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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

Mahavir Transmissin Ltd, New Delhi vs. DCIT, Central Circle-25, New Delhi

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

ITA 2635/DEL/2022[2020-21]Status: DisposedITAT Delhi02 Jul 2024AY 2020-21

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

For Appellant: Sh. Ved Jain, Adv. &For Respondent: Subhra J. Chakraborty, CIT-DR
Section 153Section 153ASection 153D

Revenue for all the three years, the only issue is regarding the deletion of addition by the ld. CIT(A) on account of alleged bogus purchases whereby ld. CIT(A) has restricted the addition to the gross profit rate. 4. In addition to the above-mentioned common issue in four ... Rs.2,35,48,600/- on account of difference between purchase price of land acquired by assessee and stamp duty value of such land. Alleged Bogus purchases: 5. Brief facts of the case are that the assessee company is engaged in the business of manufacturing and supply of aluminum conductors

Mahavir Transmission Ltd, New Delhi vs. DCIT, Central Circle-25, New Delhi

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

ITA 2634/DEL/2022[2019-20]Status: DisposedITAT Delhi02 Jul 2024AY 2019-20

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

For Appellant: Sh. Ved Jain, Adv. &For Respondent: Subhra J. Chakraborty, CIT-DR
Section 153Section 153ASection 153D

Revenue for all the three years, the only issue is regarding the deletion of addition by the ld. CIT(A) on account of alleged bogus purchases whereby ld. CIT(A) has restricted the addition to the gross profit rate. 4. In addition to the above-mentioned common issue in four ... Rs.2,35,48,600/- on account of difference between purchase price of land acquired by assessee and stamp duty value of such land. Alleged Bogus purchases: 5. Brief facts of the case are that the assessee company is engaged in the business of manufacturing and supply of aluminum conductors

Mahavir Transmission Ltd, New Delhi vs. DCIT, Central Corcle-25, New Delhi

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

ITA 2633/DEL/2022[2018-19]Status: DisposedITAT Delhi02 Jul 2024AY 2018-19

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

For Appellant: Sh. Ved Jain, Adv. &For Respondent: Subhra J. Chakraborty, CIT-DR
Section 153Section 153ASection 153D

Revenue for all the three years, the only issue is regarding the deletion of addition by the ld. CIT(A) on account of alleged bogus purchases whereby ld. CIT(A) has restricted the addition to the gross profit rate. 4. In addition to the above-mentioned common issue in four ... Rs.2,35,48,600/- on account of difference between purchase price of land acquired by assessee and stamp duty value of such land. Alleged Bogus purchases: 5. Brief facts of the case are that the assessee company is engaged in the business of manufacturing and supply of aluminum conductors

Mahavir Transmission Ltd, New Delhi vs. DCIT, Central Circle-25, New Delhi

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

ITA 2632/DEL/2022[2017-18]Status: DisposedITAT Delhi02 Jul 2024AY 2017-18

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

For Appellant: Sh. Ved Jain, Adv. &For Respondent: Subhra J. Chakraborty, CIT-DR
Section 153Section 153ASection 153D

Revenue for all the three years, the only issue is regarding the deletion of addition by the ld. CIT(A) on account of alleged bogus purchases whereby ld. CIT(A) has restricted the addition to the gross profit rate. 4. In addition to the above-mentioned common issue in four ... Rs.2,35,48,600/- on account of difference between purchase price of land acquired by assessee and stamp duty value of such land. Alleged Bogus purchases: 5. Brief facts of the case are that the assessee company is engaged in the business of manufacturing and supply of aluminum conductors

M/S Bcl Industries Ltd., Bathinda vs. DCIT, CC-I, Ludhiana

In the result, both appeals of the assessee are

ITA 409/CHANDI/2023[2011-12]Status: DisposedITAT Chandigarh01 Jul 2024AY 2011-12

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Smt. Amanpreet Kaur, Sr.DR
Section 148Section 68Section 69C

formation of belief that income assessable to tax has escaped assessment are based on two counts. One, the assessee has made bogus purchases and the second, that the purchases are not verifiable as the assessee has not filed the return of income. Thus the formation of belief is based ... these two factual aspects that the assessee has made bogus purchases which are not verifiable as assessee has not filed the return of income. The reason for non verifiableness of the purchases made by the assessee due to non filing of the return of income as stated

Kissan Fats Ltd., Bathinda vs. DCIT, CC-1, Ludhiana

In the result, both appeals of the assessee are

ITA 407/CHANDI/2023[2011-12]Status: DisposedITAT Chandigarh01 Jul 2024AY 2011-12

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Smt. Amanpreet Kaur, Sr.DR
Section 148Section 68Section 69C

formation of belief that income assessable to tax has escaped assessment are based on two counts. One, the assessee has made bogus purchases and the second, that the purchases are not verifiable as the assessee has not filed the return of income. Thus the formation of belief is based ... these two factual aspects that the assessee has made bogus purchases which are not verifiable as assessee has not filed the return of income. The reason for non verifiableness of the purchases made by the assessee due to non filing of the return of income as stated

M/S. Gordhansingh S Rajpurohit, Navi Mumbai vs. The Income Tax Officer, Ward-5, Panvel

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

ITA 512/PUN/2024[2009-10]Status: DisposedITAT Pune01 Jul 2024AY 2009-10

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

For Appellant: N O N EFor Respondent: Shri Ramnath P. Murkunde
Section 133(6)Section 143(3)Section 145Section 68

above since there is no business, the assessee does neither had any staff nor any tax consultant. GOA No.2:- 15% Addition on Account of bogus purchases of Rs.3,08,99,339/-  The Ld.CIT(A) not justified in confirming the adhoc 15% disallowances on account of purchases affected from suspicious hawala ... trader. In view of these facts, this is not a case where the entire cash has been siphoned off by debiting the bogus purchases. This is a case, where at the most, the purchase amount would have been inflated. Moreover the impugned addition of Rs.3,08,99,339/- would result

ITO(It)-3(1)(1), Mumbai vs. Mohit Jain, Mumbai

In the result, the appeal filed by the revenue is dismissed

ITA 991/MUM/2024[2010-11]Status: DisposedITAT Mumbai01 Jul 2024AY 2010-11

Bench: Shri Pavan Kumar Gadale & Shri Ratnesh Nandan Sahaymohit Jain, Ito(It)-3(1)(1), Vs. 24,Cci Chambers, Room No.1630, D.N Vachha Road, Air India Building, Mumbai-400020. Nariman Point, Mumbai-400021. Pan/Gir No. Afapj6477R (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 133(6)

facts and in circumstances of the case and in the law, the Ld.CIT(A) was erred in restricting addition/disallowance made on account of bogus purchases to 1.97% of gross profit instead of upholding AO's action of disallowing entire bogus purchases? 2 Mohit jain, Mumbai 2. Whether on the facts ... dated 28.03.2013. Subsequently, the Assessing Officer (AO) has received the information from DGIT (Inv), Mumbai that the assessee was engaged in bogus purchase transactions as per Sales Tax Department of Maharashtra and the assessee is a beneficiary. The Assessing Officer (AO) has reason to believe that the income has escaped

Monika Mukul Gupta, Mumbai vs. Income Tax Officer-31(2)(3), Mumbai

In the result, appeal of the assessee is allowed

ITA 726/MUM/2024[2009-10]Status: DisposedITAT Mumbai28 Jun 2024AY 2009-10

Bench: SHRI AMIT SHUKLA, JUDICIAL MEMBER & SHRI.RATNESH NANDAN SAHAY (Accountant Member)

Section 143(3)Section 148

notice u/s.148 should have been issued in the name of Late Shri Ramkumar Puranchand Gupta to his legal heir, because the transaction of alleged bogus purchases of Rs. 12,48,130/- from Arun Paper and Iron Traders was made during the period of Late Shri Ramkumar Puranchand Gupta. This fact ... Gupta itself was beyond jurisdiction and is bad in law. Not only that, making the addition of Rs.12,48,130/- on account of alleged bogus purchases made by the earlier proprietor Late Shri Ramkumar Puranchand Gupta cannot be added in the hands of the successor proprietor

Computerised Numerical Control India (P) Ltd, Mumbai vs. ACIT, Circle- 4(1)(1), Mumbai

In the result, appeal of the assessee is treated as allowed for statistical purpose

ITA 1736/MUM/2024[2015-16]Status: DisposedITAT Mumbai28 Jun 2024AY 2015-16

Bench: Shri B.R. Baskaran & Shri Sunil Kumar Singhassessment Year :2015-16

For Appellant: NoneFor Respondent: Shri H.M.Bhatt

manufacture of industrial engineering goods. The assessment was completed by the Assessing Officer by disallowing a sum of Rs.2.46 crores relating to alleged bogus purchases. The Ld.CIT(A) also confirmed the said addition and hence, the assessee has filed this appeal before the Tribunal. As noticed earlier, the Ld.CIT

Rajnish Srikishan Gupta, Mumbai vs. ITO-20(3)(1), Mumbai

The appeal of the assessee is allowed to that extent as per ground number 2 of the

ITA 1124/MUM/2024[2011-12]Status: DisposedITAT Mumbai28 Jun 2024AY 2011-12

Bench: Shri Prashant Maharishi (Am)

Section 133Section 143Section 147Section 148Section 69C

dated 30/11/2017 were dismissed. 2. In both the appeals the issue is with respect to the addition on account of bogus purchase of ₹ 2,430,272 and 35,67,407/- paid by the learned assessing officer under section 69C of the act whereas the learned CIT A has dismissed ... appeal upholding the addition of hundred percent of such bogus purchases. 3. The brief facts for assessment year 2010 – 11 shows that assessee filed his return of income on 23/6/2010 declaring a total income of 593,230/-. As the information was received that assessee has obtained the bogus bills from

Rajnish Srikishan Gupta, Mumbai vs. ITO-20(3)(1), Mumbai

The appeal of the assessee is allowed to that extent as per ground number 2 of the appeal for both the years

ITA 1123/MUM/2024[2010-11]Status: DisposedITAT Mumbai28 Jun 2024AY 2010-11

Bench: Shri Prashant Maharishi (Am) I.T.A. No. 1123/Mum/2024 (A.Y. 2010-11) I.T.A. No. 1124/Mum/2024 (A.Y. 2011-12) Rajnish Srikishan Gupta Vs. Ito 20(3)(1) A-3, Brindavan Housing Priamal Chamber Society Ltd., Lala 4Th Floor Jamnadas Gupta Marg Lalbaug Deonar, Mumbai-400088. Parel Mumbai-40 0012. Pan : Aabpg2210M (Appellant) (Respondent) Assessee By Shri Kirit Sanghvi Department By Shri R.R. Makwana Date Of Hearing 11.06.2024 Date Of Pronouncement 28.06.2024 O R D E R Per Prashant Maharishi

Section 133Section 143Section 147Section 148Section 69C

dated 30/11/2017 were dismissed. 2. In both the appeals the issue is with respect to the addition on account of bogus purchase of ₹ 2,430,272 and 35,67,407/– paid by the learned assessing officer under section 69C of the act whereas the learned CIT – A has dismissed ... appeal upholding the addition of hundred percent of such bogus purchases. 2 ITA number 1123" and 24/M/2024 Assessment year 2010 – 11 and 2011 – 12 Rajneesh S Gupta V Ito ward 20(3)(1) Mumbai 3. The brief facts for assessment year 2010 – 11 shows that assessee filed his return

Pavan Steel India, Mumbai vs. ITO 19(2)(5), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 1002/MUM/2024[2012-2013]Status: DisposedITAT Mumbai28 Jun 2024AY 2012-2013

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI. RATNESH NANDAN SAHAY (Accountant Member)

Section 133(6)Section 143(1)Section 143(3)Section 147Section 148

Steel India therefore, we hold that 5% GP rate should be applied over and above the GP disclosed by the assessee on the alleged bogus purchases of Rs. 20,29,840/-. 7. In the result, appeal of the assessee is partly allowed. Order pronounced on 28th June, 2024. (RATNESH NANDAN

ACIT, Cir.20(1), Mumbai vs. Rajendra Kumar Mansukhlal Shah, Matunga, Mumbai

In the result, the appeal filed by the Revenue Department stands dismissed

ITA 3722/MUM/2023[2010-11]Status: DisposedITAT Mumbai28 Jun 2024AY 2010-11

Bench: Shri Narender Kumar Choudhry & Shri Girish Agrawalassessment Year: 2010-11

For Appellant: Shri Manish Goyal, A.RFor Respondent: Smt Mahita Nair, SR. D.R
Section 133(6)Section 143(1)Section 250

further observed that Sales Tax Department of the Maharashtra Government has investigated the affairs of the dealers, who have been issuing the bogus purchase bills, as a result thereof publicly displayed a list of nearly 2000 persons/dealers on the website of the Sales Tax Department, who have admitted to issuing ... bogus purchase bills. Therefore, by issuing a show cause notice dated 26.02.2013 the Assessee was given an opportunity for establishing the 3 Shri Rajendra Kumar Mansukhlal Shah genuineness of the parties and the purchases made from them, with supporting evidences and also to produce the parties before the AO along

M/S. Gunny Dealers Ltd., Kolkata vs. ITO, Tech-1, Kolkata

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

ITA 1373/KOL/2023[2012-13]Status: DisposedITAT Kolkata27 Jun 2024AY 2012-13

Bench: Shri Sanjay Garg & Shri Rakesh Mishrai.T.A. No.1373/Kol/2023 Assessment Years: 2012-13 M/S Gunny Dealers Ltd…………………....................…...……………....Appellant C/O Subash Agarwal & Associates, Advocates Siddha Gibson, 1, Gibson Lane, Suite 213, 2Nd Floor, Kolkata – 700069. [Pan: Aabcg0019R] Vs. Ito, Tech-1, Kolkata………….……………............................…..…..... Respondent Appearances By: Shri Siddharth Agarwal, Advocate, Appeared On Behalf Of The Assessee. Shri P. P. Barman, Addl. Cit-Sr. Dr, Appeared On Behalf Of The Revenue. Date Of Concluding The Hearing : April 30, 2024 Date Of Pronouncing The Order : June 27, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 28.11.2023 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Assessee In This Appeal Has Taken The Following Grounds Of Appeal: “1. For That On The Facts & In The Circumstances Of The Case, The Ld. Cit(A) Ought To Haye Considered That The Order U/S 143(3) Was Passed By An Authority Who Lacks Jurisdiction Over The Appellant & As Such, The Said Order Is Bad In Law & Is Liable To Be Quashed. 2. For That On The Facts & In The Circumstances Of The Case, The Ld. Cit(A) Was Not Justified In Confirming The Disallowance Of

Section 131Section 143(3)Section 250Section 36(1)(va)Section 40A(3)

that on the facts and in the circumstances of the case, the Ld. CIT(A) was not justified in confirming the disallowance of alleged bogus purchase to the extent of Rs. 84,789/- being 8% of the total purchase of Rs. 10,59,861/- made from Smt. Anima ... case, the Ld. CIT(A) ought to have deleted the entire disallowance of Rs.10,59,861/- made by the A.O. on account of alleged bogus purchases made from Smt. Anima Roy. 5. For that on the facts and in the circumstances of the case

Manoharlal Kanayalal Takhtani, Bandra vs. Deputy Commissioner of Income Tax, Circle 22(1) Mumbai, Mumbai

In the result, the appeal is partly allowed

ITA 966/MUM/2024[2012-13]Status: DisposedITAT Mumbai27 Jun 2024AY 2012-13

Bench: Shri Amit Shukla & Ratnesh Nandan Sahayassessment Year: 2012-13 M/S. Manoharlal Deputy Commissioner Of Kanayalal Takhtani Income Tax, Circle 22(1) 702, Dheerajdhan, Pirmal Chambers, Vs. St. Alexious Road, Dr. S. S. Rao Marg, Bandra (West) S.O., Parel- 400012. Mumbai- 400052. Pan:Aabpt2851P (Appellant) (Respondent) Present For : : Ms. Manisha Ghind, A.R. Assessee By Revenue By : Smt. Kakoli Uttam Ghosh, D.R.

For Appellant: 1. “The Hon'ble CIT (Appeal) has erred in passing anFor Respondent: Smt. Kakoli Uttam Ghosh, D.R
Section 143(3)Section 147Section 148Section 250Section 69C

failed to appreciate that even on merits the additions made by the Ld. Assessing Officer, being 100% of the alleged bogus purchase was not called for and also the fact that in appellants own case for the A.Y. 2009-10 the addition/disallowance @ 5% of the alleged bogus purchase ... said Jain Group. The Ld. AO, therefore, added a sum of Rs.8,26,000/- u/s. 69C of the Income Tax Act treating this as bogus purchases as the assessee could not establish the genuineness of this purchases. 4 M/s. Manoharlal Kanayalal Takhtani 4. Aggrieved by the order

Galaxy Gems, Mumbai vs. Ward 19(1)(1), Mumbai

ITA 830/MUM/2024[2012-13]Status: DisposedITAT Mumbai27 Jun 2024AY 2012-13

Bench: Shri Amit Shukla & Shri Ratnesh Nandan Sahay

For Appellant: 1. "On facts and in law, the Learned Commissioner
Section 138Section 147Section 250Section 69C

thereafter, added a sum of Rs.28,00,000/- u/s. 69C of the Income Tax Act holding that this purchase was bogus purchase and there is no actual delivery of goods only the accommodation entries were taken by the assessee. 5. Aggrieved by the order of the Ld. AO, the assessee ... appeal of the assessee on the ground that the appellant could not establish the genuineness of the transaction and the entire purchase was a bogus purchase. Aggrieved by the order of the Ld. CIT(A), this appeal has been filed before us. During the appellate proceedings before us, the appellant

Assistant Commissioner of Income Tax-4(2)(1), Mumbai vs. Gemsons Precision Engineering Pvt Ltd, Mumbai

In the result, appeal filed by the revenue is dismissed in the above terms

ITA 791/MUM/2024[2011-12]Status: DisposedITAT Mumbai27 Jun 2024AY 2011-12

Bench: Smt. Padmavathy S. & Shri. Raj Kumar Chauhanassistant Commissioner Of Income Vs. Gemsons Precision Tax – 4(2)(1) Engineering Pvt. Ltd. Room No. 640, Aayakar Bhavan, M. Plot No. Af-1, Cama Industrial K. Road, New Marine Lines, Estate, Walbhat Road, Mumbai – 400020. Goregaon East, Mumbai Pan: Aabcg0333J 400063. (Appellant) (Respondent)

Section 142(1)Section 143(1)Section 143(2)Section 250Section 69C

Gemsons Precision Engineering Pvt. Ltd.; A.Y. 2011-12 disallowance of Rs. 1,34,21,728/- was deleted and addition was restricted to 12.5% on bogus purchase whereas the Learned Assessing Officer, DCIT, 9(1), Mumbai (hereinafter referred to as the “AO”) has made addition @100%. Aggrieved by the order ... facts and in circumstances of the case and in law, the Ld CIT(A)/ NFAC is right in restricting the addition to 12.5% on bogus purchases where AO made addition @ 100%? c. Whether on the facts and in circumstances of the case and in law, the Ld CIT(A)/NFAC

Income Tax Officer, Mumbai vs. Sureshkumar Hansraj Shah, Mumbai

In the result, the appeal filed by the learned Assessing

ITA 45/MUM/2024[2009-10]Status: DisposedITAT Mumbai27 Jun 2024AY 2009-10

Bench: Shri Prashant Maharishi, Am & Shri Kuldip Singh, Jm Sureshkumar Hansraj Shah Income Tax Officer 2Nd Floor, 2/1, Room No.405, 4Th Floor, Piramal Kikabhai Mansion, Chambers, Vs. Kika Street Gulalwadi Parel, Mumbai-400 012 Mumbai-400 004 (Appellant) (Respondent) Co No. 52/Mum/2024 (Assessment Year: 2009-10) Sureshkumar Hansraj Shah Income Tax Officer 2Nd Floor, 2/1, Room No.405, 4Th Floor, Piramal Kikabhai Mansion, Chambers, Vs. Kika Street Gulalwadi Parel, Mumbai-400 012 Mumbai-400 004 (Appellant) (Respondent) Assessee By : Shri Vimal Punmiya, Ar Revenue By : Shri R.R. Makwana, Dr Date Of Hearing: 05.06.2024 Date Of Pronouncement : 27.06.2024

For Appellant: Shri Vimal Punmiya, ARFor Respondent: Shri R.R. Makwana, DR
Section 133(6)Section 143(1)Section 143(2)Section 143(3)Section 145(3)Section 147Section 148

allowed. Assessee has also filed a cross objection against the same appellate order challenging that the addition to the extent of 12.5% on alleged bogus purchases upheld by the learned CIT (A) is not proper. The learned Assessing Officer has challenged the appellate order holding that the learned ... correct in deleting the addition to the extent of 25% on alleged bogus purchases and instead restricting it to 12.5%. In Cross Objection the assessee has also challenged the reopening of the assessment. 02. The brief facts of the case shows that the assessee is an individual engaged

Hajaram Purohit, Mumbai vs. DCIT 36, Mumbai

In the result, the appeal filed by the assessee is allowed for statistical purpose

ITA 2667/MUM/2015[2010-11]Status: DisposedITAT Mumbai26 Jun 2024AY 2010-11

Bench: Ms Kavitha Rajagopal, Jm & Shri Girish Agrawal, Am Hajaram Purohit Dcit-36 Shop No. 8, Building No. 33, Mumbai Ganesh Bhuvan, 3Rd Khetwadi Lane, Vs. Mumbai-400 004

For Appellant: Shri Viraj MehtaFor Respondent: Smt. Mahita Nair
Section 133Section 143(1)Section 143(3)Section 147Section 148Section 250Section 69A

business premises of the assessee. the learned Assessing Officer (ld. A.O. for short) observed that the assessee is one of the beneficiary of bogus purchases from various parties some of whom are accommodation entry providers alleged to be hawala operators as per the Sales Tax Department. The ld. A.O. then