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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

Mr Proview Real Tech Private Limite Director, Delhi vs. DCIT Central Circle-26, Delhi

Appeal is partly allowed in above terms

ITA 5564/DEL/2025[2013-14]Status: DisposedITAT Delhi05 Feb 2026AY 2013-14

Bench: Sh. Satbeer Singh Godara & Sh. Naveen Chandraita No. 5564/Del/2025 : Asstt. Year: 2013-14 Mr Proview Teal Tech Pvt. Ltd., Vs Dcit, 190, Saini Enclave, Vikas Marg, Central Circle-26, Anand Vihar, Delhi-110092 New Delhi-110055 (Appellant) (Respondent) Pan No. Aagcm4612D Assessee By : None Revenue By : Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing: 05.02.2026 Date Of Pronouncement: 05.02.2026 Order Per Satbeer Singh Godara: This Assessee’S Appeal For Assessment Year 2013-14 Arises Against The Cit(A)-29, New Delhi’S Order Dated 16.08.2025 In Case No. Cit(A), Delhi-29/10257/2012-13, In Proceedings U/S 147 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: NoneFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Section 147Section 68

Kohinoor Foods Ltd.; and (2025) 177 taxmann.com 836 (Delhi-trib.) DCIT Vs. Tirupati Matsup (P.) Ltd. have already decided the instant issue of bogus purchases with divergent views as well. 5. Faced with these peculiar facts, it is deemed appropriate in the larger interest of justice that a lump ... disallowance @ 3 MR Proview Real Tech Pvt. Ltd. 10% of the assessee’s alleged bogus purchases of Rs.75,75,000/-; coming to Rs.7,57,500/-, would be just and proper with a rider that the same shall not be treated as a precedent. Necessary computation shall follow

Navgrahaa Jewels Private Limited, Mumbai vs. Deputy Commissioner, Mumbai

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

ITA 4786/MUM/2025[2013-14]Status: DisposedITAT Mumbai30 Jan 2026AY 2013-14

Bench: Shri Anikesh Banerjee & Shri Makarand Vasant Mahadeokarnavgrahaa Jewels Private Ltd. Vs Deputy Commissioner 7(1)(1), Unit No.341 & 342, Pragati Mumbai Industrial Esrate, N. M. Joshi Aayakar Bhawan, Mumbai-400020 Marg, Lower Parel East, Mumbai-400011 Pan: Aaecn0220G Appellant Respondent Assessee By : Shri Dharan Gandhi, Adv., Ms. Vinita Nara Adv Respondent By : Shri Leyaqat Ali Aafaqui, Sr Dr Date Of Hearing : 28/01/2026 Date Of Pronouncement : 30/01/2026 O R D E R Per: Anikesh Banerjee (Jm): The Instant Appeal Of The Assessee Filed Against The Order Of The Nfac, Delhi [For Brevity ‘The Ld. Cit(A)], Order Passed Under Section 250 Of The Income Tax Act 1961 (For Brevity ‘The Act’) For Assessment Year 2013-14, Date Of Order 11.11.2024. The Impugned Order Emanated From The Order Of The Assessment

For Appellant: Shri Dharan Gandhi, Adv., Ms. Vinita Nara AdvFor Respondent: Shri Leyaqat Ali Aafaqui, SR DR
Section 14Section 147Section 148Section 148ASection 14bSection 250Section 69C

contended that the addition was made by the Ld. AO amount of Rs.1,72,69,594/- u/sec. 69C related to the bogus purchase. The Ld. AR argued that the notice under section 14b which is deemed to be notice 148A(b) of the Act was duly issued ... misconceived and ignores the Supreme Court's directives. The reopening is valid and within time limits as extended. Ground 1(b): Addition of Bogus Purchases under Section 69C and Addition toTotal Income 14. The Appellant challenges the confirmation of addition of Rs. 1,72,69,594/- as unexplained expenditure under

Manoj Kumar, Panipat vs. Income Tax Officer, Ward -1, Panipat

In the result, appeal of the assessee is allowed

ITA 3378/DEL/2025[2018-19]Status: DisposedITAT Delhi29 Jan 2026AY 2018-19

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Assessment Year : 2018-19] Manoj Kumar Vs Ito Prop. Avitex India, Barsat Ward-1 Road, Opp.Kirpal Ashram, Panipat Panipat, Haryana-132103. Pan-Aaepo2553J Appellant Respondent Assessee By Shri Suresh Kumar Gupta, Ca Revenue By Ms. Amisha S.Gutpa, Cit Dr Date Of Hearing 27.11.2025 Date Of Pronouncement 29.01.2026 Order Per Manish Agarwal, Am : The Captioned Appeal Is Filed By Assessee Against The Order Dated 27.03.2025 Passed By Ld. Pr. Commissioner Of Income Tax, Rohtak [“Ld. Pr. Cit”] U/S 263 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 24.02.2023 Passed U/S 147 R.W.S. 144B Of The Act Pertaining To Assessment Year 2018-19. 2. Brief Facts Of The Case Are That The Assessee Filed His Return Of Income On 18.10.2018, Declaring Total Income Of Inr 5,12,820/-. Based On The Available That The Assessee Had Accepted Accommodation Entries In The Form Of Bogus Purchases From M/S. Soni Textiles Of Inr 11,47,500/-, Case Was Re-Opened By Issue Of Notice U/S 148 On 29.03.2022. In Response To The Notice, Assessee Filed Return Of Income On 25.11.2022, Declaring Total Income Of Inr 5,12,820/-. Thereafter, Various Notices Were Issued From Time To Time However, Were Remained Uncompiled With. Thereafter, Ao Vide Order Dated 24.02.2023 Passed U/S 147 R.W.S. 144B Of The Act Assessed The Income Of The Assessee At Inr 16,60,320/- By Making Addition Of Alleged Bogus Purchases.

Section 147Section 148Section 15BSection 263Section 37(1)Section 69C

declaring total income of INR 5,12,820/-. Based on the available that the assessee had accepted accommodation entries in the form of bogus purchases from M/s. Soni Textiles of INR 11,47,500/-, case was re-opened by issue of notice u/s 148 on 29.03.2022. In response ... passed u/s 147 r.w.s. 144B of the Act assessed the income of the assessee at INR 16,60,320/- by making addition of alleged bogus purchases. 3. Thereafter, ld. PCIT has initiated the revision proceedings u/s 263 of the Act vide issue of show cause notice on 18.03.2025 and when

Income Tax Officer, Ward-1(8), Bhavnagar vs. Alinaqi Gulamabbas Bhimani, Bhavnagar

The appeal of the Revenue is treated as allowed for statistical purposes

ITA 2140/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad28 Jan 2026AY 2018-19

Bench: Shri Sanjay Garg & Annapurna Guptaआयकर अपील सं /Ita No.2140/Ahd/2025 िनधा"रण वष" /Assessment Year : 2018-19 The Income Tax Officer Alinaqi Gulamabbas Bhimani बनाम/ Ward-1(8) Prop. Of United Steel V/S. Bhavnagar – 364 001 Corporation Nr. Bajrangdas Dada Ni Vav At Sihor Dist. Bhavnagar – 364 240 "थायी लेखा सं./Pan: Bljpb 9200 L (अपीलाथ(/ Appellant) ()* यथ(/ Respondent) Assessee By : Shri Varis Isani, Advocate Revenue By : Shri Arvind Kumbhare, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 20/01/2026 घोषणा की तारीख /Date Of Pronouncement: 28/01/2026 आदेश/O R D E R Per Sanjay Garg:

For Appellant: Shri Varis Isani, AdvocateFor Respondent: Shri Arvind Kumbhare, Sr.DR
Section 115BSection 133ASection 147Section 250Section 68

Assessing Officer under Section 68 (read with Section 115BBE) of the Income-tax Act, without appreciating the fact that assessee had made bogus purchases from M/s. India Steel Impex, whose proprietor, Shri Bhaveshkumar Bhogilal Patel, admitted under oath to issuing accommodation entries? 2. The appellant craves leave to amend ... providing accommodation entries to various beneficiaries. The assessee was also found to be one of the beneficiaries, who allegedly had obtained accommodation entry of bogus purchases. The case of the assessee was reopened u/s.147/148 of the Act. During the assessment proceedings, the assessee submitted the explanation stating that the purchases

DCIT, Cr Building vs. Gulshan Polyols Limited, Laxmi Nagar

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

ITA 5551/DEL/2024[2019-20]Status: DisposedITAT Delhi28 Jan 2026AY 2019-20

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharmadcit (Osd), Range 10, Vs. M/S. Gulshan Polyols Limited, New Delhi. G – 81, Preet Vihar, Anand Vihar, East Delhi, Delhi – 110 092. (Pan : Aabcg3954F) Co No.47/Del/2025 (In Ita No.5551/Del/2024) (Assessment Year: 2019-20) M/S. Gulshan Polyols Limited, Vs. Dcit (Osd), Range 10, G – 81, Preet Vihar, New Delhi. Anand Vihar, East Delhi, Delhi – 110 092. (Pan : Aabcg3954F) (Appellant) (Respondent) Assessee By : Mohd. Shahid, Ca Revenue By : Shri Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing : 10.11.2025 Date Of Order : 28.01.2026 O R D E R Per S. Rifaur Rahman: 1. The Revenue Has Filed Appeal Against The Order Of The Learned Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre, Delhi [“Ld. Cit (A)”, For Short] Dated 29.11.2024 For The Assessment Year

For Appellant: Mohd. Shahid, CAFor Respondent: Shri Rajesh Kumar Dhanesta, SR. DR
Section 133(6)Section 133ASection 143(2)Section 148ASection 68Section 69C

impugned 5 CO No.47/Del/2025 addition of Rs. 48,29,200/- on account of unaccounted sale and Rs. 5,30,000/- on account of bogus purchases without giving any rebuttal to the documentary evidences filed by the appellant during the assessment proceedings. Therefore, the addition made ... submitted that in a survey, Ashok Kumar Gupta had categorically admitted that all the entries provided to the assessee are bogus sales and also bogus purchases. Ld. DR submitted that the sales entries were made through entity, Madan Lal Madho Prasad who is father- in-law of Ashok Kumar Gupta

DCIT, Circle - 19(1), Delhi vs. Ramayna Ispat Pvt. Ltd., Delhi

In the result, the appeal of the assessee and Revenue are dismissed

ITA 4147/DEL/2024[2018-19]Status: DisposedITAT Delhi28 Jan 2026AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalramayna Ispat Private Limited, Dcit, A-48, 1St Floor, Wazirpur Circle-19(1), Industrial Area, Delhi-110052. Vs. New Delhi. Pan-Aaccr7382R (Appellant) (Respondent) Dcit, Ramayna Ispat Private Limited, A-48, 1St Floor, Wazirpur Circle-19(1), New Delhi. Vs. Industrial Area, Delhi-110052. Pan-Aaccr7382R (Appellant) (Respondent) Assessee By Shri Maneesh Upneja, Ca, Shri Baldev Raj, Ca & Ms. Sanju Kumari, Adv. Department By Shri Khitesh Gupta, Sr. Dr Date Of Hearing 27/11/2025 Date Of Pronouncement 27/11/2025 O R D E R Per Manish Agarwal, Am: These Cross Appeals Are Filed By The Assessee & Revenue Against The Order Of Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Ld. Cit(A)] Dated 11.07.2024 U/S 250 Of The Income Tax Act, 1961 (“The Act” In Short) For Assessment Year 2018-19. Ramayna Ispat Pvt. Ltd. Vs. Ito 2. Brief Facts Of The Case Are That The Assessee Is A Private Ltd. Company Engaged In The Business Of Manufacturing, Processing, Forging, Casting Mixing Of Various Kinds Of Steel, Carbon Settle, Mild Steel, Stainless Steel, High Speed Steel & Bright Steel Etc. The Return Of Income Was Revised On 28.10.2018 At An Income Of Rs.1,00,96,587/-. The Case Of The Assessee Was Reopened U/S 148 For The Reason That Assessee Has Taken Accommodation Entries Of Bogus Purchases & After Considering The Submissions Made, Ao Had Made The Addition Of Rs.5,78,99,593/- U/S 69C Of The Act Towards Unexplained Expenditure On Account Of Bogus Purchase & Further Invoked The Provisions Of Section 115Bbe Of The Act. The Ao Further Made An Addition Of Rs.3,14,795/- By Estimating The Net Profit Declared By The Assessee. Besides This Further Disallowance Of Rs.9,37,608/- Was Made Out Of Freight Expenses And, Accordingly, The Total Income Of The Assessee Was Assessed At Rs.6,87,83,788/-.

Section 115BSection 147Section 148Section 250Section 690Section 69C

Rs.1,00,96,587/-. The case of the assessee was reopened u/s 148 for the reason that assessee has taken accommodation entries of bogus purchases and after considering the submissions made, AO had made the addition of Rs.5,78,99,593/- u/s 69C of the Act towards unexplained expenditure ... account of bogus purchase and further invoked the provisions of section 115BBE of the Act. The AO further made an addition of Rs.3,14,795/- by estimating the net profit declared by the assessee. Besides this further disallowance of Rs.9,37,608/- was made out of Freight Expenses and, accordingly