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“bogus purchases”

DisallowancesSection 69CSection 69C9,532 judgments

The decision most relied on for bogus purchases is CIT v. Simit P. Sheth (356 ITR 451), cited in 1,465 judgments on BharatTax.

Leading authorities on bogus purchases

CIT v. Simit P. Sheth
356 ITR 451 · 2013 · High Court
1,465
citing judgments

Additions for alleged bogus purchases should be restricted to the profit element, not the entire turnover. The profit element is often estimated at 12.5% of the purported 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.

CIT v. Nikunj Exim Enterprises Pvt. Ltd.
372 ITR 619 · 2015 · High Court
391
citing judgments

Transactions defying human probability cannot be applied to isolated purchases if sales are accepted as genuine, and purchases cannot be disallowed without considering the entire transaction and documentary evidence. Failure to produce parties in an assessment proceeding may not be fatal to the assessee.

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.

Judgments citing bogus purchases

Asst CIT Cir 2, Kalyan vs. Ketankumar Jayantibhai Patel, Ambernath

In the result, both the appeal of the assessee and Revenue are partly allowed

ITA 5237/MUM/2015[2010-11]Status: DisposedITAT Mumbai29 May 2018AY 2010-11

Bench: Shri C.N. Prasad, Hon'Ble & Shri Rajesh Kumar, Hon'Ble

For Appellant: Shri Vimal PunmiyaFor Respondent: Shri M.C. Omi Ningshan

only issue in both the appeals of the assessee and Revenue is in respect of partly deleting the addition made towards bogus purchases. 3. At the outset, Ld. Counsel for the assessee submitted that an identical issue came up before the Tribunal for the immediately preceding Assessment Year ... Tribunal restricted the addition/disallowance to 2% on the alleged bogus purchases. Copy of the order is placed on record. Ld. Counsel also submitted that the parties are identical, therefore the same may be followed for the year under appeal. 4. Ld. DR strongly placed reliance on the order

Ketankumar J Patel, Mumbai vs. DCIT Cir 2, Mumbai

In the result, both the appeal of the assessee and Revenue are partly allowed

ITA 5041/MUM/2015[2010-11]Status: DisposedITAT Mumbai29 May 2018AY 2010-11

Bench: Shri C.N. Prasad, Hon'Ble & Shri Rajesh Kumar, Hon'Ble

For Appellant: Shri Vimal PunmiyaFor Respondent: Shri M.C. Omi Ningshan

only issue in both the appeals of the assessee and Revenue is in respect of partly deleting the addition made towards bogus purchases. 3. At the outset, Ld. Counsel for the assessee submitted that an identical issue came up before the Tribunal for the immediately preceding Assessment Year ... Tribunal restricted the addition/disallowance to 2% on the alleged bogus purchases. Copy of the order is placed on record. Ld. Counsel also submitted that the parties are identical, therefore the same may be followed for the year under appeal. 4. Ld. DR strongly placed reliance on the order

ITO 25(3)(2), Mumbai vs. Kaushik Kumar Sumanla Vakharia, Mumbai

In the result, the appeal of the revenue are dismissed

ITA 2621/MUM/2013[2009-10]Status: DisposedITAT Mumbai29 May 2018AY 2009-10

Bench: Shri C N Prasad & Shri Rajesh Kumarita No.2621/Mum/2013 Assessment Year : 2009-10 Ita No.2380/Mum/2012 Assessment Year : 2008-09

For Appellant: Shri M C Omi NingshenFor Respondent: Shri N M Porwal
Section 133(6)Section 143(3)

grounds is against the deletion of the addition by the CIT(A) of Rs.1,38,29,815/- as made by the Assessing Officer towards bogus purchases from M/s. Dharnendra Associates and directing to adopt gross profit rate of @0.74% of the turnover without considering the facts on record ... ground that even if the ratio laid down by the various Benches of the Tribunal, directing the addition to be sustained @12.5% of the bogus purchases, even then the addition would be Rs.17,25,000/- whereas in the present case, the CIT(A) has sustained the addition to the tune

ITO 25(3)(2), Mumbai vs. Kaushik Kumar Sumanlal Vakharia, Mumbai

In the result, the appeal of the revenue are dismissed

ITA 2380/MUM/2012[2008-09]Status: DisposedITAT Mumbai29 May 2018AY 2008-09

Bench: Shri C N Prasad & Shri Rajesh Kumarita No.2621/Mum/2013 Assessment Year : 2009-10 Ita No.2380/Mum/2012 Assessment Year : 2008-09

For Appellant: Shri M C Omi NingshenFor Respondent: Shri N M Porwal
Section 133(6)Section 143(3)

grounds is against the deletion of the addition by the CIT(A) of Rs.1,38,29,815/- as made by the Assessing Officer towards bogus purchases from M/s. Dharnendra Associates and directing to adopt gross profit rate of @0.74% of the turnover without considering the facts on record ... ground that even if the ratio laid down by the various Benches of the Tribunal, directing the addition to be sustained @12.5% of the bogus purchases, even then the addition would be Rs.17,25,000/- whereas in the present case, the CIT(A) has sustained the addition to the tune

Shri Sudeep Mahendrabhai Shah, Surat vs. The Income Tax Officer, Ward1(3)(5), Surat

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

ITA 2423/AHD/2016[2008-09]Status: DisposedITAT Surat28 May 2018AY 2008-09

Bench: Shri C.M.Garg & Shri O.P.Meena

Section 132(4)Section 143Section 147Section 148

Income Tax (Appeals) has erred in confirming the action of the assessing officer in making addition of Rs.1,42,56,361/- on account of bogus purchases. 2. On the facts and circumstances of the case as well as law on the subject, the learned Commissioner of Income Tax (Appeals ... relates to confirming the action of the 18. Assessing Officer in making addition of Rs.1,42,56,361/- on account of bogus purchases without admitting additional evidence filed under Rule 46A . The short facts are that the assessee earned income from business 19. of trading of diamond in proprietary concern

Shanteelal Chenaramji Joshi, Nashik vs. Income-Tax Officer, Nashik

In the result, appeal of the assessee is partly allowed

ITA 949/PUN/2017[2010-11]Status: DisposedITAT Pune25 May 2018AY 2010-11

Bench: Shri D. Karunakara Rao, Am

For Appellant: Shri Sanket JoshiFor Respondent: Shri Pankaj Garg
Section 143(3)Section 147Section 148

assessment proceedings u/s.143(3) r.w.s. 147 of the Act, the AO made addition of Rs.26,58,213/- on account of the said bogus purchases. Aggrieved with the order of AO, the assessee filed an appeal before the CIT(A) challenging the validity of notice issued u/s.148 ... well as the addition on account of bogus purchases amounting to Rs.26,58,213/-. 4. During the First Appellate proceedings, with regard to the first issue i.e. validity of notice issuing u/s.148 of the Act, CIT(A) noted that as the assessee failed to furnish full details in response

Firoz Ahmed Moh. Motin Choudhary, Pune vs. Income-Tax Officer, Pune

In the result, appeal of the assessee is partly allowed

ITA 942/PUN/2017[2010-11]Status: DisposedITAT Pune25 May 2018AY 2010-11

Bench: Shri D. Karunakara Rao, Am

For Appellant: Shri Dinesh R. GulbaniFor Respondent: Shri Pankaj Garg
Section 143(3)Section 145(3)Section 148Section 41(1)Section 69C

Traders. Otherwise, the AO allowed the purchases to the extent the payment was made. In my view, such an approach in matters relating to bogus purchases involving the information received from Sales Tax Department, is not sustainable. I find making entire addition of Rs.28,54,540/- is not appropriate ... rate of such suspected purchases and also the applicability of the catena of decisions on this issue. 9. I find that similar issue of bogus purchases has been decided by the Tribunal in series of decisions. Further, it is not the case of the Revenue that something is wrong with

Income Tax Officer vs. M/S. Trinity Steel Profiles Pvt. Ltd, Nashik

In the result, the Cross Objection of the assessee is partly allowed

ITA 2985/PUN/2016[2011-12]Status: DisposedITAT Pune25 May 2018AY 2011-12

Bench: Shri D. Karunakara Rao, Am

For Appellant: Shri Pankaj GargFor Respondent: Shri Sanket Joshi

received from Sales Tax Department. The AO after considering the submission of the assessee held that purchases made from hawala dealers tantamount to bogus purchase and made an addition of Rs.81,48,113/-, Rs.1,16,48,157/- & Rs.25,73,189/- for the A.Ys. 2009-10, 2010-11 & 2011-12 respectively ... that no averment on sale is made cannot be overlooked. Considering the totality of facts, in my view, this is not a case of bogus purchase but rather a case of bogus parties. It is possible that assessee has over invoiced his purchase to reduce his taxable income. In steel

Mohemadmustafa A. Khan, Nashik vs. Income Tax Officer

In the result, appeal of the assessee is partly allowed

ITA 2970/PUN/2016[2011-12]Status: DisposedITAT Pune25 May 2018AY 2011-12

Bench: Shri D. Karunakara Rao, Am

For Appellant: Shri Sanket JoshiFor Respondent: Shri Pankaj Garg

order and the same reads as under : “6.13 Thus, in my opinion the facts on record demonstrate that this is not a case of bogus purchase but a case of inflated purchases and at best from bogus parties. The appellant has purchased goods of Rs.2,17,199/- and Rs.18 ... that in view of the plethora of decisions of the Pune Bench of the Tribunal, the addition may be restricted to 10% of the bogus purchases. In support of the same, Ld. Counsel for the assessee also filed a copy of the order of Tribunal in ITA No.1732/PUN/2015

Deputy Commissioner of Income-Tax vs. M/S. Satyam Developers, Navi Mumbai

In the result, the appeal by the Revenue is partly allowed in the terms aforesaid

ITA 1226/PUN/2015[2010-11]Status: DisposedITAT Pune25 May 2018AY 2010-11

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm

For Appellant: Shri Sharad ShahFor Respondent: Shri Achal Sharma
Section 143(2)

additions have been made on the ground that the assessee has made 4 ITA No. 1226/PUN/2015 & CO No. 32/PUN/2018, A.Y. 2010-11 bogus purchases from Hawala dealers. Once, the Department has accepted that the parties are genuine, no addition in respect of purchases made from such parties should be suspected ... appeal by the Department is against deleting addition of Rs.86,43,221/- by the Commissioner of Income Tax (Appeals) alleged to be bogus purchases. During assessment proceedings, the Assessing Officer observed that the assessee had made purchases from 21 parties. The substantial number of parties (17) figured in the list

Meena Jewellers Private Limited, Hyderabad vs. Asst. Commissioner of Income Tax, Circle-16(2), Hyderabad

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

ITA 2016/HYD/2017[2013-14]Status: DisposedITAT Hyderabad25 May 2018AY 2013-14

Bench: Smt. P. Madhavi Devi & Shri B. Ramakotaiahm/S. Meena Jewellers Vs Asst. Commissioner Of Private Limited Income Tax, Circle 16(2) Hyderabad Hyderabad Pan: Aafcm1756R (Appellant) (Respondent)

For Appellant: Shri P. Murali Mohan RaoFor Respondent: Smt. Geetender Mann, DR
Section 131Section 132Section 143(3)

additions made by the Assessing officer towards disallowance of the purchases. 4. The Ld. CIT (A) erred in upholding the disallowance of the alleged bogus purchases amounting to Rs. 24,91,1501- without considering the facts of the case and the submission made by the assessee and without even referring ... clear that these two companies are only issuing accommodating entries without there being actual sale and therefore, the AO was justified in disallowing the bogus purchases. 5. Having regard to the rival contentions and the material on record, we find that the assessee has made the payments to the parties

Konark Structural Engg Private Limited, Mumbai vs. Principal Commissioner of Income Tax-12, Mumbai

In the result, the appeal of assessee is allowed

ITA 5488/MUM/2017[2009-10]Status: DisposedITAT Mumbai25 May 2018AY 2009-10

Bench: Sri Mahavir Singh, Jm & Sri Manoj Kumar Aggarwal, Am

For Appellant: Revenue by B Sriniwas, DR
Section 143(3)Section 147Section 148Section 263

issued for escapement of income for the reason that the AO received information for DGIT(Investigation) that assessee is indulging in bogus purchases and for the issuance of this notice the AO recorded the following reasons :- “the return of income was filed by the assessee ... information has been received from DGIT (Inv.) that the Sales Tax Department has informed that the assessee indulged in accounting the bogus purchase bills without actual delivery of goods. In this case under consideration as per the information provided by the Sales Tax Department the assessee has availed the bills

Income Tax Officer-25(3)(4), Mumbai vs. S.R.Jewels, Mumbai

In the result, Revenue’s appeal is allowed for statistical purposes

ITA 5405/MUM/2017[2009-10]Status: DisposedITAT Mumbai25 May 2018AY 2009-10

Bench: Shri Saktijit Dey & Shri Manoj Kumar Aggarwalincome Tax Officer ……………. Appellant Circle–25(3)(4), Mumbai V/S S.R. Jewels 2Nd Floor, Shanta Bhavan ……………. Respondent Opp. Railway Station, Vile Parle (W) Mumbai 400 056 Pan – Aayfs8159E

For Appellant: NoneFor Respondent: Ms. N. Hemlatha
Section 132Section 147Section 68

submissions of the assessee that the amount in question represents value of polished diamonds purchased by the assessee, proceeded to treat it as bogus purchase. However, he was of the view that only the profit element embedded in such purchases has to be brought to tax. Thereafter, referring ... benign assessment procedure (BAP) 3 S.R. Jewels Scheme, the learned Commissioner (Appeals) restricted the addition to 3% of the alleged bogus purchases. 5. When the appeal was called for hearing, no one was present for the assessee. Even, there is no request for adjournment of appeal. In view

Hiralal Motilal Jewellers, Kolkata vs. ACIT, Circle - 43, Kolkata

In the result, the appeal of the assessee is allowed

ITA 104/KOL/2018[2007-08]Status: DisposedITAT Kolkata24 May 2018AY 2007-08

Bench: Shri P.M. Jagtap, Am] I.T.A. No. 104/Kol/2018 Assessment Year: 2007-08 Hiralal Motila Jewellers................................………………………………………...............Appellant C/O D.J. Shah & Co., Kalyan Bhavan, 2, Elgin Road, Kolkata – 700 020 [Pan: Aadfh 8943 E] Acit Circle 43 Kolkata...................……………………………………………..................Respondent 3, Govt. Place (West), Kolkata – 700 001. Appearances By: Shri Miraj D. Shah, Ar Appearing On Behalf Of The Assessee. Shri A.K. Bandopadhya, Addl. Cit Appearing On Behalf Of The Revenue. Date Of Concluding The Hearing : April 11, 2018 Date Of Pronouncing The Order : May 24, 2018 Order This Appeal Filed By The Assessee Is Directed Against The Order Of Ld. Cit (Appeals) – 13, Kolkata Dated 25.09.2017. 2. The Assessee In The Present Case Is A Partnership Firm Which Is Carrying On The Business Of Jewelers. The Return Of Income For The Year Under Consideration Was Filed By It Originally On 31.10.2007 Declaring A Total Income Of Rs. 5,20,450/-. The Said Return Was Initially Accepted By The A.O. Under Section U/S 143(1) On 27.02.2009. The A.O, Thereafter Received Information That M/S. Vitrag Jewels Was One Of The Firms Providing Bogus Entries. In His Statement Recorded By The Department, Shri Rajendra Jain, Employee Of The Said Concern Confessed That He Was Managing Various Concerns In Order To Provide Bogus Sale Bills To Domestic Concerns For The Diamonds. He Stated That The Concerns Which Were Purchasing Diamond In Cash From Grey

Section 143(1)Section 143(3)Section 148

assessment as well as disputing the addition made 3 I.T.A. No. 104/Kol/2018 Assessment Year: 2007-08 Hiralal Motilal Jewellers therein on account of alleged bogus purchases. The Ld. CIT(A) however did not find merit in the case of the assesses on both the issues and after upholding the validity ... under section 143(3)/147 of the Act, he also confirmed the addition made by the A.O. on account of the alleged bogus purchases for the following reasons given in his impugned order: “In this case it is clear that the aforesaid concern M/s. Vitrag Jewels has not actually purchased

JCIT, (OSD), Cir-2(2), Kolkata vs. M/S West Bengal Tourism Development Corporation Ltd., Kolkata

Appeal is dismissed

ITA 636/KOL/2016[2009-2010]Status: DisposedITAT Kolkata24 May 2018AY 2009-2010

Bench: Shri S.S.Godara & Dr. A.L. Sainiassessment Year :2009-10 Jcit(Osd), Circle-2(2), V/S. M/S West Bengal Tourism Aayakar Bhawan, P-7, Development Corporation Chowringhee Sqr. Ltd., 12, Hemanta Bhawan, 4Th Floor, B.B.D. Kolkta-69 Bag East, Kolkata- 001 [Pan No.Aaacw 3093 Q] .. अपीलाथ" /Appellant ""यथ"/Respondent Shri S. Dasgupta, Addl. Cit-Dr अपीलाथ" क" ओर से/By Appellant Shri G.R. Saha, Advocate ""यथ" क" ओर से/By Respondent 16-05-2018 सुनवाई क" तार"ख/Date Of Hearing 24-05-2018 घोषणा क" तार"ख/Date Of Pronouncement आदेश /O R D E R Per S.S.Godara:- This Revenue’S Appeal For Assessment Year 2009-10 Arises Against Commissioner Of Income Tax (Appeals)-10, Kolkata’S Order Dated 22.01.201, Passed In Appeal No.406/Cit(A)-10/Cir.2/2014-15/Kol, In Proceedings U/S 143(3) Of The Income Tax Act, 1961; In Short As ‘The Act’.

Section 133(6)Section 143(3)Section 277Section 44A

made the following submission:- ‘The Third Ground of appeal relates to an amount of Rs.45,25,959 which according to the AO represents “Bogus Purchases”. He held so on the basis of confirmations obtained behind the back of the Appellant from the concerned creditors. His inference is based on some

Gagandeep Maan, Pune vs. Deputy Commissioner of Income Tax, Pune

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

ITA 656/PUN/2017[2009-10]Status: DisposedITAT Pune23 May 2018AY 2009-10

Bench: Shri Anil Chaturvedi, Am & Shri Vikas Awasthy, Jm

For Appellant: Shri V.L. JainFor Respondent: Smt. Nirupama Kotru
Section 143(3)Section 148

Officer vide order dated 05-03-2014. Thereafter, the Assessing Officer passed assessment order making addition of Rs.31,35,79,329/- on account of bogus purchases made by the assessee from Hawala operators. Aggrieved by the assessment order dated 16-03-2015 passed u/s. 143(3) r.w.s ... Revenue in appeal has assailed the order of Commissioner of Income Tax (Appeals) in deleting substantial addition (90%) in respect of bogus purchases. 5. Shri V.L. Jain appearing on behalf of the assessee submitted that the Assessing Officer has wrongly assumed jurisdiction u/s. 148 to reopen the assessment. The reassessment

Income-Tax Officer, Pune vs. Shri Gagandeep Amarpal Maan, Pune

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

ITA 1078/PUN/2017[2009-10]Status: DisposedITAT Pune23 May 2018AY 2009-10

Bench: Shri Anil Chaturvedi, Am & Shri Vikas Awasthy, Jm

For Appellant: Shri V.L. JainFor Respondent: Smt. Nirupama Kotru
Section 143(3)Section 148

Officer vide order dated 05-03-2014. Thereafter, the Assessing Officer passed assessment order making addition of Rs.31,35,79,329/- on account of bogus purchases made by the assessee from Hawala operators. Aggrieved by the assessment order dated 16-03-2015 passed u/s. 143(3) r.w.s ... Revenue in appeal has assailed the order of Commissioner of Income Tax (Appeals) in deleting substantial addition (90%) in respect of bogus purchases. 5. Shri V.L. Jain appearing on behalf of the assessee submitted that the Assessing Officer has wrongly assumed jurisdiction u/s. 148 to reopen the assessment. The reassessment

P.P. Enterprises, Panvel vs. Income-Tax Officer, Panvel

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

ITA 1010/PUN/2017[2009-10]Status: DisposedITAT Pune23 May 2018AY 2009-10

Bench: Shri D. Karunakara Rao, Am

For Appellant: NoneFor Respondent: Shri Pankaj Garg
Section 143(2)Section 144Section 148Section 250(6)

circumstances of the case and in law, the learned CIT(A) erred in confirming the addition of Rs.17,69,894 on account of alleged bogus purchase. Looking to the facts and in the circumstances of the case and in law the Appellant submits that Learned CIT(A) ought to have ... adjudicate the issue on merits. Otherwise, there is an addition of Rs.17,69,894/- made by the AO in this case on account of bogus purchases. 3. Before me, there is none to represent the assessee despite the service of notice. Acknowledgement is placed on record. However, considering the smallness

Lalji Jetsi Maheshwari, Nashik vs. Assistant Commissioner of Income-Tax

In the result, appeal of the assessee is partly allowed

ITA 860/PUN/2016[2011-12]Status: DisposedITAT Pune23 May 2018AY 2011-12

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपील आयकर अपील संसंसंसं. / Ita No.860/Pun/2016 आयकर आयकर अपील अपील िनधा"रण वष" िनधा"रण वष" / Assessment Year : 2011-12 िनधा"रण िनधा"रण वष" वष" Laiji Jetsi Maheshwari, C/O. Maheshwari Steel Mart, Saikheda Chaufulu, Agra Road, Oar (Mig), Nashik – 422 206 अपीलाथ"/Appellant Pan : Akfpm3322C …. Vs. Acit, Central –I, …. ""यथ" / Respondent Nahsik Assessee By : Shri Harshal A. Nasikkar Revenue By : Shri Achal Sharma सुनवाई क" तारीख / घोषणा क" तारीख / Date Of Hearing : 07.05.2018 Date Of Pronouncement: 23.05.2018

For Appellant: Shri Harshal A. NasikkarFor Respondent: Shri Achal Sharma
Section 133ASection 143(3)

unrecorded sales at Rs.13,48,747/-. 2. The Ld.CIT(A) further erred in sustaining addition of Rs.6,83,046/- on account of bogus purchases. 3. The appellant craves leave to add to, alter, amend or withdraw any of the grounds of appeal at the time of hearing.” 3. Briefly stated ... Addition on account of unexplained cash – Rs. 1,00,000/- Addition on account of unaccounted income-Rs.15,43,670/- Addition on account of bogus purchases – Rs.6,83,046/- ----------------------------- Total Addition Rs.36,74,863/- ----------------------------- 4. Assessee challenged the additions made by the AO before the CIT(A) by filing

Jewelry Unlimited, Mumbai vs. Income Tax Officer 23(2)(1), Mumbai

The appeals stand partly allowed

ITA 651/MUM/2018[2008-09]Status: DisposedITAT Mumbai23 May 2018AY 2008-09

Bench: Shri Saktijit Dey, Jm & Shri Manoj Kumar Aggarwal, Am

For Appellant: Pradip N. Kapasi, Ld.ARFor Respondent: N. Hemalatha, Ld. DR
Section 133(6)Section 143(3)Section 147

Commissioner of Income- Tax (Appeals)-33 [CIT(A)], Mumbai, Appeal No.CIT(A)- 33/Rg.23/17/89/90/91/2015 dated 14/11/2017 qua confirmation of certain additions on account of alleged bogus purchases. The assessment for all ITA.Nos.650-653/Mum/2018 Jewelry Unlimited Assessment Years- 2007-08 to 2010-11 these years has been framed ... read with Section 147 of the Income Tax Act, 1961. Since common issue of estimation of addition against alleged bogus purchase is involved in all the appeals, the same are being disposed-off by way of this common order for the sake of convenience & brevity. 2. The facts as emerging