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“bogus purchases”

DisallowancesSection 69CSection 69C9,532 judgments

The decision most relied on for bogus purchases is CIT v. Bholanath Poly Fab. Pvt. Ltd. (355 ITR 290), cited in 712 judgments on BharatTax.

Leading authorities on bogus purchases

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.

Sanjay Oilcake Industries v. CIT
316 ITR 274 · 2009 · High Court
460
citing judgments

In cases of alleged bogus or unverifiable purchases, rather than disallowing the entire purchase value, a reasonable profit element or a proportionate percentage of the purchases should be added back to the assessee's income.

Vijay Proteins Ltd. v. Asst. CIT
58 ITD 428 · 1996 · ITAT
430
citing judgments

Where purchases are found to be non-genuine or fictitious, a reasonable disallowance of 25% of such purchases or the peak credit, whichever is higher, can be made. This is applied to address unexplained expenditure under Section 69C when actual goods are likely procured from the grey market.

CIT v. Odeon Builders Pvt. ltd.
418 ITR 315 · 2019 · Supreme Court
408
citing judgments

Income tax additions cannot be sustained merely on the basis of uncorroborated statements or allegations. The Revenue must bring on record sufficient material and allow the assessee to produce evidence to prove such additions.

Nikunj Eximp Enterprises v. CIT
216 Taxmann 171 · 2013 · High Court
325
citing judgments

Purchases may be treated as genuine even if the purchase parties are untraceable or not available for verification, as long as there is no specific evidence from the parties themselves denying the transactions or proving them to be bogus.

CIT v. Shyam R. Pawar
54 Taxmann.com 108 · 2015 · High Court
279
citing judgments

Transactions involving the purchase and sale of shares cannot be considered bogus where the assessee provides documentary evidence, unless the revenue brings substantial evidence on record to reject such proof. This principle is consistently applied in cases concerning claims of bogus long-term capital gains arising from penny stock transactions.

CIT v. Simit P. Seth
38 Taxmann.com 385 · 2013 · High Court
278
citing judgments

When an assessee obtains accommodation bills for purchases but the corresponding sales are genuine, the addition to income is limited to the gross profit margin embedded in such purchases. This principle acknowledges that the underlying sales were real, but profit was suppressed through bogus invoices.

CIT v. Vijay M. Mistry Construction Ltd.
355 ITR 498 · 2013 · High Court
252
citing judgments

In cases of alleged bogus or hawala purchases where the existence of transactions is not entirely denied, only the profit element embedded in such purchases, and not the entire purchase price, can be added to the assessee's income. The focus is on determining a reasonable profit percentage for such additions.

Judgments citing bogus purchases

CO-OPERATION METALS,PUNE vs. ITO WARD 6(3), PUNE

In the result, the appeals filed by the assessee are partly allowed and the appeals filed by the Revenue are dismissed

ITA 2321/PUN/2024[2010-11]Status: DisposedITAT Pune21 Apr 2026AY 2010-11

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Madhan Thirmanpalli, Addl. CIT
Section 131Section 133ASection 143(1)Section 143(2)Section 143(3)Section 147

hawala parties. 5. In appeal the Ld. CIT(A) / NFAC directed the Assessing Officer to restrict the addition to 18% of the said bogus purchases by observing as under: ITA Nos.2319 & 2271/PUN/2024 & Ors 6. Aggrieved with part relief granted by the Ld. CIT(A) / NFAC, the assessee as well ... deciding the GPM (gross profit margin) of 18% on alleged Hawala Purchases solely relying upon the information received from sales tax department indicating alleged bogus purchases made. The I-T authorities ought to have proceeded further for cross-examination of the suppliers/further probing of such suppliers, from whom the alleged

CO-OPERATION METALS,PUNE vs. ITO WARD 6(3), PUNE

In the result, the appeals filed by the assessee are partly allowed and the appeals filed by the Revenue are dismissed

ITA 2320/PUN/2024[2011-12]Status: DisposedITAT Pune21 Apr 2026AY 2011-12

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Madhan Thirmanpalli, Addl. CIT
Section 131Section 133ASection 143(1)Section 143(2)Section 143(3)Section 147

hawala parties. 5. In appeal the Ld. CIT(A) / NFAC directed the Assessing Officer to restrict the addition to 18% of the said bogus purchases by observing as under: ITA Nos.2319 & 2271/PUN/2024 & Ors 6. Aggrieved with part relief granted by the Ld. CIT(A) / NFAC, the assessee as well ... deciding the GPM (gross profit margin) of 18% on alleged Hawala Purchases solely relying upon the information received from sales tax department indicating alleged bogus purchases made. The I-T authorities ought to have proceeded further for cross-examination of the suppliers/further probing of such suppliers, from whom the alleged

CO-OPERATION METALS,PUNE vs. ITO WARD 6(3), PUNE

In the result, the appeals filed by the assessee are partly allowed and the appeals filed by the Revenue are dismissed

ITA 2319/PUN/2024[2009-10]Status: DisposedITAT Pune21 Apr 2026AY 2009-10

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Madhan Thirmanpalli, Addl. CIT
Section 131Section 133ASection 143(1)Section 143(2)Section 143(3)Section 147

hawala parties. 5. In appeal the Ld. CIT(A) / NFAC directed the Assessing Officer to restrict the addition to 18% of the said bogus purchases by observing as under: ITA Nos.2319 & 2271/PUN/2024 & Ors 6. Aggrieved with part relief granted by the Ld. CIT(A) / NFAC, the assessee as well ... deciding the GPM (gross profit margin) of 18% on alleged Hawala Purchases solely relying upon the information received from sales tax department indicating alleged bogus purchases made. The I-T authorities ought to have proceeded further for cross-examination of the suppliers/further probing of such suppliers, from whom the alleged

INCOME TAX OFFICER, PUNE vs. COOPERATION METALS, PUNE

In the result, the appeals filed by the assessee are partly allowed and the appeals filed by the Revenue are dismissed

ITA 2263/PUN/2024[2011-12]Status: DisposedITAT Pune21 Apr 2026AY 2011-12

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Madhan Thirmanpalli, Addl. CIT
Section 131Section 133ASection 143(1)Section 143(2)Section 143(3)Section 147

hawala parties. 5. In appeal the Ld. CIT(A) / NFAC directed the Assessing Officer to restrict the addition to 18% of the said bogus purchases by observing as under: ITA Nos.2319 & 2271/PUN/2024 & Ors 6. Aggrieved with part relief granted by the Ld. CIT(A) / NFAC, the assessee as well ... deciding the GPM (gross profit margin) of 18% on alleged Hawala Purchases solely relying upon the information received from sales tax department indicating alleged bogus purchases made. The I-T authorities ought to have proceeded further for cross-examination of the suppliers/further probing of such suppliers, from whom the alleged

INCOME TAX OFFICER, PUNE vs. COOPERATION METALS, PUNE

In the result, the appeals filed by the assessee are partly allowed and the appeals filed by the Revenue are dismissed

ITA 2262/PUN/2024[2009-10]Status: DisposedITAT Pune21 Apr 2026AY 2009-10

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Madhan Thirmanpalli, Addl. CIT
Section 131Section 133ASection 143(1)Section 143(2)Section 143(3)Section 147

hawala parties. 5. In appeal the Ld. CIT(A) / NFAC directed the Assessing Officer to restrict the addition to 18% of the said bogus purchases by observing as under: ITA Nos.2319 & 2271/PUN/2024 & Ors 6. Aggrieved with part relief granted by the Ld. CIT(A) / NFAC, the assessee as well ... deciding the GPM (gross profit margin) of 18% on alleged Hawala Purchases solely relying upon the information received from sales tax department indicating alleged bogus purchases made. The I-T authorities ought to have proceeded further for cross-examination of the suppliers/further probing of such suppliers, from whom the alleged

DCIT-13.3.2, MUMBAI vs. REMI SALES AND ENGINEERING LIMITED , MUMBAI

In the result, the appeal of the Revenue stands dismissed

ITA 9259/MUM/2025[2011-12]Status: DisposedITAT Mumbai21 Apr 2026AY 2011-12
Section 115JSection 143(1)Section 143(3)Section 147Section 69C

Revenue lies in the action of the learned CIT(A) in restricting the addition made under section 69C on account of alleged bogus purchases to 15% of the impugned purchases amounting to Rs.1,23,750/-, thereby sustaining an addition of only Rs.18,562/- as against 100% disallowance made

ITO 19.3.1, MUMBAI, MUMBAI vs. SOURABH NAVALKISHOR GARG, MUMBAI

In the result the appeals filed by the revenue for both years under consideration stands dismissed

ITA 5804/MUM/2025[2010-11]Status: DisposedITAT Mumbai21 Apr 2026AY 2010-11

Bench: Smt. Beena Pillai () & Shri Jagadish ()

Section 148Section 37Section 68Section 74

issued u/s. 148 and order under appeal passed by ACIT, Circle 2, Ajmer is without jurisdiction, without appreciating the facts that assessee has claimed bogus purchases of Rs.5,04,94,046/- from M/s. Kotsons Impex Pvt Ltd., M/s. Shree Jalaram Enterprises and M/s. Excellent Diamonds Pvt Ltd., a Hawala Bogus ... facts and circumstances of the case and in law, the Ld. CIT(A) has erred in deleting the addition on account of bogus purchases of Rs.5,04,94,046/- made from M/s. Kotsons Impex Pvt Ltd., M/s. Shree Jalaram Enterprises and M/s. Excellent Diamonds Pvt Ltd., a Hawala Bogus Entry

INCOME TAX OFFICER, PUNE vs. COOPERATION METALS, PUNE

In the result, the appeals filed by the assessee are partly allowed and the appeals filed by the Revenue are dismissed

ITA 2271/PUN/2024[2010-11]Status: DisposedITAT Pune21 Apr 2026AY 2010-11

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Madhan Thirmanpalli, Addl. CIT
Section 131Section 133ASection 143(1)Section 143(2)Section 143(3)Section 147

hawala parties. 5. In appeal the Ld. CIT(A) / NFAC directed the Assessing Officer to restrict the addition to 18% of the said bogus purchases by observing as under: ITA Nos.2319 & 2271/PUN/2024 & Ors 6. Aggrieved with part relief granted by the Ld. CIT(A) / NFAC, the assessee as well ... deciding the GPM (gross profit margin) of 18% on alleged Hawala Purchases solely relying upon the information received from sales tax department indicating alleged bogus purchases made. The I-T authorities ought to have proceeded further for cross-examination of the suppliers/further probing of such suppliers, from whom the alleged

ITO 19.3.1, MUMBAI vs. SOURABH NAVALKISHOR GARG, MUMBAI

In the result the appeals filed by the revenue for both years under consideration stands dismissed

ITA 5803/MUM/2025[2009-10]Status: DisposedITAT Mumbai21 Apr 2026AY 2009-10

Bench: Smt. Beena Pillai () & Shri Jagadish ()

Section 148Section 37Section 68Section 74

issued u/s. 148 and order under appeal passed by ACIT, Circle 2, Ajmer is without jurisdiction, without appreciating the facts that assessee has claimed bogus purchases of Rs.5,04,94,046/- from M/s. Kotsons Impex Pvt Ltd., M/s. Shree Jalaram Enterprises and M/s. Excellent Diamonds Pvt Ltd., a Hawala Bogus ... facts and circumstances of the case and in law, the Ld. CIT(A) has erred in deleting the addition on account of bogus purchases of Rs.5,04,94,046/- made from M/s. Kotsons Impex Pvt Ltd., M/s. Shree Jalaram Enterprises and M/s. Excellent Diamonds Pvt Ltd., a Hawala Bogus Entry

HIRA LAL GUPTA,KOLKATA vs. I.T.O., WARD - 52(1), KOLKATA

In the result, the appeal filed by the assessee is partly allowed

ITA 2077/KOL/2025[2018-2019]Status: DisposedITAT Kolkata17 Apr 2026AY 2018-2019

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 139(1)Section 142(1)Section 148Section 250

circumstances of the case the Ld. Assessing Officer has eared in disallowing a portion of Purchase of Rs.31,38,175/- on account of bogus purchases without proper verification. 2. That the Ld. Assessing Officer has failed to consider the fact that by disallowing the purchases, the gross profit rate ... Machinery and M/s. Dev Traders was Sh. Bittu Mondal and purchases made from Sh. Bittu Mondal were for ₹72,99,685/- only, the total bogus purchases were worked out at ₹1,25,52,701/-. The assessee had requested in response to the show cause notice citing various High Courts’ decisions

M/S. PERQ ADVERTISINGS PVT LTD ,MUMBAI vs. DCIT, CIRCLE 2(3)(1), MUMBAI

ITA 76/MUM/2026[2010-11]Status: DisposedITAT Mumbai17 Apr 2026AY 2010-11
For Appellant: Shri Sameer G. DalalFor Respondent: Shri Virabhadra S. Mahajan
Section 133(6)Section 143(3)Section 147Section 271(1)(c)

read with Section 147 of the Act addition of INR.43,00,258/- was made in the hands of the Assessee in respect of alleged bogus purchases since the Assessee had failed to furnish corroborative documents. The profit element embedded alleged bogus purchases was computed at 14.60% of the alleged bogus ... INR.2,94,53,819/-. In the quantum appeal, the Learned CIT(A) vide Order dated 19/03/2019 reduced the addition to 12.5% of alleged bogus purchases. No further appeal was preferred by the appellant against the order of the Learned CIT (A) in quantum proceedings. 6. Thereafter, vide Penalty Order, dated

M/S. PERQ ADVERTISING PVT LTD, MUMBAI vs. DCIT, CIRCLE 2(3)(1), MUMBAI

ITA 75/MUM/2026[2011-12]Status: DisposedITAT Mumbai17 Apr 2026AY 2011-12
For Appellant: Shri Sameer G. DalalFor Respondent: Shri Virabhadra S. Mahajan
Section 133(6)Section 143(3)Section 147Section 271(1)(c)

read with Section 147 of the Act addition of INR.43,00,258/- was made in the hands of the Assessee in respect of alleged bogus purchases since the Assessee had failed to furnish corroborative documents. The profit element embedded alleged bogus purchases was computed at 14.60% of the alleged bogus ... INR.2,94,53,819/-. In the quantum appeal, the Learned CIT(A) vide Order dated 19/03/2019 reduced the addition to 12.5% of alleged bogus purchases. No further appeal was preferred by the appellant against the order of the Learned CIT (A) in quantum proceedings. 6. Thereafter, vide Penalty Order, dated

DCIT, CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. BALMUKUND CONCAST PRIVATE LIMITED, PATNA

In the result, the appeals of the Revenue are dismissed and the appeal of the assessee is allowed

ITA 1893/KOL/2025[2023-24]Status: DisposedITAT Kolkata15 Apr 2026AY 2023-24

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm Balmukund Concast Pvt. Ltd. Dcit, Cc 4(3) 108 Kalyani Complex, Exhibition Aaykar Bhawan, Kolkata-700069 Vs. Road, Patna-800001, Bihar West Bengal (Respondent) (Appellant) Pan No. Aaacb9503G

For Appellant: Shri Manish Rastogi, ARFor Respondent: Shri Dheeraj, DR
Section 115JSection 132Section 143(1)

based on surmises and conjectures. Based on the above discussion it is decided thatthe addition made of Rs.12,45,885/-. on account of bogus purchases @ 4% on the turnoverof Rs.3,11,47,131/- is to be deleted. Hence, the AO is directed to delete the addition ofRs.12,45,885/-. Therefore ... purchases were made from parties different than the parties entered in the books of account. On this account, AO has made addition for bogus purchases @ 25% of the purchases. This can only be said to be surmise. It is settled law that no addition is permissible on the basis

DCIT, CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. BALMUKUND CONCAST PRIVATE LIMITED, PATNA

In the result, the appeals of the Revenue are dismissed and the appeal of the assessee is allowed

ITA 1892/KOL/2025[2019-20]Status: DisposedITAT Kolkata15 Apr 2026AY 2019-20

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm Balmukund Concast Pvt. Ltd. Dcit, Cc 4(3) 108 Kalyani Complex, Exhibition Aaykar Bhawan, Kolkata-700069 Vs. Road, Patna-800001, Bihar West Bengal (Respondent) (Appellant) Pan No. Aaacb9503G

For Appellant: Shri Manish Rastogi, ARFor Respondent: Shri Dheeraj, DR
Section 115JSection 132Section 143(1)

based on surmises and conjectures. Based on the above discussion it is decided thatthe addition made of Rs.12,45,885/-. on account of bogus purchases @ 4% on the turnoverof Rs.3,11,47,131/- is to be deleted. Hence, the AO is directed to delete the addition ofRs.12,45,885/-. Therefore ... purchases were made from parties different than the parties entered in the books of account. On this account, AO has made addition for bogus purchases @ 25% of the purchases. This can only be said to be surmise. It is settled law that no addition is permissible on the basis

BALMUKUND CONCAST PVT. LTD.,,PATNA vs. DCIT, CENTRAL CIRCLE 4(3),, KOLKATA

In the result, the appeals of the Revenue are dismissed and the appeal of the assessee is allowed

ITA 1380/KOL/2025[2023-2024]Status: DisposedITAT Kolkata15 Apr 2026AY 2023-2024

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm Balmukund Concast Pvt. Ltd. Dcit, Cc 4(3) 108 Kalyani Complex, Exhibition Aaykar Bhawan, Kolkata-700069 Vs. Road, Patna-800001, Bihar West Bengal (Respondent) (Appellant) Pan No. Aaacb9503G

For Appellant: Shri Manish Rastogi, ARFor Respondent: Shri Dheeraj, DR
Section 115JSection 132Section 143(1)

based on surmises and conjectures. Based on the above discussion it is decided thatthe addition made of Rs.12,45,885/-. on account of bogus purchases @ 4% on the turnoverof Rs.3,11,47,131/- is to be deleted. Hence, the AO is directed to delete the addition ofRs.12,45,885/-. Therefore ... purchases were made from parties different than the parties entered in the books of account. On this account, AO has made addition for bogus purchases @ 25% of the purchases. This can only be said to be surmise. It is settled law that no addition is permissible on the basis

VINOD KUMAR,NEW DELHI vs. DCIT, CIRCLE-1(1)(1), MEERUT

ITA 1311/DEL/2026[2018-19]Status: DisposedITAT Delhi15 Apr 2026AY 2018-19

Bench: Shri Satbeer Singh Godaraassessment Year: 2018-19 Vs. Deputy Sh. Vinod Kumar Commissioner C/O M/S Raj Kumar & Income Tax Circle-1(1)(1) Associates Aayakar Bldgi, Meerut, L-7A (Lgf), South Extension Uttar Pradesh Part-Ii New Delhi- 110049

Section 147

appellate’ discussions have made it clear as to in what manner the assessee’s payer; M/s Swastik Traders, had been engaged in providing such bogus purchases entries of agricultural produce. That being the case, I hereby uphold the impugned addition made in the assessee’s case in very terms

ACIT CENTRAL CIRCLE-13, NEW DELHI vs. MINDA CAPITAL PVT LTD, NEW DELHI

In the result, the appeal of the Revenue is dismissed

ITA 7919/DEL/2019[2011-12]Status: DisposedITAT Delhi15 Apr 2026AY 2011-12

Bench: Shri Mahavir Singh & Before Shri Mahavir Singh & Before Shri Before Shri Mahavir Singh & Mahavir Singh & Shri Shri Manish Agarwal Shri Shri Manish Agarwal Manish Agarwalmanish Agarwal

For Appellant: Shri Salil Aggarwal, Senior Advocate with Shri Madhur Aggarwal, ShriFor Respondent: Ms. Amisha S. Gupt, Senior DR
Section 142(1)Section 143(3)Section 147Section 153CSection 68

appeal of the Revenue is as regards the order of learned CIT(A) deleting the addition of `1,93,20,640/- on account of bogus purchases and fabricated bills of purchases and sales. For this, Revenue has raised following ground No.2:- “2. Whether the Ld. CIT(A) is correct ... spare parts of automobile. The Assessing Officer made addition only on one premise that the assessee has carried out trading in garments and made bogus purchases of trading in garments, Learned CIT(A) deleted the addition vide paragraph 5 (iv) and (v) as under:- “5. (iv) The addition of Rs.1

SUNRISE STRUCTURALS & ENGINEERING PVT LTD,NAGPUR vs. ASSISTANT/ DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-4 NAGPUR, NAGPUR

In the result, appeal filed by the assessee stands allowed

ITA 167/NAG/2025[2019-20]Status: DisposedITAT Nagpur10 Apr 2026AY 2019-20

Bench: Shri Pawan Singh & Shri Khettra Mohan Roysunrise Structural & Acit/Dcit, Circle-4, Engineering P. Ltd., A10, Vs Nagpur Hingna Midc, Nagpur (Urban), Nagpur-440016 Pan : Aaccs 3220 M Assessee Respondent Assessee By : Shri K.P. Dewani, Advocate Revenue By : Shri Surjit Kumar Saha, Sr. Dr Date Of Hearing : 25.02.2026 Date Of Pronouncement : 10.04.2026 O R D E R

For Appellant: Shri K.P. Dewani, AdvocateFor Respondent: Shri Surjit Kumar Saha, Sr. DR
Section 115BSection 143(1)Section 147Section 148Section 148ASection 234BSection 250Section 69C

processed u/s 143(1) of the Act. Later, on the information received from Insight portal and Directorate General of GST Intelligence (DGGI) regarding bogus purchases from M/s. Dadhichi Iron & Steel Pvt. Ltd., proceedings u/s 148A were initiated and notice u/s 148 was issued. In response, assessee filed it return declaring ... extract of the judgement of Hon’ble Chhattisgarh High Court in the case of M/s Dadhichi Iron & Steel Pvt. Ltd. concluded that there is bogus purchase from the said concern and assessee has received accommodation entry. The aforesaid information was not confronted/put to notice to assessee before drawing adverse view

ITO WARD-14(3)(1), MUMBAI, MUMBAI vs. VINIPUL INORGANICS PRIVATE LIMITED, MUMBAI

In the result, the appeal by the Revenue is dismissed

ITA 7970/MUM/2025[2011-12]Status: DisposedITAT Mumbai10 Apr 2026AY 2011-12

Bench: Shri Sandeep Singh Karhailshri Bijayananda Pruseth

For Appellant: Shri Rahul HakaniFor Respondent: Shri Anurag Tripathi, SR. DR
Section 143(3)Section 147Section 148Section 250Section 254Section 271(1)(c)Section 69C

Pursuant to information received from the DGIT (Investigation) Wing, Mumbai, that the assessee is a beneficiary of accommodation entry transactions of bogus purchases, notices under section 148 of the Act were issued, and proceedings under section 147 of the Act were initiated. Vide assessment order passed under section ... Tribunal, in a further appeal by the assessee in quantum proceedings, vide order dated 18.01.2024, passed in disallowance to 12.5% of the bogus purchases. 5. In the meanwhile, penalty proceedings under section 271(1)(c) of the Act were initiated separately by the AO for the year under consideration

OMNITEL TECHNOLOGIES PRIVATE LIMITED,GURUGRAM HARYANA vs. ITO WARD - 3(1) GURGAON, GURGAON HARYANA

In the result, appeal of the assessee is allowed

ITA 353/DEL/2025[2014-15]Status: DisposedITAT Delhi10 Apr 2026AY 2014-15

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2014-15] Omnitel Technologies Vs Ito Pvt.Ltd., B-220, Florence Ward-3(1) Marvel, Sushant Lok-Iii, Gurgaon Chakkarpur B.O., Sikanderpur Ghost (68), Gurgaon, Haryana-122002 Pan-Aafca2421B Appellant Respondent [Assessment Year : 2016-17] Omnitel Technologies Pvt. Vs Additional/Joint/ Ltd., B-220, Florence Deputy/Assistant Marvel, Sushant Lok-Iii, Commissioner Of Sector-57, Gurgaon, Income Tax, National Haryana-122002 Faceless Assessment Pan-Aafca2421B Centre, Delhi Appellant Respondent Appellant By Shri Sanjay Kumar, Adv. Respondent By Ms. Indu Bala Saini, Sr. Dr Date Of Hearing 21.01.2026 Date Of Pronouncement 10.04.2026 Order Per Manish Agarwal, Am : The Captioned Appeals Are Filed By Assessee Against The Separate Orders Dated 10.12.2024 & 06.11.2024 Of Ld. Commissioner Of Income Tax (A), National Faceless Appeal Centre (“Nfac”), Delhi [“Ld.

Section 115BSection 147Section 250Section 69C

Nos.353 & 73/Del/2025 accepted the contention of the assessee and made the addition of INR 1,43,20,000/- towards bogus purchases and invoked provision of section 115BBE of the Act. 5. Against such order, assessee preferred an appeal before Ld. CIT(A) who vide impugned order dated 10.12.2024, partly allowed ... memo. Grounds of appeal Nos. 1 to 4 raised by the assessee are with 7. respect to confirmation of addition made on account of bogus purchases therefore, they have been taken together for consideration. 8. Heard the contentions of both the parties at length and perused the material available