/2025[2017-18]Status: DisposedITAT Lucknow31 Dec 2025AY 2017-18

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2017-18 Santosh Kumar Gupta V. The Assessment Unit (Nfac) 624 61, Chinhat Ito 1(4), Lucknow Faizabad Road Lucknow (U.P) Tan/Pan:Ahspg3013E (Applicant) (Respondent) Applicant By: Shri Mahendra Kumar, Fca Respondent By: Shri R.R.N. Shukla, D.R. O R D E R This Appeal Has Been Preferred By The Assessee Against The Order Dated 29.05.2024, Passed By The National Faceless Appeal Centre, Delhi (Nfac) For Assessment Year 2017-18. 2.0 The Brief Facts Of The Case Are That The Assessee Was Carrying On The Business Of Mobiles, Electrical & Electronic Goods. The Assessee Had Not Filed The Return Of Income For The Year Under Consideration. The Income Tax Department Was In Possession Of Information That The Assessee Had Made Cash Deposits Of Rs.15,60,000/- During The Demonetization Period (From 09.11.2016 To 31.12.2016) In His Four Different Bank Accounts Bearing A/C Nos.20050580560 & 31121736248, Maintained With State Bank Of India, Chinhat Branch, Lucknow, A/C No.1840210572, Maintained With Central Bank Of India

For Respondent: Shri R.R.N. Shukla, D.R
Section 115BSection 133(6)Section 144Section 44ASection 69A

year under consideration. The AO, therefore, called for information relating to the bank account details of the assessee from the respective banks under section 133(6) of the Income Tax Act, 1961 (hereinafter called “the Act’). As per the details furnished by the banks, the sum of the cash deposits

Dharm Raj Kushwaha, Unnao vs. Income Tax Officer -2(4), Unnao

In the result, the appeal of the assessee stands allowed for statistical purposes

ITA 494/LKW/2025[2018-19]Status: DisposedITAT Lucknow31 Dec 2025AY 2018-19

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2018-19 Dharm Raj Kushwaha V. The Income Tax Officer 2(4) 172, Saipur Sarauda Unnao Safpur Unnao (U.P) Tan/Pan:Bmepk6477L (Applicant) (Respondent) Applicant By: None Respondent By: Shri R.R.N. Shukla, D.R. O R D E R This Appeal Has Been Preferred By The Assessee Against The Order Dated 27.05.2025, Passed By The National Faceless Appeal Centre, Delhi (Nfac) For Assessment Year 2018-19. 2.0 The Brief Facts Of The Case Are That The Assessee Was A Business Correspondent Of State Bank Of India & Ran A Customer Service Point (Csp). The Assessee Had Not Filed His Return Of Income For The Year Under Consideration. The Income Tax Department Was In Possession Of Information That The Assessee Had Made Cash Withdrawals Of Rs.1,36,10,616/- From The Current Account Maintained With The State Bank Of India, Received An Amount Of Rs.11,550/- As ‘Commission/Brokerage’ & ‘Insurance Commission’ During The Year Under Consideration. The Case Of The Assessee Was Reopened Under

For Respondent: Shri R.R.N. Shukla, D.R
Section 144Section 144BSection 147Section 148Section 194H

action of assessing officer without appreciating the fact that the impugned assessment was passed without ensuring the compliance of notice issued under section 133(6) of the Income Tax Act, 1961 himself by the assessing officer. 4. Because on the facts and in law, the Ld. CIT (Appeals) has erred

Harnek Singh, Shahjahanpur vs. Income Tax Officer, Shahjahanpur

In the result, the appeal of the assessee stands allowed for statistical purposes

ITA 492/LKW/2025[2017-18]Status: DisposedITAT Lucknow31 Dec 2025AY 2017-18

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2017-18 Harnek Singh V. The Income Tax Officer Jaswant Nagar Shahjahanpur Narotha Hansram Shahjahanpur Tan/Pan:Hdgps6958R (Applicant) (Respondent) Applicant By: Shri Dharmendra Kumar, C.A. Respondent By: Shri R.R.N. Shukla, D.R. O R D E R This Appeal Has Been Preferred By The Assessee Against The Order Dated 18.03.2025, Passed By The National Faceless Appeal Centre, Delhi (Nfac) For Assessment Year 2017-18. 2.0 The Brief Facts Of The Case Are That The Assessee Had Not Filed The Return Of Income For The Year Under Consideration. The Income Tax Department Was In Possession Of Information That The Assessee Had Made Cash Deposits Totaling To Rs.10,56,500/- In His Following Bank Accounts During The Demonetization Period (9.11.2016 To 30.12.2016):

For Respondent: Shri R.R.N. Shukla, D.R
Section 10(1)Section 115BSection 133(6)Section 142(1)Section 144Section 144(1)Section 69A

that the assessee also disclosed the accounts maintained with State Bank of India and Axis Bank. The AO also issued notice under section 133(6) of the Act to Axis Bank, Khutar Khas, Shahjahanpur and HDFC Bank Ltd., ITA No.492/LKW/2025 Page 3 of 7 Puranpur and obtained bank accounts statements

Nitin Dwivedi, Hardoi vs. CIT(A), Hardoi

In the result, the appeal of the assessee stands allowed for statistical purposes

ITA 362/LKW/2025[2017-18]Status: DisposedITAT Lucknow31 Dec 2025AY 2017-18

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudharyassessment Year: 2017-18 Nitin Dwivedi V. The Ito – 3(3) Avas Vikas Colony Hardoi Prahladpuri, Hardoi (U.P) Tan/Pan:Ajfpd9057Q (Appellant) (Respondent) Appellant By: None Respondent By: Shri R.R.N. Shukla, D.R. O R D E R

For Appellant: NoneFor Respondent: Shri R.R.N. Shukla, D.R
Section 115BSection 133(6)Section 142(1)Section 143(3)Section 144Section 250(6)Section 271ASection 69A

also obtained bank account statements for the financial years 2015-16 and 2016-17 from the respective banks under section 133(6) of the Act. However, the AO observed that the assessee had made cash deposits of Rs.19,18,000/- during the year under consideration in his bank accounts

Amar Diwakar, Kanpur Nagar vs. Dy. Commissioner of Income Tax, Circle-4, Kanpur

The appeal of the assessee stands allowed for statistical purposes

ITA 117/LKW/2025[2012-13]Status: DisposedITAT Lucknow31 Dec 2025AY 2012-13

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2012-13 Amar Diwakar V. Dcit J0512, Avas Vikas Circle 4 Keshavpuram, Kalyanpur Kanpur Kanpur Nagar (U.P) Tan/Pan:Aiypd7324G (Applicant) (Respondent) Applicant By: Shri Pradeep Seth, Advocate Respondent By: Shri R.R.N. Shukla, D.R. O R D E R This Appeal Has Been Preferred By The Assessee Against The Order Dated 20.12.2024, Passed By The National Faceless Appeal Centre, Delhi (Nfac) For Assessment Year 2012-13. 2.0 The Brief Facts Of The Case Are That As Per Information Gathered By The Department From Network Management System (Nms) Portal, The Assessee Had Earned Salary Income Of Rs.17,50,162/- From Fiit Jee Ltd & Had Made Cash Deposit Of Rs.11,50,000/- In His Saving Bank Account During The Year Under Consideration. The Assessee Had Not Filed His Return Of Income For The Year Under Consideration. The Assessing Officer (Ao) Initiated Proceedings Under Section 147 Of The Income Tax Act, 1961 After Issuing Notice Under Section 148 Of The Act To The Assessee. In Response To The Notice Under Section 148 Of The Act

For Respondent: Shri R.R.N. Shukla, D.R
Section 133(6)Section 147Section 148Section 250Section 271(1)(c)Section 69A

No.117/LKW/2025 Page 3 of 7 2.2 The AO also obtained bank statement of the assessee from Axis Bank under section 133(6) of the Act, as per which the assessee had made cash deposits of Rs.4,50,500/- during the year under consideration. In the absence of any documentary evidence

Abhiruchi Marketing P. Ltd., Kolkata vs. ITO, Ward 7(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 934/KOL/2025[2008-2009]Status: DisposedITAT Kolkata31 Dec 2025AY 2008-2009

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm Abhiruchi Marketing P. Ltd. C/O. S.N. Ghosh & Associates, Ito, Ward 7(1) Advocates, Aaykar Bhawan, P-7, 2, Garstin Place, 2 Nd Floor, Suite Chowringhee Square, Fifth Floor, Vs. No.203, Off Hare Street, Kolkata, Kolkata-700069, West Bengal West Bengal-700001 (Appellant) (Respondent) Pan No. Aagca1408B Assessee By : Shri Somnath Ghosh, Ar Revenue By : Shri Manas Mondal, Dr Date Of Hearing: 16.10.2025 Date Of Pronouncement: 31.12.2025

For Appellant: Shri Somnath Ghosh, ARFor Respondent: Shri Manas Mondal, DR
Section 131Section 132(6)Section 133(6)Section 142(1)Section 143(1)Section 147Section 263Section 68

IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, KOLKATA BEFORE SHRI RAJESH KUMAR, AM AND SHRIPRADIP KUMAR CHOUBEY, JM Abhiruchi

Vaibhav Nandkishor Patil, Navi Mumbai vs. Income-Tax Officer 3 (4), Kalyan, Thane District

Appeal of the assessee is allowed

ITA 1672/MUM/2025[2011-12]Status: DisposedITAT Mumbai31 Dec 2025AY 2011-12

Bench: Shri Pawan Singh & Shri Girish Agrawalassessment Year: 2011-12 Vaibhav Nandkishor Patil, Income Tax Officer 3 (4), Kalyan, C-602, Patel Heritage, Mumbai Sector, Kharghar Maharashtra -421301 Vs. Mumbai Maharastra-410210 (Pan: Amxpp0196M) (Appellant) (Respondent) Present For: Assessee : Shri Mehul Shah, Ca Revenue : Shri Praveen Salunkhe, Sr. Dr Date Of Hearing : 13.10.2025 Date Of Pronouncement : 31.12.2025 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Order Of Addl/Jcit(A), Panchkula, Vide Order No. Itba/Apl/S/250/2024- 25/1073638541(1), Dated 24.02.2025, Passed U/S. 250 Of The Income- Tax Act, 1961 (Hereinafter Referred To As The “Act”) Against The Assessment Order U/S. 143(3) R.W.S. 147 By Ito Ward 3(2), Kalyan, Dated 23.02.2015, For Assessment Year 2011-12. 2. Grounds Taken By The Assessee Are Reproduced As Under: 1. On The Facts & In Circumstances Of The Case & In Law, Learned Commissioner Of Income-Tax (Appeal) Erred In Upholding Action Of The Assessing Officer In Disallowing The Entire Alleged Bogus Purchases Of Rs.15,47,224 Without Making Any Independent Inquiry By Treating The Purchases As Bogus In Nature On Mere Suspicion That The Parties Were Listed On Website Of Mvat

For Appellant: Shri Mehul Shah, CAFor Respondent: Shri Praveen Salunkhe, Sr. DR
Section 133(6)Section 142(1)Section 143(3)Section 148Section 250

purchase vouchers, transportation and octroi payment receipts, stock register along with details of payment made in this respect. He also issued notice under Section 133(6) of the Act which was returned with the remarks “Left/Not Known”. Assessee was also asked to furnish bank details of the supplier from whom ... assessee as narrated above, ld. AO did not point out any discrepancy or deficiency in the same. Except for issuing notice under section 133(6) of the Act, no further exercise was undertaken by the ld. AO to examine and verify the information received alleging purchase made by the assessee

J. M. Housing Limited, Delhi vs. Pr. CIT (Central) Knp Meerut, Uttar Pradesh

In the result, the appeal of the assessee is allowed

ITA 8248/DEL/2025[2021-22]Status: DisposedITAT Delhi31 Dec 2025AY 2021-22

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2021-22] J.M. Housing Limited, Pr.Cit (Central) Kanpur, At Meerut, 312/3T/F5 Pratap Bhawan, Aayakar Bhawan, Bhainsali Ground, Bhahadur Shah Zafar Marg, Vs Meerut, Uttar Pradesh-25001 Central Delhi, Delhi-11002 Pan-Aaccj1692E Assessee Revenue

Section 133(6)Section 143(3)Section 263Section 271ASection 68

assessee merely furnished list of creditors along with ITRs and few incomplete confirmations. The ld. AO simultaneously issued notices under section 133(6) dated 29.11.2022 to sixteen creditors against whom large amounts were shown as outstanding. Out of sixteen, thirteen creditors responded electronically. The ld. AO has narrated the responses ... section 263 of the Act. The ld. Counsel submitted that as evident from the ld. AO extracted hereinabove, detailed enquiries under section 133(6) of the Act qua the impugned liabilities of Rs.12,48,69,810/- was made by the ld. AO. It was fiercely argued that therefore

Om Prakash, HUF, Jhajjar vs. ITO Ward -3, Rohtak

In the result, impugned order is set aside and appeal of the assessee is allowed

ITA 7186/DEL/2025[2022-23]Status: DisposedITAT Delhi31 Dec 2025AY 2022-23

Bench: Shri Vikas Awasthyआअसं.7186/धिल्ली/2025 (नि.व. 2022-23) Om Prakash, Huf 3/152, Kath Mandi, Bahadurgarh, Jhajjar, Haryana 124507 ...... अपीलार्थी/Appellant Pan: Aaaho-5004-J बिाम Vs. Income Tax Officer, Ward-3, ..... प्रनिवादी/Respondent Zila Parishad Building, Rohtak, Haryana अपीलार्थी द्वारा/Appellant By : S/Shri Pancham Sethi, Chartered Accountant & M.P Agarwal, Advocates प्रधििािीद्वारा/Respondent By : Shri Manoj Kumar, Sr. Dr सुिवाई की निथर्थ/ Date Of Hearing : 16/12/2025 घोषणा की निथर्थ/ Date Of Pronouncement : 16/12/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Order Of Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [In Short ‘The Cit(A)’] Dated 13.10.2025, For The Assessment Year 2022-23. 2. Shri Pancham Sethi, Appearing On Behalf Of The Assessee Submitted That The Assessee Is Engaged In The Business Ofwholesale Trading Of Timber. The Assessee Had Purchased Timber From Various Parties Including One Sadhu Ram Jai Prakash Of Gujarat. During The Course Of Assessment Proceedings, The Assessing Officer (Ao) Issued Notice U/S.133(6) Of The Income Tax Act,1961 (Hereinafter Referred To As ‘The Act’) To Various Parties, Some Of The Parties Confirmed & Furnished The Requisite

For Appellant: S/Shri Pancham Sethi, Chartered Accountant &For Respondent: Shri Manoj Kumar, Sr. DR
Section 133(6)

आयकर अपीलीय अधिकरण धिल्ली पीठ “एस एम सी”, धिल्ली श्री धिकास अिस्थी, न्याधयक सिस्य IN THE INCOME TAX APPELLATE TRIBUNAL

Harish Narang, Panipat vs. The Principal Commissioner of Income Tax, Rohtak

In the result, the appeal of the assessee is dismissed

ITA 3637/DEL/2025[2018-19]Status: DisposedITAT Delhi31 Dec 2025AY 2018-19

Bench: Shri Anubhav Sharma& Shri Amitabh Shukla[Assessment Year: 2018-19] Harish Narang, The Principal Commissioner Of H. No.238, Ward No.8, Income Tax, Rohtak, Panipat, Haryana-132103 Vs Aayakar Bhawan, Opp. Mansarover Park, Rohtak, Haryana-124001 Pan:Acvpn4090J Appellant Respondent Assessee By Shri Amit Kaushik, Adv. Revenue By Ms. Amisha S. Gupt, Cit(Dr) Date Of Hearing 16.10.2025 Date Of Pronouncement 31.12.2025

Section 144BSection 147Section 263Section 69C

failed to provide copies of cash book, bank pass book, delivery challans, consignment notes, etc. The ld. AO also conducted enquiries under section 133(6) against Shri Balaji Wooltex and Shri Rameshwaram International (supra), however the same went unanswered. The ld AO got enquiries conducted through Verification Unit

Deputy Commissioner of Income Tax, Meerut vs. Sunder Singh, Ghaziabad

In the result, all the appeals are filed by revenue are dismissed

ITA 376/DEL/2024[2016-17]Status: DisposedITAT Delhi31 Dec 2025AY 2016-17

Bench: Shri C.N. Prasad & Shri M. Balaganesh

Section 143(2)Section 153ASection 68

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, ‘G’: NEW DELHI BEFORE SHRI C.N. PRASAD, JUDICIAL MEMBER AND SHRI M