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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

Jitendrakumar Dahyalal Parmar, Deesa vs. The ITO, Ward-2, Palanpur

In the result, the appeal of the assessee is allowed

ITA 943/AHD/2025[2011-12]Status: DisposedITAT Ahmedabad06 Jan 2026AY 2011-12

Bench: Ms. Suchitra Kambleassessment Year 2011-12

For Appellant: Shri Mehul Thakker, C.AFor Respondent: Shri Suresh Chand Meena, Sr. D.R
Section 132Section 147Section 148Section 44Section 44A

During the pre-search and post-search inquiry, it was found that the said M/s. Dinesh Chandra R. Agrawal Infracon Pvt. Ltd. has booked bogus purchases expenses for materials through bogus sub- contractor expenses shown in the name of various dummy entities. The name of the assessee was reflected ... Statutory notices were issued and after taking cognizance of the assessee’s reply, the Assessing Officer held that the assessee booked bogus purchase expenses for materials through bogus sub-contractors expenses to the tune of Rs. 25,71,047/- in the name of various dummy entities and assessee’s name

DCIT, Central Circle 7(1), Mumbai vs. Subhkaran & Sons, Mumbai

In the result, appeal of the assessee is allowed and that by the revenue is dismissed, for Assessment Year 2013-14

ITA 3986/MUM/2025[2014-15]Status: DisposedITAT Mumbai06 Jan 2026AY 2014-15

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Snehal Shah, CAFor Respondent: Shri R A Dhyani, CIT DR
Section 1Section 132

banking credit facilities availed by it. According to the ld. Assessing Officer, AYs: 2013-14 to 2017-18 assessee provided accommodation entries by doing bogus purchases from various paper / shell entities of Topworth, Uttam Galva and Lloyds group of companies. These shell entities discounted the bills in the banks ... backed / supported by LC payments only. Ld. Assessing Officer observed that during the year under consideration, various LCs were opened for payment of bogus purchases to alleged paper / shell entities. 3.2. He noted that as far as LC funding facility is concerned, assessee would have earned for providing the additional

DCIT, Central Circle 7(1), Mumbai vs. Subhkaran & Sons, Mumbai

In the result, appeal of the assessee is allowed and that by the revenue is dismissed, for Assessment Year 2013-14

ITA 3969/MUM/2025[2015-16]Status: DisposedITAT Mumbai06 Jan 2026AY 2015-16

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Snehal Shah, CAFor Respondent: Shri R A Dhyani, CIT DR
Section 1Section 132

banking credit facilities availed by it. According to the ld. Assessing Officer, AYs: 2013-14 to 2017-18 assessee provided accommodation entries by doing bogus purchases from various paper / shell entities of Topworth, Uttam Galva and Lloyds group of companies. These shell entities discounted the bills in the banks ... backed / supported by LC payments only. Ld. Assessing Officer observed that during the year under consideration, various LCs were opened for payment of bogus purchases to alleged paper / shell entities. 3.2. He noted that as far as LC funding facility is concerned, assessee would have earned for providing the additional

DCIT, Central Circle 7(1), Mumbai vs. Subhkaran & Sons, Mumbai

In the result, appeal of the assessee is allowed and that by the revenue is dismissed, for Assessment Year 2013-14

ITA 3968/MUM/2025[2017-18]Status: DisposedITAT Mumbai06 Jan 2026AY 2017-18

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Snehal Shah, CAFor Respondent: Shri R A Dhyani, CIT DR
Section 1Section 132

banking credit facilities availed by it. According to the ld. Assessing Officer, AYs: 2013-14 to 2017-18 assessee provided accommodation entries by doing bogus purchases from various paper / shell entities of Topworth, Uttam Galva and Lloyds group of companies. These shell entities discounted the bills in the banks ... backed / supported by LC payments only. Ld. Assessing Officer observed that during the year under consideration, various LCs were opened for payment of bogus purchases to alleged paper / shell entities. 3.2. He noted that as far as LC funding facility is concerned, assessee would have earned for providing the additional

DCIT, Central Circle 7(1), Mumbai vs. Subhkaran & Sons, Mumbai

In the result, appeal of the assessee is allowed and that by the revenue is dismissed, for Assessment Year 2013-14

ITA 3967/MUM/2025[2016-17]Status: DisposedITAT Mumbai06 Jan 2026AY 2016-17

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Snehal Shah, CAFor Respondent: Shri R A Dhyani, CIT DR
Section 1Section 132

banking credit facilities availed by it. According to the ld. Assessing Officer, AYs: 2013-14 to 2017-18 assessee provided accommodation entries by doing bogus purchases from various paper / shell entities of Topworth, Uttam Galva and Lloyds group of companies. These shell entities discounted the bills in the banks ... backed / supported by LC payments only. Ld. Assessing Officer observed that during the year under consideration, various LCs were opened for payment of bogus purchases to alleged paper / shell entities. 3.2. He noted that as far as LC funding facility is concerned, assessee would have earned for providing the additional

DCIT, Central Circle 7(1), Mumbai vs. Subhkaran & Sons, Mumbai

In the result, appeal of the assessee is allowed and that by the revenue is dismissed, for Assessment Year 2013-14

ITA 3966/MUM/2025[2013-14]Status: DisposedITAT Mumbai06 Jan 2026AY 2013-14

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Snehal Shah, CAFor Respondent: Shri R A Dhyani, CIT DR
Section 1Section 132

banking credit facilities availed by it. According to the ld. Assessing Officer, AYs: 2013-14 to 2017-18 assessee provided accommodation entries by doing bogus purchases from various paper / shell entities of Topworth, Uttam Galva and Lloyds group of companies. These shell entities discounted the bills in the banks ... backed / supported by LC payments only. Ld. Assessing Officer observed that during the year under consideration, various LCs were opened for payment of bogus purchases to alleged paper / shell entities. 3.2. He noted that as far as LC funding facility is concerned, assessee would have earned for providing the additional

Subhkaran and Sons, Mumbai vs. DCIT, Central Circle 7(1), Mumbai

In the result, appeal of the assessee is allowed and that by the revenue is dismissed, for Assessment Year 2013-14

ITA 2910/MUM/2025[2016-17]Status: DisposedITAT Mumbai06 Jan 2026AY 2016-17

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Snehal Shah, CAFor Respondent: Shri R A Dhyani, CIT DR
Section 1Section 132

banking credit facilities availed by it. According to the ld. Assessing Officer, AYs: 2013-14 to 2017-18 assessee provided accommodation entries by doing bogus purchases from various paper / shell entities of Topworth, Uttam Galva and Lloyds group of companies. These shell entities discounted the bills in the banks ... backed / supported by LC payments only. Ld. Assessing Officer observed that during the year under consideration, various LCs were opened for payment of bogus purchases to alleged paper / shell entities. 3.2. He noted that as far as LC funding facility is concerned, assessee would have earned for providing the additional

Subhkaran and Sons, Mumbai vs. DCIT, Central Circle 7(1), Mumbai

In the result, appeal of the assessee is allowed and that by the revenue is dismissed, for Assessment Year 2013-14

ITA 2909/MUM/2025[2014-15]Status: DisposedITAT Mumbai06 Jan 2026AY 2014-15

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Snehal Shah, CAFor Respondent: Shri R A Dhyani, CIT DR
Section 1Section 132

banking credit facilities availed by it. According to the ld. Assessing Officer, AYs: 2013-14 to 2017-18 assessee provided accommodation entries by doing bogus purchases from various paper / shell entities of Topworth, Uttam Galva and Lloyds group of companies. These shell entities discounted the bills in the banks ... backed / supported by LC payments only. Ld. Assessing Officer observed that during the year under consideration, various LCs were opened for payment of bogus purchases to alleged paper / shell entities. 3.2. He noted that as far as LC funding facility is concerned, assessee would have earned for providing the additional

Subhkaran and Sons, Mumbai vs. DCIT, Central Circle 7(1), Mumbai

In the result, appeal of the assessee is allowed and that by the revenue is dismissed, for Assessment Year 2013-14

ITA 2908/MUM/2025[2013-14]Status: DisposedITAT Mumbai06 Jan 2026AY 2013-14

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Snehal Shah, CAFor Respondent: Shri R A Dhyani, CIT DR
Section 1Section 132

banking credit facilities availed by it. According to the ld. Assessing Officer, AYs: 2013-14 to 2017-18 assessee provided accommodation entries by doing bogus purchases from various paper / shell entities of Topworth, Uttam Galva and Lloyds group of companies. These shell entities discounted the bills in the banks ... backed / supported by LC payments only. Ld. Assessing Officer observed that during the year under consideration, various LCs were opened for payment of bogus purchases to alleged paper / shell entities. 3.2. He noted that as far as LC funding facility is concerned, assessee would have earned for providing the additional

Subhkaran and Sons, Mumbai vs. DCIT, Central Circle 7(1), Mumbai

In the result, appeal of the assessee is allowed and that by the revenue is dismissed, for Assessment Year 2013-14

ITA 2907/MUM/2025[2015-16]Status: DisposedITAT Mumbai06 Jan 2026AY 2015-16

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Snehal Shah, CAFor Respondent: Shri R A Dhyani, CIT DR
Section 1Section 132

banking credit facilities availed by it. According to the ld. Assessing Officer, AYs: 2013-14 to 2017-18 assessee provided accommodation entries by doing bogus purchases from various paper / shell entities of Topworth, Uttam Galva and Lloyds group of companies. These shell entities discounted the bills in the banks ... backed / supported by LC payments only. Ld. Assessing Officer observed that during the year under consideration, various LCs were opened for payment of bogus purchases to alleged paper / shell entities. 3.2. He noted that as far as LC funding facility is concerned, assessee would have earned for providing the additional

Subhkaran and Sons, Mumbai vs. DCIT, Central Circle 7(1), Mumbai

In the result, appeal of the assessee is allowed and that by the

ITA 2906/MUM/2025[2017-18]Status: DisposedITAT Mumbai06 Jan 2026AY 2017-18

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Snehal Shah, CAFor Respondent: Shri R A Dhyani, CIT DR
Section 132

seen that assessee misused banking credit facilities availed by it. According to the ld. Assessing Officer, assessee provided accommodation entries by doing bogus purchases from various paper / shell entities of Topworth, Uttam Galva and Lloyds group of companies. These shell entities discounted the bills in the banks. On behalf ... backed / supported by LC payments only. Ld. Assessing Officer observed that during the year under consideration, various LCs were opened for payment of bogus purchases to alleged paper / shell entities. 3.2. He noted that as far as LC funding facility is concerned, assessee would have earned for providing the additional

A.C.I.T. CC -3(1), Mumbai vs. Everest Food Products Pvt. Ltd., Mumbai

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

ITA 3988/MUM/2025[2021-22]Status: DisposedITAT Mumbai05 Jan 2026AY 2021-22

Bench: Shri Vikram Singh Yadav, Jm & Ms. Kavitha Rajagopal, Am Acit, Cc-3(1), M/S. Everest Food Products Pvt. R.No.402, Kautilya Bhawan, Ltd., G Block, Bkc, Bandra East, Krushal Commercial Complex, Vs. Mumbai – 400051 G.M. Road, Tilak Nagar S.O., Chembur Mumbai – 400 089 Pan: Aafce8947A (Appellant) : (Respondent)

For Respondent: Shri Ritesh Misra, CIT DR
Section 139(1)Section 143(2)Section 143(3)Section 250Section 40

High Court set-aside the decision of Hon'ble Tribunal and confirmed the AO decision to add back 100% of the alleged bogus purchase to the assessee's income for the corresponding assessment years. The appellant craves to leave, to add, to amend and / or to alter ... addition of Rs.25,55,69,713/- being 45.73% as gross profit on the alleged transaction of Rs.55,55,83,331/- towards the alleged bogus purchases from four parties which is said to have been not substantiated with relevant documentary evidences by the assessee. 4. Aggrieved, the assessee was in appeal

DCIT Central Circle- 7(1), Mumbai vs. Yardley Investment and Trading Company Pvt Ltd, Mumbai

Accordingly, the cross-objection filed by the assessee is allowed, and the appeal by the Revenue is dismissed

ITA 4725/MUM/2025[2013-14]Status: DisposedITAT Mumbai02 Jan 2026AY 2013-14

Bench: Shri Sandeep Singh Karhailshri Prabhash Shankarassessment Year : 2013-14 Deputy Commissioner Of Income Tax, Central Circle - 7(1), Room No.653, 6Th Floor Aayakar Bhavan, M.K. Road, ……………. Appellant Mumbai – 400020 V/S Yardley Investment & Trading Company Pvt. Ltd. 1, Pearl Mansion N, 91, M.K. Road, Mumbai – 400020 ……………. Respondent Pan: Aaacy0327M

For Appellant: Shri Snehal ShahFor Respondent: Shri Arun Kanti Datta, CIT-DR
Section 132Section 153ASection 250Section 68

held that the physical movement of goods was not actually being done and the searched entities were providing accommodation entries by doing bogus purchases from various papers/shell entities of Topworth, Uttam Galva and Lloyds Group of companies. The findings of the AO in this regard are reproduced as follows ... above mentioned entities to whom sales are made, have admitted that no actual goods is delivered and only bills have issued against these bogus purchases. • Directors of the searched entities failed to give any satisfactory reasons and did not provide any substantial documentary evidences to establish the genuineness of these

Axis Infoline P Ltd, Delhi vs. PCIT-1, Delhi

In the result, appeal of the assessee is allowed

ITA 2613/DEL/2025[2021-22]Status: DisposedITAT Delhi02 Jan 2026AY 2021-22

Bench: Shri Mahavir Singh, Hon’Ble & Shri Sanjay Awasthiआ.अ.सं/.I.T.A No.2613/Del/2025 िनधा"रणवष"/Assessment Year: 2021-22 बनाम Axis Infoline P. Ltd., Principal Commissioner Of Income 196/16B, 2Nd Floor, Vs. Tax, Ramesh Market, East Of Kailash, Income Tax Office, Delhi-1. Nehru Nagar, South Delhi. Delhi. Pan No.Aadca9862C अपीलाथ" Appellant ""यथ"/Respondent

Section 143(3)Section 263

offer of the assessee for the Ld. AO to add 12.50% of such purchases and proceeded ahead to disallow 25% of the said bogus purchases as shown by the assessee. 1 1.1 This matter was examined by the Ld. PCIT and based on the presumption that once purchases are held ... Impex case (supra) the Hon’ble Supreme Court has dismissed the SLP also. The Ld. PCIT came to the conclusion that 100% of the bogus purchases deserved to be disallowed and thereafter, he held the Ld. AO’s order to be erroneous and prejudicial to the interest of Revenue

Income Tax Officer-1(2), Raipur vs. Kanha Grain Process, Raipur

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

ITA 260/RPR/2025[2015-16]Status: DisposedITAT Raipur01 Jan 2026AY 2015-16

Bench: Shri R. K. Panda & Shri Partha Sarathi Chaudhuryassessment Year : 2015-16 Ito, Ward 1(2), Raipur Kanha Grain Process Vs. Station Road, Tilda Neora, Raipur – 493114 Pan: Aaifk3222G (Appellant) (Respondent) Assessee By : Shri Sunil Kumar Agrawal Department By : Dr. Priyanka Patel, Sr. Dr Date Of Hearing : 14-11-2025 Date Of Pronouncement : 01-01-2026 O R D E R Per R.K. Panda, Vp:

For Appellant: Shri Sunil Kumar AgrawalFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 143(3)Section 147Section 148Section 148ASection 69C

Subsequently information was made available with the department that the assessee is a beneficiary of Rs.44,87,500/- on account of bogus purchases from M/s. Maa Sharda Process and Rs.74,12,500/- from M/s. Shri Vaishno Devi Exim. Accordingly a notice u/s 148 of the Income Tax Act, 1961 (hereinafter ... Rs.1,27,01,710/- by making addition of Rs.1,19,00,000/- as unexplained expenditure u/s 69C of the Act on account of bogus purchases. 4. Before the Ld. CIT(A) / NFAC, the assessee apart from challenging the addition on merit, challenged the validity of re-assessment proceedings

Kamlesh Kukreja, Raipur vs. ITO, Ward-1(1), Raipur

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

ITA 119/RPR/2025[2016-17]Status: DisposedITAT Raipur01 Jan 2026AY 2016-17

Bench: Shri R. K. Panda & Shri Partha Sarathi Chaudhuryassessment Year : 2016-17 Kamlesh Kukreja Ito, Ward-1(1), Raipur Prop. Anmol Industries, Vs. Surajpura Road, Bhatapara, Raipur – 493118 Ahvpk6618C (Appellant) (Respondent) Assessee By : Shri Sunil Kumar Agrawal Department By : Dr. Priyanka Patel, Sr. Dr Date Of Hearing : 14-11-2025 Date Of Pronouncement : 01-01-2026 O R D E R Per R.K. Panda, Vp:

For Appellant: Shri Sunil Kumar AgrawalFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 144Section 148Section 69C

Rs.5,97,440/-. The case of the assessee was reopened on the ground that the assessee has received accommodation entries in the guise of bogus purchases of Rs.1,87,90,375/- during the financial year 2015-16 relevant to assessment year 2016-17 from Shri Deepak Nanjyani. Accordingly notice ... circumstances of the case and in law, CIT(A) has erred in sustaining the addition of Rs.2,59,23,992 on account of bogus purchases of 'Chana' (i.e. raw material); while corresponding sales of 'Chana Dall' (ie, finished), "Chana Bhusa' & 'Chana Chuni' has not been disputed

Srinu Venkataiah Margam, Surat vs. PCIT-1, Surat

In the result, the appeal of the assessee stands allowed

ITA 481/SRT/2025[2018-19]Status: DisposedITAT Surat01 Jan 2026AY 2018-19

Bench: Shri Sanjay Garg & Shri Bijayananda Pruseth

For Appellant: Shri Ramesh Malpani, CAFor Respondent: Shri Aashish Pophare, CIT (DR)
Section 147Section 263

observed that the A.O. should have disallowed the entire purchases and not the only gross profit on such bogus purchases. He therefore, set aside the assessment order and directed the Assessing Officer to pass a fresh assessment order. 6. Being Aggrieved by the said Order of the Ld. PCIT

Rainbow Vanijya Pvt Ltd., New Delhi vs. ACIT, Kolkata

In the result, the appeal of the assessee is allowed

ITA 1891/KOL/2025[2020-21]Status: DisposedITAT Kolkata31 Dec 2025AY 2020-21
Section 142(1)Section 143(2)Section 143(3)Section 144BSection 44A

under:-\ni. The assessee has challenged the order of Id. CIT (A) enhancing the assessment by ₹66,12,43,527/- on account of alleged bogus purchases without doubting the sales recorded the books of accounts and thus, the Id. CIT (A) has exceeded the jurisdiction since, the addition made ... cause notice on 25.08.2022, giving show cause as to why an addition of ₹64,47,79,406/- should not be made in respect of bogus purchases from the three parties namely; Rimjim Stainless Ltd., Swaraj Overseas and Veto Merchandise. The Id. AO, after taking into account the reply

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

case, and 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 ... case, and in law, learned Commissioner of Income-tax (Appeal) while upholding action of the Assessing Officer in disallowing the entire alleged Bogus Purchases of Rs. 15,47,224 erred in not appreciating that what could at the best be disallowed was an appropriate profit percentage embedded in such sales

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

Based upon inputs received from the GST Department, information was available with the Department that the assessee was engaged in the activity of making bogus purchases and had consequently indulged in getting bogus purchases from two parties namely Shri Balaji Wooltex and Shri Rameshwaram International of Rs.82 ... firms without delivery of goods. Shri Rajesh Mittal had admitted these fraudulent transactions before the GST authorities conveying that in pursuance to payments for bogus purchases received through banking channels, cash backs were given to beneficiaries of bogus purchases after deducting commission. Pertinently, Shri Rajesh Mittal initially avoided summons