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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

Kalpataru Projects International Ltd, Mumbai vs. DCIT, CC-3(3), Mumbai

In the result, the appeals by the assessee for the assessment years

ITA 5964/MUM/2025[2014-15]Status: DisposedITAT Mumbai24 Dec 2025AY 2014-15

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhail

For Appellant: Shri Vijay MehtaFor Respondent: Shri Ritesh Misra, CIT-DR
Section 147Section 148Section 250Section 37(1)

submitted that in this decision the Hon’ble High Court held that part disallowance upheld by the Tribunal on account of alleged bogus purchases is not justified once the purchases were found to be non-genuine. Accordingly, the learned DR submitted that the learned CIT(A) erred in upholding ... basis of the information received from the Sales Tax Department that the taxpayer is a beneficiary of an accommodation entry transaction of bogus purchases. Further, in the facts of the case, the Revenue alleged that in the guise of a bogus purchase transaction, unaccounted cash of the assessee was utilised

Kalpataru Projects International Ltd, Mumbai vs. DCIT, CC-3(3), Mumbai

In the result, the appeals by the assessee for the assessment years

ITA 5963/MUM/2025[2015-16]Status: DisposedITAT Mumbai24 Dec 2025AY 2015-16

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhail

For Appellant: Shri Vijay MehtaFor Respondent: Shri Ritesh Misra, CIT-DR
Section 147Section 148Section 250Section 37(1)

submitted that in this decision the Hon’ble High Court held that part disallowance upheld by the Tribunal on account of alleged bogus purchases is not justified once the purchases were found to be non-genuine. Accordingly, the learned DR submitted that the learned CIT(A) erred in upholding ... basis of the information received from the Sales Tax Department that the taxpayer is a beneficiary of an accommodation entry transaction of bogus purchases. Further, in the facts of the case, the Revenue alleged that in the guise of a bogus purchase transaction, unaccounted cash of the assessee was utilised

Kalpataru Projects International Ltd, Mumbai vs. DCIT, CC-3(3), Mumbai

In the result, the appeals by the assessee for the assessment years

ITA 5962/MUM/2025[2017-18]Status: DisposedITAT Mumbai24 Dec 2025AY 2017-18

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhail

For Appellant: Shri Vijay MehtaFor Respondent: Shri Ritesh Misra, CIT-DR
Section 147Section 148Section 250Section 37(1)

submitted that in this decision the Hon’ble High Court held that part disallowance upheld by the Tribunal on account of alleged bogus purchases is not justified once the purchases were found to be non-genuine. Accordingly, the learned DR submitted that the learned CIT(A) erred in upholding ... basis of the information received from the Sales Tax Department that the taxpayer is a beneficiary of an accommodation entry transaction of bogus purchases. Further, in the facts of the case, the Revenue alleged that in the guise of a bogus purchase transaction, unaccounted cash of the assessee was utilised

Sunita Grovar, Panipat, Haryana vs. Principal Commissioner of Income-Tax, Rohta, Rohtak Haryana

In the result, appeal of the assessee is allowed

ITA 3608/DEL/2025[2018-19]Status: DisposedITAT Delhi24 Dec 2025AY 2018-19

Bench: Shri Vimal Kumar & Smt. Renu Jauhriassessment Year: 2018-19 Sunita Grover, Vs. Principal Commissioner Of Income T-7, Industrial Area, Panipat, Tax, Rohtak Pin: 132 103 (Haryana) Haryana Pan: Afmpg8500N (Appellant) (Respondent)

Section 115BSection 147Section 263

Income of Rs. 3,34,73,817/- by making the following addition:- (i) Addition amounting to Rs. 3,26,88,657/- on account of bogus purchases including commission expenses. 3 2.1 In pursuant to order dated 13.03.2023 of Ld. Assessing Officer, Ld. PCIT issued notice on 06.02.2024 and 25.02.2025. Show ... adding it to the total income of the Appellant under s. 37(1) of the Act as bogus purchases. The Ld. AO also made a separate addition of Rs 48,302 for commission, charging it as unexplained expenditure under Section 69C of the Act. 4.1 Ld. PCIT, issued show cause

Dy Commissioner of Income Tax, Noida vs. Surender Gupta, Delhi

In the result, the appeal of the assessee is partly allowed and of the Revenue is dismissed as discussed hereinabove

ITA 2873/DEL/2025[2020-21]Status: DisposedITAT Delhi24 Dec 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalita Nos.1670 To 1672/Del/2025 (Assessment Years 2018-19, 2019-20 & 2020-21) Surender Gupta, Dy. Cit, A-27, Phase-1, Ashok Vihar, Central Circle-30, H.O. North West Delhi-110052. Vs. Delhi. Pan-Aaopg2234J (Appellant) (Respondent) Ita Nos.2871 To 2873/Del/2025 (Assessment Years 2018-19, 2019-20 & 2020-21) Dy. Cit, Surender Gupta, Central Circle-1, A-27, Phase-1, Ashok Vihar, Noida. Vs. H.O. North West Delhi-110052. Pan-Aaopg2234J (Appellant) (Respondent) Assessee By Shri Mayank Patwari, Adv. & Shri Aakash Ojha, Adv. Department By Ms. Rajinder Kaur, Cit-Dr Date Of Hearing 20.11.2025 Date Of Pronouncement 24.12.2025 O R D E R Per Manish Agarwal, Am: The Captioned Cross Appeals Are Filed By The Assessee & Revenue Against Three Separate Orders Of Ld. Commissioner Of Income Tax (Appeals)-30, New Delhi [“Ld. Cit(A) In Short”] U/S 250 Of The Income Tax Act, 1961 [“The Act In Short”], All Are Dated 24.02.2025 Against The Orders Of The Assessing Officer U/S 153A R.W.S Ita Nos.2871 To 2873/Del/2025 Surender Gupta Vs. Dcit 143(3) Of The Income Tax Act, 1961 (“The Act” For Short) For Assessment Years 2018-19, 2019-20 & 2020-21 Respectively.

Section 127Section 139(1)Section 153ASection 153DSection 250

total income of Rs.2,18,13,670/-. A search and seizure operation was carried out in respect of the beneficiary of accommodation entry of bogus purchase bills provided by Sanjay Jain group of which assessee is one of the beneficiaries. Accordingly, case of the assessee is centralized in terms ... deleting the addition to the extent of Rs.39,59,739- out of total addition of Rs.45,25,415/-made on account of bogus purchases by applying the G.P. rate & ignoring the incriminating material and corroborative evidence seized during the search, including statements under section 132(4), WhatsApp chats, and Tally

Dy. Commissioner of Income Tax, Central Circle-I, Noida vs. Surender Gupta, Delhi

In the result, the appeal of the assessee is partly allowed and of the Revenue is dismissed as discussed hereinabove

ITA 2872/DEL/2025[2019-20]Status: DisposedITAT Delhi24 Dec 2025AY 2019-20

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalita Nos.1670 To 1672/Del/2025 (Assessment Years 2018-19, 2019-20 & 2020-21) Surender Gupta, Dy. Cit, A-27, Phase-1, Ashok Vihar, Central Circle-30, H.O. North West Delhi-110052. Vs. Delhi. Pan-Aaopg2234J (Appellant) (Respondent) Ita Nos.2871 To 2873/Del/2025 (Assessment Years 2018-19, 2019-20 & 2020-21) Dy. Cit, Surender Gupta, Central Circle-1, A-27, Phase-1, Ashok Vihar, Noida. Vs. H.O. North West Delhi-110052. Pan-Aaopg2234J (Appellant) (Respondent) Assessee By Shri Mayank Patwari, Adv. & Shri Aakash Ojha, Adv. Department By Ms. Rajinder Kaur, Cit-Dr Date Of Hearing 20.11.2025 Date Of Pronouncement 24.12.2025 O R D E R Per Manish Agarwal, Am: The Captioned Cross Appeals Are Filed By The Assessee & Revenue Against Three Separate Orders Of Ld. Commissioner Of Income Tax (Appeals)-30, New Delhi [“Ld. Cit(A) In Short”] U/S 250 Of The Income Tax Act, 1961 [“The Act In Short”], All Are Dated 24.02.2025 Against The Orders Of The Assessing Officer U/S 153A R.W.S Ita Nos.2871 To 2873/Del/2025 Surender Gupta Vs. Dcit 143(3) Of The Income Tax Act, 1961 (“The Act” For Short) For Assessment Years 2018-19, 2019-20 & 2020-21 Respectively.

Section 127Section 139(1)Section 153ASection 153DSection 250

total income of Rs.2,18,13,670/-. A search and seizure operation was carried out in respect of the beneficiary of accommodation entry of bogus purchase bills provided by Sanjay Jain group of which assessee is one of the beneficiaries. Accordingly, case of the assessee is centralized in terms ... deleting the addition to the extent of Rs.39,59,739- out of total addition of Rs.45,25,415/-made on account of bogus purchases by applying the G.P. rate & ignoring the incriminating material and corroborative evidence seized during the search, including statements under section 132(4), WhatsApp chats, and Tally

Dy. Commissioner of Income Tax, Central Circle I Noida, Noida vs. Surender Gupta, Delhi

In the result, the appeal of the assessee is partly allowed and of the Revenue is dismissed as discussed hereinabove

ITA 2871/DEL/2025[2018-19]Status: DisposedITAT Delhi24 Dec 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalita Nos.1670 To 1672/Del/2025 (Assessment Years 2018-19, 2019-20 & 2020-21) Surender Gupta, Dy. Cit, A-27, Phase-1, Ashok Vihar, Central Circle-30, H.O. North West Delhi-110052. Vs. Delhi. Pan-Aaopg2234J (Appellant) (Respondent) Ita Nos.2871 To 2873/Del/2025 (Assessment Years 2018-19, 2019-20 & 2020-21) Dy. Cit, Surender Gupta, Central Circle-1, A-27, Phase-1, Ashok Vihar, Noida. Vs. H.O. North West Delhi-110052. Pan-Aaopg2234J (Appellant) (Respondent) Assessee By Shri Mayank Patwari, Adv. & Shri Aakash Ojha, Adv. Department By Ms. Rajinder Kaur, Cit-Dr Date Of Hearing 20.11.2025 Date Of Pronouncement 24.12.2025 O R D E R Per Manish Agarwal, Am: The Captioned Cross Appeals Are Filed By The Assessee & Revenue Against Three Separate Orders Of Ld. Commissioner Of Income Tax (Appeals)-30, New Delhi [“Ld. Cit(A) In Short”] U/S 250 Of The Income Tax Act, 1961 [“The Act In Short”], All Are Dated 24.02.2025 Against The Orders Of The Assessing Officer U/S 153A R.W.S Ita Nos.2871 To 2873/Del/2025 Surender Gupta Vs. Dcit 143(3) Of The Income Tax Act, 1961 (“The Act” For Short) For Assessment Years 2018-19, 2019-20 & 2020-21 Respectively.

Section 127Section 139(1)Section 153ASection 153DSection 250

total income of Rs.2,18,13,670/-. A search and seizure operation was carried out in respect of the beneficiary of accommodation entry of bogus purchase bills provided by Sanjay Jain group of which assessee is one of the beneficiaries. Accordingly, case of the assessee is centralized in terms ... deleting the addition to the extent of Rs.39,59,739- out of total addition of Rs.45,25,415/-made on account of bogus purchases by applying the G.P. rate & ignoring the incriminating material and corroborative evidence seized during the search, including statements under section 132(4), WhatsApp chats, and Tally

Surender Gupta, Delhi vs. DCIT, Central Circle-30, Delhi

In the result, the appeal of the assessee is partly allowed and of the Revenue is dismissed as discussed hereinabove

ITA 1672/DEL/2025[2020-21]Status: DisposedITAT Delhi24 Dec 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalita Nos.1670 To 1672/Del/2025 (Assessment Years 2018-19, 2019-20 & 2020-21) Surender Gupta, Dy. Cit, A-27, Phase-1, Ashok Vihar, Central Circle-30, H.O. North West Delhi-110052. Vs. Delhi. Pan-Aaopg2234J (Appellant) (Respondent) Ita Nos.2871 To 2873/Del/2025 (Assessment Years 2018-19, 2019-20 & 2020-21) Dy. Cit, Surender Gupta, Central Circle-1, A-27, Phase-1, Ashok Vihar, Noida. Vs. H.O. North West Delhi-110052. Pan-Aaopg2234J (Appellant) (Respondent) Assessee By Shri Mayank Patwari, Adv. & Shri Aakash Ojha, Adv. Department By Ms. Rajinder Kaur, Cit-Dr Date Of Hearing 20.11.2025 Date Of Pronouncement 24.12.2025 O R D E R Per Manish Agarwal, Am: The Captioned Cross Appeals Are Filed By The Assessee & Revenue Against Three Separate Orders Of Ld. Commissioner Of Income Tax (Appeals)-30, New Delhi [“Ld. Cit(A) In Short”] U/S 250 Of The Income Tax Act, 1961 [“The Act In Short”], All Are Dated 24.02.2025 Against The Orders Of The Assessing Officer U/S 153A R.W.S Ita Nos.2871 To 2873/Del/2025 Surender Gupta Vs. Dcit 143(3) Of The Income Tax Act, 1961 (“The Act” For Short) For Assessment Years 2018-19, 2019-20 & 2020-21 Respectively.

Section 127Section 139(1)Section 153ASection 153DSection 250

total income of Rs.2,18,13,670/-. A search and seizure operation was carried out in respect of the beneficiary of accommodation entry of bogus purchase bills provided by Sanjay Jain group of which assessee is one of the beneficiaries. Accordingly, case of the assessee is centralized in terms ... deleting the addition to the extent of Rs.39,59,739- out of total addition of Rs.45,25,415/-made on account of bogus purchases by applying the G.P. rate & ignoring the incriminating material and corroborative evidence seized during the search, including statements under section 132(4), WhatsApp chats, and Tally

Surender Gupta, Delhi vs. DCIT, Central Circle-30, Delhi

In the result, the appeal of the assessee is partly allowed and of the Revenue is dismissed as discussed hereinabove

ITA 1671/DEL/2025[2019-20]Status: DisposedITAT Delhi24 Dec 2025AY 2019-20

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalita Nos.1670 To 1672/Del/2025 (Assessment Years 2018-19, 2019-20 & 2020-21) Surender Gupta, Dy. Cit, A-27, Phase-1, Ashok Vihar, Central Circle-30, H.O. North West Delhi-110052. Vs. Delhi. Pan-Aaopg2234J (Appellant) (Respondent) Ita Nos.2871 To 2873/Del/2025 (Assessment Years 2018-19, 2019-20 & 2020-21) Dy. Cit, Surender Gupta, Central Circle-1, A-27, Phase-1, Ashok Vihar, Noida. Vs. H.O. North West Delhi-110052. Pan-Aaopg2234J (Appellant) (Respondent) Assessee By Shri Mayank Patwari, Adv. & Shri Aakash Ojha, Adv. Department By Ms. Rajinder Kaur, Cit-Dr Date Of Hearing 20.11.2025 Date Of Pronouncement 24.12.2025 O R D E R Per Manish Agarwal, Am: The Captioned Cross Appeals Are Filed By The Assessee & Revenue Against Three Separate Orders Of Ld. Commissioner Of Income Tax (Appeals)-30, New Delhi [“Ld. Cit(A) In Short”] U/S 250 Of The Income Tax Act, 1961 [“The Act In Short”], All Are Dated 24.02.2025 Against The Orders Of The Assessing Officer U/S 153A R.W.S Ita Nos.2871 To 2873/Del/2025 Surender Gupta Vs. Dcit 143(3) Of The Income Tax Act, 1961 (“The Act” For Short) For Assessment Years 2018-19, 2019-20 & 2020-21 Respectively.

Section 127Section 139(1)Section 153ASection 153DSection 250

total income of Rs.2,18,13,670/-. A search and seizure operation was carried out in respect of the beneficiary of accommodation entry of bogus purchase bills provided by Sanjay Jain group of which assessee is one of the beneficiaries. Accordingly, case of the assessee is centralized in terms ... deleting the addition to the extent of Rs.39,59,739- out of total addition of Rs.45,25,415/-made on account of bogus purchases by applying the G.P. rate & ignoring the incriminating material and corroborative evidence seized during the search, including statements under section 132(4), WhatsApp chats, and Tally

Surender Gupta, Delhi vs. DCIT, Central Circle-30, Delhi

In the result, the appeal of the assessee is partly allowed and of the Revenue is dismissed as discussed hereinabove

ITA 1670/DEL/2025[2018-19]Status: DisposedITAT Delhi24 Dec 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalita Nos.1670 To 1672/Del/2025 (Assessment Years 2018-19, 2019-20 & 2020-21) Surender Gupta, Dy. Cit, A-27, Phase-1, Ashok Vihar, Central Circle-30, H.O. North West Delhi-110052. Vs. Delhi. Pan-Aaopg2234J (Appellant) (Respondent) Ita Nos.2871 To 2873/Del/2025 (Assessment Years 2018-19, 2019-20 & 2020-21) Dy. Cit, Surender Gupta, Central Circle-1, A-27, Phase-1, Ashok Vihar, Noida. Vs. H.O. North West Delhi-110052. Pan-Aaopg2234J (Appellant) (Respondent) Assessee By Shri Mayank Patwari, Adv. & Shri Aakash Ojha, Adv. Department By Ms. Rajinder Kaur, Cit-Dr Date Of Hearing 20.11.2025 Date Of Pronouncement 24.12.2025 O R D E R Per Manish Agarwal, Am: The Captioned Cross Appeals Are Filed By The Assessee & Revenue Against Three Separate Orders Of Ld. Commissioner Of Income Tax (Appeals)-30, New Delhi [“Ld. Cit(A) In Short”] U/S 250 Of The Income Tax Act, 1961 [“The Act In Short”], All Are Dated 24.02.2025 Against The Orders Of The Assessing Officer U/S 153A R.W.S Ita Nos.2871 To 2873/Del/2025 Surender Gupta Vs. Dcit 143(3) Of The Income Tax Act, 1961 (“The Act” For Short) For Assessment Years 2018-19, 2019-20 & 2020-21 Respectively.

Section 127Section 139(1)Section 153ASection 153DSection 250

total income of Rs.2,18,13,670/-. A search and seizure operation was carried out in respect of the beneficiary of accommodation entry of bogus purchase bills provided by Sanjay Jain group of which assessee is one of the beneficiaries. Accordingly, case of the assessee is centralized in terms ... deleting the addition to the extent of Rs.39,59,739- out of total addition of Rs.45,25,415/-made on account of bogus purchases by applying the G.P. rate & ignoring the incriminating material and corroborative evidence seized during the search, including statements under section 132(4), WhatsApp chats, and Tally

Amrit Varsha Udyog Ltd, Kotdwar vs. DCIT Circle 1, Dehradun

In the result, the Appeal of the Assessee is dismissed

ITA 2/DDN/2025[2018-19]Status: DisposedITAT Dehradun23 Dec 2025AY 2018-19

Bench: Sh. Yogesh Kumar U.S. & Sh. Manish Agarwal

For Appellant: NoneFor Respondent: Sh. A. S. Rana, Sr. DR
Section 147Section 148Section 69C

vide order dated 30.09.2022. 5.2 Further the AO has re-opened the assessment u/s. 147 of the IT Act on the issue of bogus purchases made to the extent of Rs. 49,13,825/- from M/s Shri) Ganpati Enterprises, Rs. Rs.15,10,506/- from M/s Delhi Steel Trading ... didn’t accept the assessee’s contention and the re-assessment was concluded making the addition of Rs. 1,17,24,405/- towards the bogus purchases.” 3. Aggrieved by the assessment order, Assessee preferred an Appeal before the ld. CIT(A). The ld. CIT(A) vide order dated 18.11.2024, confirmed

Jalpa Uttapal Patel, Ahmedabad vs. The Pr.CIT, Ahmedabad-1, Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 720/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad23 Dec 2025AY 2018-19

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.720/Ahd/2025 िनधा"रण वष" /Assessment Year : 2018-19 Jalpa Uttapal Patel The Pr.Cit बनाम/ N Y Steel Corporation Ahmedabad-1 V/S. 6 Puja Apartment Ahmedabad – 380 015 Vrundavan Colony Opp. Sardar Patel Hospital Maninagar Ahmedabad – 380 008 "थायी लेखा सं./Pan: Baxpp 4020 K (अपीलाथ%/ Appellant) (&' यथ%/ Respondent) Assessee By : Shri Biren Shah, Ar Revenue By : Shri Sher Singh, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 30 /09/2025 घोषणा की तारीख /Date Of Pronouncement: 23/12/2025 आदेश/O R D E R Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Revision Order Passed By The Principal Commissioner Of Income Tax, Ahmedabad-1 (Hereinafter Referred To As “Pcit”) Dated 26/03/2025 U/S.263 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Year (Ay) 2018-19. 2. The Assessee, In This Appeal, Has Contested The Very Exercise Of Revision Jurisdiction By The Ld. Pcit U/S.263 Of The Act. Jalpa Uttapal Patel Vs. Pcit Asst.Year : 2018-19 2

For Appellant: Shri Biren Shah, ARFor Respondent: Shri Sher Singh, CIT-DR
Section 143(1)Section 147Section 263Section 69C

said information, it was found that the assessee had carried undisclosed transactions to the tune of Rs.1,84,15,750/- in the form of bogus purchase and sale from M/s. Kapishwar Steels in the year under consideration. On the basis of said information, the assessment in the case ... Rs.6,61,49,926/- from M/s. Kapishwar Steel. However, the AO had failed to add the sum of Rs.6,61,49,926/- as bogus purchases as the assessee had transacted with M/s.Kapishwar Steel. This reasoning given by the PCIT is neither justifiable nor sufficient for exercise of revision jurisdiction u/s.263

Arcoy Industries (India) Private Limited, Ahmedabad vs. The DCIT, Circle-1(1)(1), Ahmedabad

In the result, all the captioned four appeals of the assessee are hereby allowed

ITA 427/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad23 Dec 2025AY 2017-18

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

For Respondent: Shri Alpesh Parmar, CIT-DR
Section 147Section 148Section 153CSection 250Section 68

bogus transactions with paper concerns of Rajeev Shah, Milind Shah & Jeevan jagatiya. He provided tables containing details of the bogus concerns through which the bogus purchases and bogus sales have been made. Thus, the money given for purchase of the goods to the parties is returned through bogus sales ... mentioned certain specific transactions stated by Shri Chirag Thakkar to be bogus transactions of purchases and sales. Referring to tables containing details of the bogus purchases and sales transactions, he pointed out that the purchase made from Overseas Polymers Pvt. Ltd., Anshul agencies, Faith Innovation, Lakeland Chemical

Arcoy Industries (India) Private Limited, Ahmedabad vs. The DCIT, Circle-1(1)(1), Ahmedabad

In the result, all the captioned four appeals of the assessee are hereby\nallowed

ITA 426/AHD/2024[2015-16]Status: DisposedITAT Ahmedabad23 Dec 2025AY 2015-16
For Appellant: \nShri S.N. Soparkar, Sr.AdvocateFor Respondent: \nShri Alpesh Parmar, CIT-DR
Section 147Section 148Section 153CSection 250Section 68

bogus transactions with paper concerns of\nRajeev Shah, Milind Shah & Jeevan jagatiya. He provided tables containing details\nof the bogus concerns through which the bogus purchases and bogus sales have been\nmade. Thus, the money given for purchase of the goods to the parties is returned\nthrough bogus sales ... mentioned certain specific transactions stated by Shri\nChirag Thakkar to be bogus transactions of purchases and sales. Referring to\ntables containing details of the bogus purchases and sales transactions, he\npointed out that the purchase made from Overseas Polymers Pvt. Ltd., Anshul\nagencies, Faith Innovation, Lakeland Chemical

Arcoy Industries (India) Private Limited, Ahmedabad vs. The DCIT, Circle-1(1)(1), Ahmedabad

In the result, all the captioned four appeals of the assessee are hereby allowed

ITA 425/AHD/2024[2014-15]Status: DisposedITAT Ahmedabad23 Dec 2025AY 2014-15

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

For Respondent: Shri Alpesh Parmar, CIT-DR
Section 147Section 148Section 153CSection 250Section 68

bogus transactions with paper concerns of Rajeev Shah, Milind Shah & Jeevan jagatiya. He provided tables containing details of the bogus concerns through which the bogus purchases and bogus sales have been made. Thus, the money given for purchase of the goods to the parties is returned through bogus sales ... mentioned certain specific transactions stated by Shri Chirag Thakkar to be bogus transactions of purchases and sales. Referring to tables containing details of the bogus purchases and sales transactions, he pointed out that the purchase made from Overseas Polymers Pvt. Ltd., Anshul agencies, Faith Innovation, Lakeland Chemical

Arcoy Industries (India) Private Limited, Ahmedabad vs. The DCIT, Circle-1(1)(1), Ahmedabad

In the result, all the captioned four appeals of the assessee are hereby allowed

ITA 424/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad23 Dec 2025AY 2013-14

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

For Respondent: Shri Alpesh Parmar, CIT-DR
Section 147Section 148Section 153CSection 250Section 68

bogus transactions with paper concerns of Rajeev Shah, Milind Shah & Jeevan jagatiya. He provided tables containing details of the bogus concerns through which the bogus purchases and bogus sales have been made. Thus, the money given for purchase of the goods to the parties is returned through bogus sales ... mentioned certain specific transactions stated by Shri Chirag Thakkar to be bogus transactions of purchases and sales. Referring to tables containing details of the bogus purchases and sales transactions, he pointed out that the purchase made from Overseas Polymers Pvt. Ltd., Anshul agencies, Faith Innovation, Lakeland Chemical

Bermaco Energy System Limited, Mumbai vs. DCIT, Central Circle 8(4), Mubmai

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

ITA 6878/MUM/2025[2009-10]Status: DisposedITAT Mumbai23 Dec 2025AY 2009-10

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Respondent: Shri Leyaqat Ali Aafaqui, Sr. AR
Section 132Section 132(4)Section 143(3)Section 250Section 271(1)(c)Section 274Section 69C

failed to appreciate that the addition sustained by the CIT(A) in the quantum proceedings was on an adhoc/estimated basis at 8% of alleged bogus purchases, which cannot be the basis for levy of penalty under section 271(1)(c) of the Act. 4. The Appellant craves leave ... crores u/s. 132(4) of the Act for various years in which there were discrepancies found in the books of accounts by way of bogus purchases, unaccounted cash etc. The statement of Shri Viren Ahuja recorded u/s. 132(4) of the Act was retracted subsequently on 24.11.2009. The Learned Assessing

Bermaco Energy System Limited, Mumbai vs. DCIT Central Circle, Mumbai

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

ITA 6877/MUM/2025[2008-09]Status: DisposedITAT Mumbai23 Dec 2025AY 2008-09

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Respondent: Shri Leyaqat Ali Aafaqui, Sr. AR
Section 132Section 132(4)Section 143(3)Section 250Section 271(1)(c)Section 274Section 69C

failed to appreciate that the addition sustained by the CIT(A) in the quantum proceedings was on an adhoc/estimated basis at 8% of alleged bogus purchases, which cannot be the basis for levy of penalty under section 271(1)(c) of the Act. 4. The Appellant craves leave ... crores u/s. 132(4) of the Act for various years in which there were discrepancies found in the books of accounts by way of bogus purchases, unaccounted cash etc. The statement of Shri Viren Ahuja recorded u/s. 132(4) of the Act was retracted subsequently on 24.11.2009. The Learned Assessing

Bermaco Energy System Limited, Mumbai vs. DCIT, Central Circle 8(4), Mumbai

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

ITA 6876/MUM/2025[2007-08]Status: DisposedITAT Mumbai23 Dec 2025AY 2007-08
Section 132Section 132(4)Section 143(3)Section 250Section 271(1)(c)Section 274Section 69C

failed to appreciate that the addition sustained by the\nCIT(A) in the quantum proceedings was on an adhoc/estimated basis at 8% of\nalleged bogus purchases, which cannot be the basis for levy of penalty under section\n271(1)(c) of the Act.\n4. The Appellant craves leave ... Rs.38.90 crores u/s.132(4) of the Act for various years in which there\nwere discrepancies found in the books of accounts by way of bogus purchases, unaccounted\ncash etc. The statement of Shri Viren Ahuja recorded u/s.132(4) of the Act was retracted\nsubsequently on 24.11.2009. The Learned Assessing Officer

Bermaco Energy System Limited, Mumbai vs. DCIT, Central Circle 8(4), Mumbai

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

ITA 6875/MUM/2025[2006-07]Status: DisposedITAT Mumbai23 Dec 2025AY 2006-07

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Respondent: Shri Leyaqat Ali Aafaqui, Sr. AR
Section 132Section 132(4)Section 143(3)Section 250Section 271(1)(c)Section 274Section 69C

failed to appreciate that the addition sustained by the CIT(A) in the quantum proceedings was on an adhoc/estimated basis at 8% of alleged bogus purchases, which cannot be the basis for levy of penalty under section 271(1)(c) of the Act. 4. The Appellant craves leave ... crores u/s. 132(4) of the Act for various years in which there were discrepancies found in the books of accounts by way of bogus purchases, unaccounted cash etc. The statement of Shri Viren Ahuja recorded u/s. 132(4) of the Act was retracted subsequently on 24.11.2009. The Learned Assessing