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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

Poonam Malhotra, New Delhi vs. DCIT Central Circle-04, New Delhi

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

ITA 7993/DEL/2019[2011-12]Status: DisposedITAT Delhi23 Feb 2023AY 2011-12

Bench: Dr. B. R. R. Kumar & Sh. Yogesh Kumar Usi.T.A. No. 7993/Del/2019 (A.Y 2011-12)

Section 153A

Appeals) is not correct in law and on facts. 2. The Ld. CIT (Appeals) has erred in deleting the addition of bogus purchase of Rs.1,76,10,846/- on account of unverified parties which were remained unverifiable at remand stage also. 3. The Ld. CIT (Appeals) erred in ignoring ... 7993/Del/2019 AND ITA. 8079/Del/2019 Ms. Poonam Malhotra, Delhi. 4. The Ld. CIT (Appeals) erred in not upholding the entire addition on account of unverified bogus purchases and applying estimation of profit out of bogus purchases. “ I.T.A. No. 7993/DEL/2019 (A.Y 2011-12) (Assessee) I.T.A. No. 8079/DEL/2019 (A.Y 2011-12) (Revenue

ITO Ward-3(2), Mumbai vs. Tushar Ashok Rahatgaonkar, Mumbai

In the result, appeal filed by the Revenue is dismissed and the cross objection filed by the assessee is partly allowed

ITA 2858/MUM/2022[2010-11]Status: DisposedITAT Mumbai22 Feb 2023AY 2010-11

Bench: Shri Amit Shukla () & Shri Amarjit Singh ()

Section 133(6)Section 143(2)Section 148

called the Ld.CIT(A)] in deleting the addition of Rs.50,59,242/- out of total addition of Rs.57,81,990/- made on account of bogus purchases. 3. The facts in brief are that the case of the assessee for the year under consideration was reopened by issuing of notice under ... cash, but not from the above mentioned parties from whom only bills were obtained. However, the Assessing Officer has treated the whole purchases as bogus purchases and added to the total income of the assessee. Further, the Assessing Officer noticed that assessee has debited expenses

Mukesh Saligram Sharda, Mumbai vs. ITO WD 1(2) Kalyan, Mumbai

The appeal of the assessee is allowed

ITA 1908/MUM/2021[2010-11]Status: DisposedITAT Mumbai22 Feb 2023AY 2010-11

Bench: Shri Amit Shukla () & Shri Amarjit Singh ()

Section 271Section 271(1)(c)

materials on record. It is undisputed fact that impugned penalty was levied only on estimated addition. The Assessing Officer had made addition of entire bogus purchases, however, did not doubt the sales made against such purchases. We observe that the Tribunals in various decisions have held that where sales ... disputed, entire alleged bogus purchases cannot be disallowed and only the gross profit on the alleged purchases to be disallowed. After taking into consideration the various decisions of the Tribunal that no penalty under section 271(1)(c) is leviable on estimated additions and also after taking into consideration

Mukesh Saligram Sharda, Mumbai vs. ITO WD1 (2), Kalyan

The appeal of the assessee is allowed

ITA 1907/MUM/2021[2011-12]Status: DisposedITAT Mumbai22 Feb 2023AY 2011-12

Bench: Shri Amit Shukla () & Shri Amarjit Singh ()

Section 271Section 271(1)(c)

materials on record. It is undisputed fact that impugned penalty was levied only on estimated addition. The Assessing Officer had made addition of entire bogus purchases, however, did not doubt the sales made against such purchases. We observe that the Tribunals in various decisions have held that where sales ... disputed, entire alleged bogus purchases cannot be disallowed and only the gross profit on the alleged purchases to be disallowed. After taking into consideration the various decisions of the Tribunal that no penalty under section 271(1)(c) is leviable on estimated additions and also after taking into consideration

Income Tax Officer, Ward-2(3)(8), Surat vs. Sanjaykumar Devkishan Panwar, Surat

In the result the ground No

ITA 588/SRT/2019[2008-09]Status: DisposedITAT Surat22 Feb 2023AY 2008-09

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.569/Srt/2019 Assessment Year: (2008-09) (Physical Court Hearing) Sanjaykumar Devkishan Panwar, Vs. The Ito, Ward-2(3)(8), 207, 2Nd Floor, 6/2060/61 Vedant Surat. Building Bojabhai Ni Sheri, Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aovpp8989A (Revenue)/(Appellant) (Assessee)/(Respondent) आयकर अपील सं./Ita No.588/Srt/2019 Assessment Year: (2008-09) The Ito, Ward-2(3)(8), Vs. Sanjaykumar Devkishan Panwar, 207, 2Nd Floor, 6/2060/61 Vedant Surat. Building Bojabhai Ni Sheri, Mahidharpura, Surat – 395003 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aovpp8989A (Revenue)/(Appellant) (Assessee)/(Respondent) Assessee By Shri Rohit Vijayvargia, Ca Shri Ritesh Mishra, Cit(Dr) Respondent By Date Of Hearing 03/02/2023 Date Of Pronouncement 20/02/2023

Section 143(3)Section 147Section 148

appellant’s case for A.Y.2008-09. 2. Learned CIT(A) has erred in confirming addition of Rs.1,15,68,364/- of alleged bogus purchases. 3. The appellant reserves the right to add, alter, amend or withdraw any grounds of appeal.” 4. The assessee has also filed additional grounds of appeal, which ... restricting the addition made by the AO to the extent of 5% of entire purchase i.e. Rs.23,13,67,290/- on account of bogus purchases. (ii) On the facts and circumstances of the case and in Law, the Ld. CIT(A) has failed to appreciate the fact that the entire

Sanjaykumar Devkishan Panwar, Surat vs. Income Tax Officer, Ward-2(3)(8), Surat

In the result the ground No

ITA 569/SRT/2019[2008-09]Status: DisposedITAT Surat22 Feb 2023AY 2008-09

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.569/Srt/2019 Assessment Year: (2008-09) (Physical Court Hearing) Sanjaykumar Devkishan Panwar, Vs. The Ito, Ward-2(3)(8), 207, 2Nd Floor, 6/2060/61 Vedant Surat. Building Bojabhai Ni Sheri, Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aovpp8989A (Revenue)/(Appellant) (Assessee)/(Respondent) आयकर अपील सं./Ita No.588/Srt/2019 Assessment Year: (2008-09) The Ito, Ward-2(3)(8), Vs. Sanjaykumar Devkishan Panwar, 207, 2Nd Floor, 6/2060/61 Vedant Surat. Building Bojabhai Ni Sheri, Mahidharpura, Surat – 395003 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aovpp8989A (Revenue)/(Appellant) (Assessee)/(Respondent) Assessee By Shri Rohit Vijayvargia, Ca Shri Ritesh Mishra, Cit(Dr) Respondent By Date Of Hearing 03/02/2023 Date Of Pronouncement 20/02/2023

Section 143(3)Section 147Section 148

appellant’s case for A.Y.2008-09. 2. Learned CIT(A) has erred in confirming addition of Rs.1,15,68,364/- of alleged bogus purchases. 3. The appellant reserves the right to add, alter, amend or withdraw any grounds of appeal.” 4. The assessee has also filed additional grounds of appeal, which ... restricting the addition made by the AO to the extent of 5% of entire purchase i.e. Rs.23,13,67,290/- on account of bogus purchases. (ii) On the facts and circumstances of the case and in Law, the Ld. CIT(A) has failed to appreciate the fact that the entire

Late Shri Bhimsen Darbarilal Arora, Surat vs. The Asstt. Commissioner of Income Tax, Circle-5, Surat

In the result, ground no.4 raised by assessee is allowed for statistical purposes

ITA 1706/AHD/2016[2010-11]Status: DisposedITAT Surat22 Feb 2023AY 2010-11

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.1706/Ahd/2016 "नधा"रणवष"/Assessment Year: (2010-11) (Physical Court Hearing) Bhimsen Darbarilal Arora Through, Vs. The Acit, Circle-5, L/H. Rajat Bhimsen Arora, Surat. Smt. Mamta Bhimsen Arora, A-201, Madhulika Apartment, Bhatar Road, Surat. (Appellant) (Respondent) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Acaps9230L

Section 133ASection 143(3)Section 145(3)Section 68

discrepancy has a very little significance. It was held in the case of ACIT Vs. Shrikrishan Malpani 32 Taxworld 122 (JPR) holding that alleged bogus purchase is defect in maintenance of books of a/cs and therefore, the books of a/cs rightly rejected. Further in the case of Gem Paradise Case ... making 100% disallowance of ‘unverifiable purchase’, the AO should have restricted the disallowance on some percentage basis. The AO had considered these purchases as bogus purchases and had disallowed100% of such purchases. Considering the factual matrix of the case, I am of the considered view that these purchases could

Shri Jai Bhagwan Mittal, Mumbai vs. Income Tax Officer, Ward-2(3), Thane

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

ITA 2963/MUM/2022[2009-2010]Status: DisposedITAT Mumbai21 Feb 2023AY 2009-2010

Bench: Shri Kuldip Singh, Hon'Ble & Shri S. Rifaur Rahman, Hon'Bleshri Jai Bhagwan Mittal V. Income Tax Officer – 2(3) 18/1301 Shree Shashwat Mira Ashar I.T. Park Bhayander Road, Mira Road (E) Wagle Industrial Estate Thane- 401107 Thane, Mumbai - 400604 Pan: Adlpm8443M (Appellant) (Respondent)

Section 133(6)Section 143(1)Section 143(3)Section 147Section 148Section 69C

reopening of the case was made on the basis of information received from the Sales Tax Department, Maharashtra that the assessee has taken bogus purchase bills of ₹.3,27,236/- from M/s. Maruti Steel Traders and ₹.11,34,276/- from M/s.Shiv Industries. During the assessment proceedings the Assessing Officer ... alleged unexplained investment u/s 69C of the Income Tax Act, 1961 by treating the genuine purchases as alleged bogus purchases, without considering the facts and circumstances of the case. 3. WITHOUT PREJUDICE the appellant prays that the purchases are genuine and hence in the alternative without conceding to the same

Eeva Exports, Mum vs. CIT (A), NFAC, Delhi

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

ITA 3091/MUM/2022[2011-12]Status: DisposedITAT Mumbai20 Feb 2023AY 2011-12

Bench: Shri M. Balaganesh & Shri Sandeep Singh Karhail

For Appellant: Shri Rajnish AggarwalFor Respondent: Ms. Indira Adakil
Section 147Section 250Section 253(3)

thereby confirming the action of Ld. Assessing Officer in considering it to be a bogus purchase on the basis of information received from Investigation Wing of the Income Tax Department. Mumbai ignoring the fact that the appellant is maintaining proper books of account, purchase and sales are supported by vouchers ... complete stock tally is maintained, particularly against the alleged bogus purchase made from Mayank Impex which is supported by corresponding Eeva Exports ITA no.3091/Mum./2022 sale of the item purchased and duly recorded in the audited books of account of the appellant. Therefore, the action of CIT (Appeals) (NFAC

Challenger Computers, Mumbai vs. ITO 19(1)(3), Mumbai

In the result, the appeal by the assessee for the assessment year 2009-

ITA 3750/MUM/2019[2010-11]Status: DisposedITAT Mumbai20 Feb 2023AY 2010-11

Bench: Shri M. Balaganesh & Shri Sandeep Singh Karhail

For Appellant: Shri K.J. BafnaFor Respondent: Ms. Indira Adakil
Section 143(3)Section 147Section 148Section 234BSection 250

Four lac thirty thousand eight hundred sixty one only) to the income being disallowance on account of alleged to be bogus purchase Rs. 34,46,888/- at 12.5% which is very very on higher side & also without any basis & justification & the learned CIT erred in confirming the same. They failed ... Pursuant to the information received from DGIT (Inv.), Mumbai, and the Sales Tax Department, Government of Maharashtra, that the assessee is a beneficiary of bogus purchases, the re–assessment proceedings under section 147 were initiated in the case of the assessee and notice under section

Challenger Computers, Mumbai vs. ITO 19(1)(3), Mumbai

In the result, the appeal by the assessee for the assessment year 2009-

ITA 3749/MUM/2019[2009-10]Status: DisposedITAT Mumbai20 Feb 2023AY 2009-10

Bench: Shri M. Balaganesh & Shri Sandeep Singh Karhail

For Appellant: Shri K.J. BafnaFor Respondent: Ms. Indira Adakil
Section 143(3)Section 147Section 148Section 234BSection 250

Four lac thirty thousand eight hundred sixty one only) to the income being disallowance on account of alleged to be bogus purchase Rs. 34,46,888/- at 12.5% which is very very on higher side & also without any basis & justification & the learned CIT erred in confirming the same. They failed ... Pursuant to the information received from DGIT (Inv.), Mumbai, and the Sales Tax Department, Government of Maharashtra, that the assessee is a beneficiary of bogus purchases, the re–assessment proceedings under section 147 were initiated in the case of the assessee and notice under section

DCIT Cent. Cir-2(3), Mumbai vs. Soma Enterprises Ltd, Mumbai

In the result, appeal filed by the Revenue is dismissed

ITA 1824/MUM/2021[2015-16]Status: DisposedITAT Mumbai17 Feb 2023AY 2015-16

Bench: Shri Kuldip Singh, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

Section 132Section 143(3)

under: - “At the outset we submit that AO had made additions on suspicion and surmises without following due procedure of law and judicial precedents. Bogus Purchases (ii) We submit that it is a settled principle that information collected by the department cannot be made use of against the assessee unless ... Gujarat High Court in the case of CIT VS TEJUA ROHIT KUMAR KAPADIA, ITA No.691 of 2017 on identical issues of bogus purchases. Incidentally, the Hon'ble Supreme Court dismissed the SLP filed by the department vide SLP No.12670/2018. In the instant case, the Hon'ble High Court was dealing

Bhargab Engineering Works, Howrah vs. A.C.I.T., Circle-46, Kolkata

In the result, appeal of the assessee is partly allowed

ITA 1714/KOL/2019[2012-13]Status: DisposedITAT Kolkata16 Feb 2023AY 2012-13

Bench: Shri Sanjay Garg, Hon’Ble & Dr. Manish Borad, Hon’Blei.T.A. No. 1714/Kol/2019 Assessment Year: 2012-13 Bhargab Engineering Works A.C.I.T., Circle - 46, Kolkata P-292, Benaras Road Vs Belgachia, P.O.: Netajigarh Howrah - 711108 [Pan : Aaifb2118G] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Miraj D. Shah, A.R. Revenue By : Smt. Ranu Biswas, Addl. Cit, D/R सुनवाई क" तारीख/Date Of Hearing : 28/11/2022 घोषणा क" तारीख /Date Of Pronouncement: 16/02/2023 आदेश/O R D E R Per Dr. Manish Borad: The Present Appeal Is Directed At The Instance Of The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals) - 14, Kolkata, (Hereinafter The “Ld. Cit(A)”) Dt. 07/05/2019, Passed U/S 250 Of The Income Tax Act, 1961 (“The Act’), For Assessment Year 2012-13. 2. The Assessee Has Raised The Following Grounds Of Appeal:- “1. For That The Impugned Order Of Reassessment Is Bad In Law. 2. For That The Reassessment Proceedings Are Bad In Law Inasmuch As The A.O. Had Wrongly Assumed Jurisdiction To Assess The Case. 3. For That In The Facts & Circumstances Of The Case, The Ld. Cit(A) Was Not Justified In Law In Sustaining Addition To The Tune Of 17.38% Of Alleged Disputed Purchase By Applying Average Gross Profit Ratio In The Appellant'S Case & In Any Event, The Addition Sustained By The Ld. Cit(A), Is Liable To Be Deleted In This Forum. 4. For That In The Facts & Circumstances Of The Case, The Ld. Cit(A) Was Not Justified In Law In Sustaining Addition To The Tune Of 1% Of Alleged Disputed Purchase As Commission In The Appellant'S Case & In Any Event, The Addition Sustained By The Ld. Cit(A), Is Liable To Be Deleted In This Forum. 5. For That When The Appellate Authorities Below Have Taken Note Of The Fact That No Sale Could Be Effected By The Assesse Without Purchase & Whereas In Your

For Appellant: Shri Miraj D. Shah, A.RFor Respondent: Smt. Ranu Biswas, Addl. CIT, D/R
Section 131Section 133(6)Section 250

that purchase were also accepted by the Assessing Officer. Case Reference: Hon'ble Supreme court upheld HC order on deletion of addition for Bogus Purchase. Case Name: PCIT Vs. Tejua Rohitkumar Kapadia (Supreme High I.T.A. No. 1714/Kol/2019 Assessment Year: 2012-13 Bhargab Engineering Works 3 Court). Appeal Number: Special Leave ... issued on 26/03/2018 after obtaining statutory approval. Reasons recorded were supplied to the assessee which contained the information about bogus purchases from paper concerns operated by Shri Sanjiw Kumar Singh, namely, M/s. Singh Mercantile Pvt. Ltd., at Rs.15,600/- and M/s. Jayshree Sales Corporation at Rs.17,73,589/-. Objection raised

M/S. Babji Oil Mill Pvt. Ltd., Ranekpar, Tal. Wakaner, Dist. Morbi vs. The Deputy Commissioner of Income Tax, Morbi Circle, Morbi

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

ITA 143/RJT/2018[2013-14]Status: HeardITAT Rajkot15 Feb 2023AY 2013-14

Bench: Shri Waseem Ahmed (Accountant Member), Shri Siddhartha Nautiyal, Judicial Member M/s. Babji Oil Mill Pvt. Ltd., 8- (Accountant Member)

For Appellant: Written SubmissionFor Respondent: Shri Shramdeep Sinha, Sr. D.R
Section 143(3)Section 68

erred in law and facts confirming addition of an amount of Rs. 3,17,87,900/- treating the same as unexplained 7 bogus purchase. The addition needs deletion. 4. Taking into consideration the legal, statutory, factual, accounting and administrative aspects, no addition amounting

Income Tax Officer -32(2) (1), Mumbai vs. M/S. Kinjal Enterprises, Mumb

In the result, the appeal of the revenue stand dismissed

ITA 60/MUM/2022[2014-15]Status: DisposedITAT Mumbai13 Feb 2023AY 2014-15

Bench: Shri Pavan Kumar Gadale & Shri Amarjit Singhita Nos. 60/Mum/2022 Ita Nos. 2464/Mum/2021 (A.Ys. 2013-14 & 2014-15)

For Appellant: Soumendu Kumar DashFor Respondent: Shashank Mehta
Section 132Section 143(2)

Rs.20,28,853/- under the garb of Unsecured loan from Shri Praveen Kumar Jain Group which has indulged in providing accommodation entries like bogus purchases, sales, unsecured loans. share capital etc. as per statement on oath of Shri Praveen Kumar Jain recorded during the course of search and seizure action

ITO 32(2)(1), Mumbai vs. Kinjal Enterprises, Mumbai

In the result, the appeal of the revenue stand dismissed

ITA 2464/MUM/2021[2013-14]Status: DisposedITAT Mumbai13 Feb 2023AY 2013-14

Bench: Shri Pavan Kumar Gadale & Shri Amarjit Singhita Nos. 60/Mum/2022 Ita Nos. 2464/Mum/2021 (A.Ys. 2013-14 & 2014-15)

For Appellant: Soumendu Kumar DashFor Respondent: Shashank Mehta
Section 132Section 143(2)

Rs.20,28,853/- under the garb of Unsecured loan from Shri Praveen Kumar Jain Group which has indulged in providing accommodation entries like bogus purchases, sales, unsecured loans. share capital etc. as per statement on oath of Shri Praveen Kumar Jain recorded during the course of search and seizure action

Hazari Lal Kesari Chand, New Delhi vs. ACIT, Circle-48(1), New Delhi

In the result, the appeal of the assessee is dismissed

ITA 8561/DEL/2019[2007-08]Status: DisposedITAT Delhi10 Feb 2023AY 2007-08

Bench: Shri Anil Chaturvedi & Shri Yogesh Kumar U.S

For Appellant: N O N EFor Respondent: Shri
Section 132Section 133(6)Section 143(1)Section 148

case of Sh. Rajendra Jain Group, Sh. Sanjay Choudhary and Sh. Dharmichand Group on 03/10/2013. Consequent upon the search operation, information was received regarding bogus purchase entries provided by Sh. Rajender Jain Group to the assessee during the year under consideration through shell companies, M/s Vitrag Jewels, Moulimani Impex ... Paramount Communication (P.) Ltd. (2017- TIOL- 253-SC-IT) the Hon'ble Supreme Court dismissed SLP of assessee and held that: Information regarding bogus purchase by assessee received by DRI from CCE which was passed on to revenue authorities was 'tangible material outside record' to initiate valid reassessment proceedings

M.S.Decorators P.Ltd, New Delhi vs. DCIT, Circle-6(1), New Delhi

In the result, the appeal of the assessee is allowed

ITA 2174/DEL/2018[2011-12]Status: DisposedITAT Delhi08 Feb 2023AY 2011-12

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

For Appellant: Sh. S. K. Chadda, CAFor Respondent: Sh. Amit Shukla, Sr. DR
Section 133(6)Section 147Section 148Section 68

against the provisions of law. 2. The ld. CIT(A) has erred in confirming the addition of Rs.4,68,090/- on account of bogus purchases which is also arbitrary, unjustified and against the facts of the case.” 2 M. S. Decorators P. Ltd. 3. The assessee filed return of income ... opened, re-assessing at an income of Rs.4,02,60,979/- thus, making an addition of Rs. 4,68,090/- on account of bogus purchases. 4. Heard the arguments of both the parties and perused the material available on record. Reasons for re-opening of the case

K & R Rail Engineering Limited, Secunderabad vs. ACIT, Central Circle-3(4), Hyderabad

ITA 376/HYD/2022[2017-18]Status: DisposedITAT Hyderabad07 Feb 2023AY 2017-18

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

For Appellant: Shri P. Murali Mohan Rao, C.AFor Respondent: Shri K.P.R.R.Murthy, Sr.AR
Section 234A

income which comes to his notice subsequently in course of reopening proceedings. 2. The Ld. CIT(A) ought to have appreciated the fact that bogus purchases was the reason to believe as per the satisfactory note which was supplemented to the assessee and no addition was made on the same ... income which comes to his notice subsequently in course of reopening proceedings. 3. The Ld. CIT(A) ought to have appreciated the fact that bogus purchases was the reason to believe as per the satisfactory note which was supplemented to the assessee and no addition was made on the same

K & R Rail Engineering Limited, Secunderabad vs. ACIT, Central Circle-3(4), Hyderabad

ITA 375/HYD/2022[2016-17]Status: DisposedITAT Hyderabad07 Feb 2023AY 2016-17

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

For Appellant: Shri P. Murali Mohan Rao, C.AFor Respondent: Shri K.P.R.R.Murthy, Sr.AR
Section 234A

income which comes to his notice subsequently in course of reopening proceedings. 2. The Ld. CIT(A) ought to have appreciated the fact that bogus purchases was the reason to believe as per the satisfactory note which was supplemented to the assessee and no addition was made on the same ... income which comes to his notice subsequently in course of reopening proceedings. 3. The Ld. CIT(A) ought to have appreciated the fact that bogus purchases was the reason to believe as per the satisfactory note which was supplemented to the assessee and no addition was made on the same