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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

ITO Ward - 1(1), Kalyan vs. Shri Riten Kantilal Gada, Kalyan

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

ITA 2017/MUM/2020[2010-11]Status: DisposedITAT Mumbai06 Apr 2022AY 2010-11

Bench: Shri Pramod Kumar, Vp & Amarjit Singh, Am आयकर अपील सं/ I.T.A. No.2017/Mum/2020 (निर्धारण वर्ा / Assessment Year: 2010-11) Ito, Ward -1(1) बिधम/ Shri Riten Kantilal Gada 1St Floor, Mohan Plaza, F. No.202, Green Acres, Vs. Wayale Nagar, Kalyan West- Anjur Phata, Near Oswal Saga, Kamatghar Road, 421301. Bhiwandi-421302. & Cross Objection No.148/Mum/2021 आयकर अपील सं/ I.T.A. No. 2017/Mum/2020 (निर्धारण वर्ा / Assessment Year: 2010-11) Shri Riten Kantilal Gada बिधम/ Ito, Ward -1(1) 1St Floor, Mohan Plaza, F. No.202, Green Acres, Vs. Anjur Phata, Near Oswal Wayale Nagar, Kalyan West- Saga, Kamatghar Road, 421301. Bhiwandi-421302. स्थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Acmps3743C (अपीलाथी /Appellant) .. (प्रत्यथी / Respondent) Revenue By: Shri R.A. Dhyani (Sr. Ar) Assessee By: Shri Mayur J. Gosrani सुनवाई की तारीख / Date Of Hearing: 14/03/2022 घोषणा की तारीख /Date Of Pronouncement: 06/04/2022 आदेश / O R D E R Per Amarjit Singh, Jm: The Revenue As Well As Assessee Have Filed The Above Mentioned Appeal As Well As Cross-Objection Against The Order Dated 08.09.2020 Passed By The Commissioner Of Income Tax (Appeals)-02, Thane [Hereinafter Referred To As The “Cit(A)”] Relevant To The A.Y.2010-11. C.O. No.148/Mum/2021 A.Y.2010-11

For Appellant: Shri Mayur J. GosraniFor Respondent: Shri R.A. Dhyani (Sr. AR)
Section 143Section 147

relevant supporting documents related to movement of goods, stock register, etc. to restrict the addition to 25 % is estimated on so called alleged bogus purchases from the non-existent vendors. 2 C.O. No.148/Mum/2021 A.Y.2010-11 4. On the facts and in the circumstances of the case ... No.148/Mum/2021 A.Y.2010-11 7) The Ld. CIT(A) erred of fact as well as of law by restricting the estimated addition on so called bogus purchases to the extent of 25% without appreciating the fact that the gross profit of the appellant is around 4% only. Comparison of Gross Profit Ratio

M/S Ashok Khandelwal, Dhamtari vs. Deputy Commissioner of Income Tax, Circle 2(1), Raipur

In the result, appeal of the assessee is allowed in terms of our aforesaid observations

ITA 223/RPR/2017[2008-09]Status: DisposedITAT Raipur05 Apr 2022AY 2008-09

Bench: Shri Ravish Sood & Shri Jamlappa D Battullआयकर अपील सं. / Ita No. 223/Rpr/2017 "नधा"रण वष" / Assessment Year : 2008-09 M/S. Ashok Khandelwal Tulsi Bhawan, Opp. Nehru Garden, Ratnabandha Road, Dhamtari-493 773 (C.G.) Pan : Aaifa8368F .......अपीलाथ" / Appellant बनाम / V/S. The Deputy Commissioner Of Income Tax-2(1), Raipur (C.G.) ……""यथ" / Respondent Assessee By : Shri Sunil Kumar Agrawal, Ar Revenue By : Shri Sanjay Kumar, Dr सुनवाई क" तार"ख / Date Of Hearing :14.03.2022 घोषणा क" तार"ख / Date Of Pronouncement :05.04.2022

For Appellant: Shri Sunil Kumar Agrawal, ARFor Respondent: Shri Sanjay Kumar, DR
Section 143(3)Section 147Section 148

learned CIT(A) is not justified in sustaining addition f Rs.16,48,336/- made by the learned DCIT on the alleged ground of bogus purchase of Bitumen which is duly confirmed to have been purchased and used in the contract work by the subcontractor and contractee department ... DCIT is not justified in making addition of Rs.16,48,336/- which was not the basis for reopening the case u/s.148 as the alleged bogus purchase of Bitumen for Rs.486910/- mentioned in the reason for reopening the case u/s.148 was not found to have been claimed or debited

Shri Kushal R Jain, Surat vs. ITO-3(3)(3), Surat

In the result, appeals filed by the assessee in ITA Nos

ITA 215/SRT/2020[2007-08]Status: DisposedITAT Surat29 Mar 2022AY 2007-08

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita Nos. 420 & 504 /Srt/2019 ("नधा"रणवष" / Assessment Year: (2007-08) (Virtual Court Hearing) Shri Gautam Chunilal Jain, Vs. The Ito, Ward-2(3)(7), Prop. Of M/S Sai Star, 286, Laxmi Surat. Nagar Society, Nr. Tikam Nagar, Lambe Hanuman Road, Surat. (Assessee) (Revenue) The Ito, Ward-2(3)(7), Vs. Shri Gautam Chunilal Jain, Surat. Prop. Of M/S Sai Star, 286, Laxmi Nagar Society, Nr. Tikam Nagar, Lambe Hanuman Road, Surat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abhpl0577D (Revenue) (Assessee) आयकरअपीलसं./Ita Nos. 215/Srt/2020 & 575/Srt/2019 ("नधा"रणवष" / Assessment Year: (2007-08) Shri Kushal R. Jain, The Ito, Ward-3(3)(3), Vs. Prop. M/S Kunal Gems, C/O. Surat. 901, Rajhans Tower, Mini Bazar, Varachha, Surat. (Assessee) (Revenue) The Ito, Ward-3(3)(3), Vs. Shri Kushal R. Jain, Surat. Prop. M/S Kunal Gems, C/O. 901, Rajhans Tower, Mini Bazar, Varachha, Surat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Advpj6155B (Revenue) (Assessee) Assessee By Shri Himanshu Gandhi, Ca Shri H. P. Meena, Cit(Dr) Respondent By Date Of Hearing 21/03/2022 Date Of Pronouncement 29/03/2022 आदेश / O R D E R Per Dr. A. L. Saini, Am: Captioned Cross Appeals Filed By The Assessees & Revenue, Pertaining To Assessment Year (Ay) 2007-08, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-1, Surat [In Ita. 420 & 504, 575/Srt/2019 & 215/Srt/2020 Assessment Year: 2007-08 Gautam C. Jain & Kushal R. Jain Short “The Ld. Cit(A)”] Which In Turn Arise Out Of Separate Assessment Orders Passed By The Assessing Officer Under Section 143(3) R.W.S 147 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”).

Section 132(4)Section 143(3)

commission agent is not acceptable, it is only an attempt on the part of the assessee to avoid explanation for the bogus purchase. The assessee has debited in his books of accounts and consequently the tax liability which may arise as a result of disallowances of these purchases ... statement recorded under section 132(4) of the Income Tax Act, 1961. The Assessing Officer noted that Shri Gautam C. Jain, assessee made bogus purchases from Shri Rajendra Jain Group, Sanjay Group and Dharmchand Jain Group, amounting to Rs.42,22,03,472/-, therefore Assessing Officer disallowed all bogus purchases

ITO, Ward-3(3)(3), Surat vs. Kushal R Jain, Surat

In the result, appeals filed by the assessee in ITA Nos

ITA 575/SRT/2019[2007-08]Status: DisposedITAT Surat29 Mar 2022AY 2007-08

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita Nos. 420 & 504 /Srt/2019 ("नधा"रणवष" / Assessment Year: (2007-08) (Virtual Court Hearing) Shri Gautam Chunilal Jain, Vs. The Ito, Ward-2(3)(7), Prop. Of M/S Sai Star, 286, Laxmi Surat. Nagar Society, Nr. Tikam Nagar, Lambe Hanuman Road, Surat. (Assessee) (Revenue) The Ito, Ward-2(3)(7), Vs. Shri Gautam Chunilal Jain, Surat. Prop. Of M/S Sai Star, 286, Laxmi Nagar Society, Nr. Tikam Nagar, Lambe Hanuman Road, Surat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abhpl0577D (Revenue) (Assessee) आयकरअपीलसं./Ita Nos. 215/Srt/2020 & 575/Srt/2019 ("नधा"रणवष" / Assessment Year: (2007-08) Shri Kushal R. Jain, The Ito, Ward-3(3)(3), Vs. Prop. M/S Kunal Gems, C/O. Surat. 901, Rajhans Tower, Mini Bazar, Varachha, Surat. (Assessee) (Revenue) The Ito, Ward-3(3)(3), Vs. Shri Kushal R. Jain, Surat. Prop. M/S Kunal Gems, C/O. 901, Rajhans Tower, Mini Bazar, Varachha, Surat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Advpj6155B (Revenue) (Assessee) Assessee By Shri Himanshu Gandhi, Ca Shri H. P. Meena, Cit(Dr) Respondent By Date Of Hearing 21/03/2022 Date Of Pronouncement 29/03/2022 आदेश / O R D E R Per Dr. A. L. Saini, Am: Captioned Cross Appeals Filed By The Assessees & Revenue, Pertaining To Assessment Year (Ay) 2007-08, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-1, Surat [In Ita. 420 & 504, 575/Srt/2019 & 215/Srt/2020 Assessment Year: 2007-08 Gautam C. Jain & Kushal R. Jain Short “The Ld. Cit(A)”] Which In Turn Arise Out Of Separate Assessment Orders Passed By The Assessing Officer Under Section 143(3) R.W.S 147 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”).

Section 132(4)Section 143(3)

commission agent is not acceptable, it is only an attempt on the part of the assessee to avoid explanation for the bogus purchase. The assessee has debited in his books of accounts and consequently the tax liability which may arise as a result of disallowances of these purchases ... statement recorded under section 132(4) of the Income Tax Act, 1961. The Assessing Officer noted that Shri Gautam C. Jain, assessee made bogus purchases from Shri Rajendra Jain Group, Sanjay Group and Dharmchand Jain Group, amounting to Rs.42,22,03,472/-, therefore Assessing Officer disallowed all bogus purchases

ITO, Ward 2(3)(7), Surat vs. Gautamchand Chunilal Jain, Surat

In the result, appeals filed by the assessee in ITA Nos

ITA 504/SRT/2019[2007-08]Status: DisposedITAT Surat29 Mar 2022AY 2007-08

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita Nos. 420 & 504 /Srt/2019 ("नधा"रणवष" / Assessment Year: (2007-08) (Virtual Court Hearing) Shri Gautam Chunilal Jain, Vs. The Ito, Ward-2(3)(7), Prop. Of M/S Sai Star, 286, Laxmi Surat. Nagar Society, Nr. Tikam Nagar, Lambe Hanuman Road, Surat. (Assessee) (Revenue) The Ito, Ward-2(3)(7), Vs. Shri Gautam Chunilal Jain, Surat. Prop. Of M/S Sai Star, 286, Laxmi Nagar Society, Nr. Tikam Nagar, Lambe Hanuman Road, Surat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abhpl0577D (Revenue) (Assessee) आयकरअपीलसं./Ita Nos. 215/Srt/2020 & 575/Srt/2019 ("नधा"रणवष" / Assessment Year: (2007-08) Shri Kushal R. Jain, The Ito, Ward-3(3)(3), Vs. Prop. M/S Kunal Gems, C/O. Surat. 901, Rajhans Tower, Mini Bazar, Varachha, Surat. (Assessee) (Revenue) The Ito, Ward-3(3)(3), Vs. Shri Kushal R. Jain, Surat. Prop. M/S Kunal Gems, C/O. 901, Rajhans Tower, Mini Bazar, Varachha, Surat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Advpj6155B (Revenue) (Assessee) Assessee By Shri Himanshu Gandhi, Ca Shri H. P. Meena, Cit(Dr) Respondent By Date Of Hearing 21/03/2022 Date Of Pronouncement 29/03/2022 आदेश / O R D E R Per Dr. A. L. Saini, Am: Captioned Cross Appeals Filed By The Assessees & Revenue, Pertaining To Assessment Year (Ay) 2007-08, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-1, Surat [In Ita. 420 & 504, 575/Srt/2019 & 215/Srt/2020 Assessment Year: 2007-08 Gautam C. Jain & Kushal R. Jain Short “The Ld. Cit(A)”] Which In Turn Arise Out Of Separate Assessment Orders Passed By The Assessing Officer Under Section 143(3) R.W.S 147 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”).

Section 132(4)Section 143(3)

commission agent is not acceptable, it is only an attempt on the part of the assessee to avoid explanation for the bogus purchase. The assessee has debited in his books of accounts and consequently the tax liability which may arise as a result of disallowances of these purchases ... statement recorded under section 132(4) of the Income Tax Act, 1961. The Assessing Officer noted that Shri Gautam C. Jain, assessee made bogus purchases from Shri Rajendra Jain Group, Sanjay Group and Dharmchand Jain Group, amounting to Rs.42,22,03,472/-, therefore Assessing Officer disallowed all bogus purchases

Gautamchand Chunilal Jain, Surat vs. ITO, Ward-2(3)(7), Surat

In the result, appeals filed by the assessee in ITA Nos

ITA 420/SRT/2019[2007-08]Status: DisposedITAT Surat29 Mar 2022AY 2007-08

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita Nos. 420 & 504 /Srt/2019 ("नधा"रणवष" / Assessment Year: (2007-08) (Virtual Court Hearing) Shri Gautam Chunilal Jain, Vs. The Ito, Ward-2(3)(7), Prop. Of M/S Sai Star, 286, Laxmi Surat. Nagar Society, Nr. Tikam Nagar, Lambe Hanuman Road, Surat. (Assessee) (Revenue) The Ito, Ward-2(3)(7), Vs. Shri Gautam Chunilal Jain, Surat. Prop. Of M/S Sai Star, 286, Laxmi Nagar Society, Nr. Tikam Nagar, Lambe Hanuman Road, Surat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abhpl0577D (Revenue) (Assessee) आयकरअपीलसं./Ita Nos. 215/Srt/2020 & 575/Srt/2019 ("नधा"रणवष" / Assessment Year: (2007-08) Shri Kushal R. Jain, The Ito, Ward-3(3)(3), Vs. Prop. M/S Kunal Gems, C/O. Surat. 901, Rajhans Tower, Mini Bazar, Varachha, Surat. (Assessee) (Revenue) The Ito, Ward-3(3)(3), Vs. Shri Kushal R. Jain, Surat. Prop. M/S Kunal Gems, C/O. 901, Rajhans Tower, Mini Bazar, Varachha, Surat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Advpj6155B (Revenue) (Assessee) Assessee By Shri Himanshu Gandhi, Ca Shri H. P. Meena, Cit(Dr) Respondent By Date Of Hearing 21/03/2022 Date Of Pronouncement 29/03/2022 आदेश / O R D E R Per Dr. A. L. Saini, Am: Captioned Cross Appeals Filed By The Assessees & Revenue, Pertaining To Assessment Year (Ay) 2007-08, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-1, Surat [In Ita. 420 & 504, 575/Srt/2019 & 215/Srt/2020 Assessment Year: 2007-08 Gautam C. Jain & Kushal R. Jain Short “The Ld. Cit(A)”] Which In Turn Arise Out Of Separate Assessment Orders Passed By The Assessing Officer Under Section 143(3) R.W.S 147 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”).

Section 132(4)Section 143(3)

commission agent is not acceptable, it is only an attempt on the part of the assessee to avoid explanation for the bogus purchase. The assessee has debited in his books of accounts and consequently the tax liability which may arise as a result of disallowances of these purchases ... statement recorded under section 132(4) of the Income Tax Act, 1961. The Assessing Officer noted that Shri Gautam C. Jain, assessee made bogus purchases from Shri Rajendra Jain Group, Sanjay Group and Dharmchand Jain Group, amounting to Rs.42,22,03,472/-, therefore Assessing Officer disallowed all bogus purchases

Shri Manish Agarwal, Surat vs. The ITO, Ward-3(1)(5), Surat

In the result, assessee’s the appeals in ITA No

ITA 256/SRT/2017[2008-09]Status: DisposedITAT Surat29 Mar 2022AY 2008-09

Bench: Shri Pawan Singh, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita Nos.206 & 256/Srt/2017 (िनधा"रणवष" / Assessment Year: (2008-09) (Virtual Court Hearing) Income Tax Officer, Ward- Manish Agarwal 3(1)(5)Room No. 115, 1St Floor, 204, Vaibhav Chambers, Anavil Business Centre, Hajira Raghunathpura, Main Road, Road, Opp. Star Bazar, Adajan, Surat-395003 Surat-395009 Vs. Income Tax Officer, Ward- Manish Agarwal 3(1)(5), Aayakar Bhawan, 204, Vaibhav Chambers, Majura Gate, Surat Raghunathpura, Main Road,Surat-395003 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afwpa 2629 A (Appellant ) (Respondent)

For Appellant: Shri Suchek Anchalia, C.AFor Respondent: Shri H.P.Meena, CIT-DR
Section 143(3)

quashed. The Ld. AR of the assessee submits that for the year under consideration, the Assessing Officer made addition @ 25% of the disputed / bogus purchases. These purchases are from Shri Bhawarlal Jain Group. The Ld. AR drew our attention that grounds of appeal raised by assessee, on merits, are covered ... Tribunal, vide order dated 27.09.2021 in the case of Pankaj K. Choudhary & others, wherein the Co- ordinate Bench has sustained the addition @ 6%of bogus purchases. The Ld. AR contended that all these appeals are covered by the afore-said decision of the Co- ordinate Bench, in the case

Shri Ramprakash V. Vijayvergiya, Surat vs. The ITO, Ward-3(1)(5), Surat

In the result, assessee’s the appeals in ITA No

ITA 253/SRT/2017[2008-09]Status: DisposedITAT Surat29 Mar 2022AY 2008-09

Bench: Shri Pawan Singh, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita Nos.206 & 256/Srt/2017 (िनधा"रणवष" / Assessment Year: (2008-09) (Virtual Court Hearing) Income Tax Officer, Ward- Manish Agarwal 3(1)(5)Room No. 115, 1St Floor, 204, Vaibhav Chambers, Anavil Business Centre, Hajira Raghunathpura, Main Road, Road, Opp. Star Bazar, Adajan, Surat-395003 Surat-395009 Vs. Income Tax Officer, Ward- Manish Agarwal 3(1)(5), Aayakar Bhawan, 204, Vaibhav Chambers, Majura Gate, Surat Raghunathpura, Main Road,Surat-395003 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afwpa 2629 A (Appellant ) (Respondent)

For Appellant: Shri Suchek Anchalia, C.AFor Respondent: Shri H.P.Meena, CIT-DR
Section 143(3)

quashed. The Ld. AR of the assessee submits that for the year under consideration, the Assessing Officer made addition @ 25% of the disputed / bogus purchases. These purchases are from Shri Bhawarlal Jain Group. The Ld. AR drew our attention that grounds of appeal raised by assessee, on merits, are covered ... Tribunal, vide order dated 27.09.2021 in the case of Pankaj K. Choudhary & others, wherein the Co- ordinate Bench has sustained the addition @ 6%of bogus purchases. The Ld. AR contended that all these appeals are covered by the afore-said decision of the Co- ordinate Bench, in the case

The ITO, Ward-3(1)(5), Surat vs. Shri Manish Agarwal, Surat

In the result, assessee’s the appeals in ITA No

ITA 206/SRT/2017[2008-09]Status: DisposedITAT Surat29 Mar 2022AY 2008-09

Bench: Shri Pawan Singh, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita Nos.206 & 256/Srt/2017 (िनधा"रणवष" / Assessment Year: (2008-09) (Virtual Court Hearing) Income Tax Officer, Ward- Manish Agarwal 3(1)(5)Room No. 115, 1St Floor, 204, Vaibhav Chambers, Anavil Business Centre, Hajira Raghunathpura, Main Road, Road, Opp. Star Bazar, Adajan, Surat-395003 Surat-395009 Vs. Income Tax Officer, Ward- Manish Agarwal 3(1)(5), Aayakar Bhawan, 204, Vaibhav Chambers, Majura Gate, Surat Raghunathpura, Main Road,Surat-395003 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afwpa 2629 A (Appellant ) (Respondent)

For Appellant: Shri Suchek Anchalia, C.AFor Respondent: Shri H.P.Meena, CIT-DR
Section 143(3)

quashed. The Ld. AR of the assessee submits that for the year under consideration, the Assessing Officer made addition @ 25% of the disputed / bogus purchases. These purchases are from Shri Bhawarlal Jain Group. The Ld. AR drew our attention that grounds of appeal raised by assessee, on merits, are covered ... Tribunal, vide order dated 27.09.2021 in the case of Pankaj K. Choudhary & others, wherein the Co- ordinate Bench has sustained the addition @ 6%of bogus purchases. The Ld. AR contended that all these appeals are covered by the afore-said decision of the Co- ordinate Bench, in the case