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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

DCIT, Central Circle -3, Thane vs. Dodhia Synthetics Limited, Bhiwandi

The appeal of the assessee is Allowed on the

ITA 2105/MUM/2025[2014-15]Status: DisposedITAT Mumbai17 Sept 2025AY 2014-15
Section 143(3)Section 147Section 250Section 68

raised by the assessee in the written submissions before us or before lower authorities. Disallowance u/s 37(1) of the Act on account of bogus purchases. [Relevant for AY 2014-15 and AY 2015-16] 42. On this issue, both the parties have filed cross appeals. We noted that ... seized bundle number 3,8 and 9 from the premises of Shri Divesh Dhanani, the Assessing Officer has made an addition on account of bogus purchases by assessee from V.V. Dyechem P Limited. It is submitted by the assessee that during the assessment proceedings to prove the genuineness

Nidhika Rehani, New Delhi vs. ACIT, Circle 5(2)(2), Noida

In the result, appeal of the assessee is partly allowed

ITA 2236/DEL/2023[2017-18]Status: DisposedITAT Delhi17 Sept 2025AY 2017-18

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2017-18] Mrs. Nidhika Rehani, Vs Acit, G-7, Sector-6, Gautam Budh Circle-5(2)(2), Nagar, Noida, U.P.-201301. G.B.Nagar, Noida Pan-Arjpg8733C Appellant Respondent Appellant By Ms. Rano Jain, Adv., Ms. Mansi Jain, Ca & Ms. Shakshi Rustagi, Adv. Respondent By Shri Dheeraj Kumar Jain, Sr.Dr Date Of Hearing 23.06.2025 Date Of Pronouncement 17.09.2025 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By Assessee Against The Order Dated 27.06.2023 Passed By Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (“Nfac”), Delhi [“Ld.Cit(A)”] In Appeal No. Cit(Appeal) Ghaziabad/10645/2019-20 U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 21.12.2019 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2017-18. 2. Brief Facts Of The Case Are That Assessee Is An Individual & E- Filed Her Return Of Income On 31.10.2017, Declaring Total Income Of Inr 32,08,530/-.The Assessee Is Engaged In The Manufacturing & Trading Of Readymade Garments & Is Sole Proprietor Of M/S. Dsyngreen. Based On The Information Available On Record That Assessee Has Made Cash Deposits In The Bank Accounts During Demonetization In Specified Bank Notes (Sbn), Case Of The Assessee Was Taken Up For Scrutiny. After Considering The Submissions Made, Assessment Was Completed U/S 143(3) At A Total Income Of Inr 2,03,49,108/- By Making Following Additions/Disallowances:-

Section 143(3)Section 250Section 68Section 69Section 69C

Assessing Office making disallowance of aggregate amount of Rs 35.32.65% of purchases debited to the profit and loss account treating the same as bogus purchases. The appellant contends that on the facts and in the circumstances of the case and in law, the CIT(A) ought not to have upheld

DCIT, Circle-14(2), New Delhi vs. Kohinoor Foods Ltd., Faridabad

In the result, the Revenue’s appeal as well as Assessee’s Appeal stand dismissed in the aforesaid manner

ITA 587/DEL/2020[2011-12]Status: DisposedITAT Delhi17 Sept 2025AY 2011-12

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay, Accoutant Member Dcit, Circle-14(2), New Delhi Vs. M/S Kohinoor Foods Ltd. 10Th Floor, Pinnacle Room No. 323, C.R. Building, New Delhi – 2 Business Tower, Suraj Kund Road, Faridabad Haryana-121001 (Pan: Aaacs2470D) (Appellant) (Respondent) & M/S Kohinoor Foods Ltd. Vs. Acit, Circle 14(2), 10Th Floor, Pinnacle New Delhi Business Tower, Suraj Kund Road, Faridabad, Haryana-121001 (Pan: Aaacs2470D) (Appellant) (Respondent) Assessee By : S/Sh. Salil Kapoor, Utkarsha Kumar Gupta, Ms. Soumya Singh, Advocates Department By : Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing 28.08.2025 Date Of Pronouncement 17.09.2025

For Appellant: S/Sh. Salil Kapoor, Utkarsha KumarFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Section 147Section 68Section 92C

deleting the balance addition of Rs. 8,11,18,773/- made by AO on account of taking accommodation entry in the form of bogus purchases from M/s Rajdhani Sales Corporation. 2. That on the facts and circumstances of the case and in law, the Ld. CIT(A) has erred ... estimating gross profit 2 19.93% (GP ratio) on the said bogus purchases, despite of confirming that the assessee has neither substantiate the purchase nor the sales of specific purchase made from M/s Rajdhani Sales Corporation. 2. Brief facts of the case are that the assessee had filed its return

Kohinoor Foods Ltd., Faridabad vs. ACIT, Circle-14(2), New Delhi

In the result, the Revenue’s appeal as well as Assessee’s Appeal stand dismissed in the aforesaid manner

ITA 149/DEL/2020[2011-12]Status: DisposedITAT Delhi17 Sept 2025AY 2011-12

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay, Accoutant Member Dcit, Circle-14(2), New Delhi Vs. M/S Kohinoor Foods Ltd. 10Th Floor, Pinnacle Room No. 323, C.R. Building, New Delhi – 2 Business Tower, Suraj Kund Road, Faridabad Haryana-121001 (Pan: Aaacs2470D) (Appellant) (Respondent) & M/S Kohinoor Foods Ltd. Vs. Acit, Circle 14(2), 10Th Floor, Pinnacle New Delhi Business Tower, Suraj Kund Road, Faridabad, Haryana-121001 (Pan: Aaacs2470D) (Appellant) (Respondent) Assessee By : S/Sh. Salil Kapoor, Utkarsha Kumar Gupta, Ms. Soumya Singh, Advocates Department By : Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing 28.08.2025 Date Of Pronouncement 17.09.2025

For Appellant: S/Sh. Salil Kapoor, Utkarsha KumarFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Section 147Section 68Section 92C

deleting the balance addition of Rs. 8,11,18,773/- made by AO on account of taking accommodation entry in the form of bogus purchases from M/s Rajdhani Sales Corporation. 2. That on the facts and circumstances of the case and in law, the Ld. CIT(A) has erred ... estimating gross profit 2 19.93% (GP ratio) on the said bogus purchases, despite of confirming that the assessee has neither substantiate the purchase nor the sales of specific purchase made from M/s Rajdhani Sales Corporation. 2. Brief facts of the case are that the assessee had filed its return

Anil K. Shah HUF, Mumbai vs. Income Tax Officer Ward 41(2), Mumbai

In the result, the appeal of the assessee is allowed

ITA 3630/MUM/2025[2009-10]Status: DisposedITAT Mumbai16 Sept 2025AY 2009-10

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjeeassessment Year : 2009-10 Anil K. Shah (Huf), Income Tax Officer, 703, Supershav, Nahur Road, Ward-41(2)(1), Sarvodaya Nagar, Vs. Room No. 636, Mulund (West), Kautilya Bhavan, Mumbai-400080. Bandra Kurla Complex, Pan : Aadha5072M Bandra East, Mumbai-400051. (Appellant) (Respondent) For Assessee : Shri Devendra Jain & Shri Shashank Mehta For Revenue : Shri Surendra Mohan, Sr.Dr Date Of Hearing : 10-09-2025 Date Of Pronouncement : 16-09-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-National Faceless Appeal Centre (Nfac), Delhi [„Ld.Cit(A)‟], Dated 25-04-2025, Pertaining To Assessment Year (Ay) 2009-10, Challenging The Sustenance Of Levy Of Penalty Of Rs. 6,96,096/- U/S. 271(1)(C) Of The Income Tax Act, 1961 („The Act‟).

For Appellant: Shri Devendra Jain &For Respondent: Shri Surendra Mohan, Sr.DR
Section 143(3)Section 148Section 271(1)(c)

wherein the assessed income was determined at Rs. 5,38,54,780/-, after making various additions, including additions on account of bogus purchases amounting to Rs. 17,19,214/-. Thereafter, the assessee carried the matter in appeal before the Ld.CIT(A) and thereafter before the Tribunal and the Co-ordinate ... were held as „bogus‟. At the same time, the AO was directed to restrict the addition @12.5% of the total bogus purchases and the remaining addition was directed to be deleted. The AO subsequently, gave the appeal effect order to the Tribunal order vide his order dt.02-02-2021 followed by rectification

Ashok Nariyani, Jaipur vs. ACIT, Circle-5, Jaipur

In the result, the appeal of the assessee is allowed

ITA 1532/JPR/2024[2017-18]Status: DisposedITAT Jaipur15 Sept 2025AY 2017-18
For Appellant: Sh.Deepak Sharma, Adv. &For Respondent: Mrs. Anita Rinesh, JCIT, Sr.-DR
Section 115BSection 131Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 68

fact, the AO neither found any concrete and conclusive evidence of back dating of the entries of sales, evidence of bogus sales, evidence of bogus purchases, and non-existing cash balance in the books of account Similar observations were made by ITAT, Jaipur Bench, in the case of Raj Kumar

Trustar Diamonds, Mumbai vs. Assistant Commissioner of Income Tax-19(3), Lalbaug

In the result, the appeal is partly allowed

ITA 868/MUM/2025[2012-13]Status: DisposedITAT Mumbai15 Sept 2025AY 2012-13

Bench: Ms. Kavitha Rajagopal & Shri Prabhash Shankartrustar Diamonds V/S. Assistant Commissioner Of Ec 3070, Bharat Diamond बनाम Income Tax– 19(3), 5Th Floor, Bourse, Bkc, Mumbai – Piramal Chambers, Lalbaug, 400051, Maharashtra Mumbai–400012, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aafft7349N Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Ms. Krupali Mehta, ARFor Respondent: Shri Hemanshu Joshi (Sr.AR)
Section 147Section 250Section 271(1)(c)

completed on assessed income of Rs. 7,32,72,363/- after addition of Rs. 6,62,48,443/- on account of bogus purchase of diamond being accommodation entries. Consequently, penalty proceedings under section 271(1)(c) were initiated for concealment of particulars of income and furnishing inaccurate particulars of income ... component of the transaction can be added in the income thus addition is restricted to the extent of fair estimation of profit arising from bogus purchases. Thus, the appellate authorities have not absolved the assessee from the default of bogus purchases. The AO, while levying the impugned penalty has clearly

Roshanlal Khichi, Ahmedabad vs. The ITO, Ward-6(1)(1), Ahmedabad

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

ITA 501/AHD/2025[2021-22]Status: DisposedITAT Ahmedabad12 Sept 2025AY 2021-22

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Respondent by: Shri Abhijit, Sr. DRFor Respondent: Shri Abhijit, Sr. DR
Section 133(6)Section 143(2)Section 68

issuance of notice u/s 143(2) of the Act. It is clear from the assessment order that credible information was available with Department regarding bogus purchases and hence the case was selected for scrutiny. In order to provide appellant an opportunity to produce evidence on which the appellant may rely

Deputy Commissioner of Income Tax, Central Circle 2, Trichy, Income Tax Office vs. Ramasamy Sivaprakasam, Karur

ITA 1267/CHNY/2025[2016-17]Status: DisposedITAT Chennai12 Sept 2025AY 2016-17

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr. M.K. Rangaswamy, CAFor Respondent: Ms. Anitha, Addl. CIT
Section 131Section 133ASection 250Section 37Section 37(1)

relevant portions of his statement at Pages 20-22 of the assessment order. With these observations, the AO is noted to have quantified the bogus purchases at Rs.2,22,77,459/- out of the total purchases and show caused the assessee as to why it should not be disallowed ... were made from bogus parties. Having held so, the Ld. CIT(A) however disagreed with the AO’s action of disallowing 100% of the bogus purchases. The Ld. CIT(A) observed that the assessee had furnished quantitative analysis of purchases and sales in response to the show cause notice, which

Deputy Commissioner of Income Tax, Income Tax Office, Trichy vs. Ramasamy Sivaprakasam, Karur

ITA 1266/CHNY/2025[2014-15]Status: DisposedITAT Chennai12 Sept 2025AY 2014-15

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr. M.K. Rangaswamy, CAFor Respondent: Ms. Anitha, Addl. CIT
Section 131Section 133ASection 250Section 37Section 37(1)

relevant portions of his statement at Pages 20-22 of the assessment order. With these observations, the AO is noted to have quantified the bogus purchases at Rs.2,22,77,459/- out of the total purchases and show caused the assessee as to why it should not be disallowed ... were made from bogus parties. Having held so, the Ld. CIT(A) however disagreed with the AO’s action of disallowing 100% of the bogus purchases. The Ld. CIT(A) observed that the assessee had furnished quantitative analysis of purchases and sales in response to the show cause notice, which

Ajay Kumar Gupta, Panipat vs. Income Tax Officer, Ward- 1, Panipat

In the result, the Appeal of the Assessee is partly allowed for

ITA 1529/DEL/2025[2018-19]Status: DisposedITAT Delhi12 Sept 2025AY 2018-19

Bench: S. Rifaur Rahman & Shri Yogesh Kumar U.S.Ajay Kumar Gupta, Vs Income Tax Officer, 106, M/S Aggarwal Yarn Ward-1, House, S. D. College Road, Panipat, Haryana Panipat, Haryana-132103 Pan: Aappg0343K Appellant Respondent Assessee By Sh. Amit Kaushik, Adv, Sh. Himanshu Sharma, Itp Revenue By Sh. Dheeraj Kumar Jain, Sr. Dr Date Of Hearing 03/09/2025 Date Of Pronouncement 12/09/2025 Order Per Yogesh Kumar, U.S. Jm: The Present Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income Tax (Appeals/ National Faceless Appeal Centre (‘Ld. Cit(A)/Nfac’ For Short), New Delhi Dated 10/01/2025 For The Assessment Year 2018-19. 2. Brief Facts Of The Case Are That, An Assessment Order Came To Be Passed On 08/03/2023 Passed U/S 147 R.W. Section 144B Of Income Tax Act, 1961 ('Act' For Short), By Computing The Income Of The Assessee At Rs. 69,77,220/-, As Against The Returned Income Of Rs. 11,70,620/- By Making Disallowance Of Rs. 58,06,600/- On Account Of Bogus Purchases. Aggrieved By The Assessment Order Dated Ajay Kumar Gupta Vs. Ito

Section 144BSection 147

against the returned income of Rs. 11,70,620/- by making disallowance of Rs. 58,06,600/- on account of bogus purchases. Aggrieved by the assessment order dated Ajay Kumar Gupta Vs. ITO 08/03/2023, the Assessee preferred the Appeal before the Ld. CIT(A). The Ld. CIT(A) vide order

Dy. Commissioner of Income Tax, Kitchlu Nagar vs. Abir Knits Pvt. Ltd., Focal Point

In the result, appeal of the Revenue is dismissed

ITA 496/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh11 Sept 2025AY 2018-19

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: NoneFor Respondent: Shri Manav Bansal, CIT, DR
Section 115BSection 133ASection 144Section 145(3)Section 251(1)(a)Section 271A

reasoning of the Ld. CIT(A). The approach ensures that the issues raised in the assessment, particularly with respect to unsecured loans and alleged bogus purchases, are adjudicated afresh after granting the assessee an adequate opportunity of being heard. Accordingly, we uphold the findings

ITO-19(2)(2), Mumbai vs. M/S. Kobe Steel India, Mumbai

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

ITA 5623/MUM/2024[2011-12]Status: DisposedITAT Mumbai10 Sept 2025AY 2011-12

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Vimal Punmiya, ARFor Respondent: Shri Hemanshu Joshi (Sr. DR)
Section 143(3)Section 69C

parties declared as hawala traders who were bogus traders and not doing any genuine business, but were involved in providing only accommodation entries of bogus purchases ?” 2. “Whether on the facts and in the circumstances of the case and in law, Ld. CIT(A) has erred in deleting the entire ... Steel India of the assessee One such case is Srl. Ganesh Rice Mills Vs. CIT 294 ITR 316 (All), wherein the entire amount of bogus purchases, from the hawala parties, was disallowed and same was also upheld ?” 8. Whether on the facts and in the circumstances of the case

DCIT-14(1)(1), Mumbai vs. Miniboss Consultancy Pvt. Ltd., Mumbai

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

ITA 5306/MUM/2024[2021-22]Status: DisposedITAT Mumbai10 Sept 2025AY 2021-22

Bench: Shri Narendra Kumar Billaiya, Hon’Ble & Shri Anikesh Banerjee, Hon’Ble

For Appellant: Revenue byFor Respondent: Ms. Kavita Kaushik, Sr. D/R
Section 142(1)Section 68

reminders during the entire assessment proceedings. The returned income was assessed at Rs. 2,86,40,872/- after making additions on account of bogus purchases Rs. 2,02,45,042/-. In respect of other liabilities of Rs. 24,34,200/- and in respect of additions in the capital account

Arvind Kumar, Panipat vs. PCIT, Rohtak

In the result, appeal of assessee in ITA No

ITA 2178/DEL/2025[2018-19]Status: DisposedITAT Delhi09 Sept 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Shri Dhruv Goel, CAFor Respondent: Shri Jitender Singh, CIT-DR
Section 115BSection 147Section 148Section 263Section 37Section 69C

binding force not covered under the doctrine of merger finds force. The question before Gujarat High Court was regarding quantum of addition of bogus purchases i.e. 100% or 25% and section of disallowance (s.69C or s.37) was never in dispute. 13. We also find that the Assessing Officer

Chaudhary Trading Co Private Limited, Delhi vs. Income Tax Officer, Delhi

Appeal is allowed

ITA 2077/DEL/2025[2018-19]Status: DisposedITAT Delhi09 Sept 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2018-19 Vs. Income Tax Officer, Chaudhary Trading Co. Pvt. Ltd., Ward-6(1), Plot No. 121, Gali No.2, Assam Delhi Timber Market, Mundka, Delhi Pan: Aaccc0648K (Appellant) (Respondent) Assessee By Sh. R.R. Singla, Ca Department By Sh. Mahesh Kumar, Cit(Dr)

Section 263

Proteins Ltd. Vs. DCIT (2017) 84 taxmann.com 195 (SC) that the Assessing Officer’s foregoing action disallowing only a portion of the assessee’s bogus purchases than that in entirety is erroneous action causing prejudice to the interest of the Revenue. He has accordingly revised the foregoing assessment finding ... that the learned PCIT’s sole exception to the assessment findings hereinabove is only qua disallowance of the assessee’s bogus purchases quantification i.e @ 12.5% made by the Assessing Officer. That being the case, learned CIT(DR) could hardly dispute that the hon’ble apex court landmark decision settling

Ashish Bhargava, Jaipur vs. DCIT, Jaipur

In the result, the appeal of the assessee is allowed

ITA 875/JPR/2025[2017-18]Status: DisposedITAT Jaipur08 Sept 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

For Appellant: Shri Vinok Kumar Gupta, C.AFor Respondent: Shri Dharam Singh Meena, JCIT
Section 115BSection 139Section 143(2)Section 143(3)Section 145(3)Section 68

also neither doubted the availability of stock with the assessee prior to cash sales nor there is any allegation of any bogus purchases which means the ld. AO was satisfied that the assessee was having sufficient stock in hand for making the impugned sales during the demonetization period. Therefore ... making the impugned sales during the demonetization period and it is not the case of the Assessing Officer that the assessee has shown bogus purchases to show bogus sales to cover up cash deposited during the demonetization period” 12. We also see that

Air Wind Green Energy Limited, Bhavnagar vs. The PCIT, Ahmedabad -1, Ahmedabad

In the result, appeal filed by the assessee is allowed

ITA 615/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad08 Sept 2025AY 2018-19

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), SHRI T.R. SENTHIL KUMAR (Judicial Member)

For Appellant: Shri Varis Isani, AdvocateFor Respondent: Shri Sher Singh, CIT.DR
Section 147Section 263Section 270A(9)Section 37Section 69C

jurisdiction to revise the assessment order passed in the case of the assessee u/s.147 of the Act noting that the AO had erroneously disallowed bogus purchases made by the assessee ITA No. 615/Ahd/2025 [Air Wind Green Energy Limited vs. PCIT] A.Y. 2018-19 - 3 – u/s.37 (1) of the Act while ... PCIT held that there was no error in the order of the AO for not invoking Section 69C of the Act while disallowing the bogus purchases made by the assessee. However, he went on to hold that since admittedly the assessee had taken bogus accommodation entry of purchases

Narayan Suppliers Pvt. Ltd., Kolkata vs. I.T.O., Ward - 6(3), Kolkata

In the result, appeal of the assessee is dismissed

ITA 1077/KOL/2024[2011-2012]Status: DisposedITAT Kolkata08 Sept 2025AY 2011-2012

Bench: Shri George Mathan & Shri Rakesh Mishra

For Appellant: Shri Avijit Ghoshal, ARFor Respondent: Shri Raja Sengputa, CIT-DR
Section 10(38)

reopened without proper 'reason to believe'. If the reasons state that the information received from the VAT Dept. that the assessee entered into bogus purchases "needed deep verification", it means the Assessing Officer is reopening for doing a 'fishing or roving inquiry' without proper reason to believe, which

Gauge 16 Kitchen Equipments, Bangalore vs. Income Tax Officer Ward 5(2)(4), Bangalore

In the result, appeal of the assessee is allowed

ITA 1680/BANG/2024[2018-19]Status: DisposedITAT Bangalore08 Sept 2025AY 2018-19

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2018-19

For Appellant: Sri Balram R Rao, A.RFor Respondent: Sri Balusamy N., D.R
Section 143(2)Section 143(3)Section 250

agency of REIC i.e. Commercial Tax Department, Karnataka that the assessee is one of the beneficiaries of bogus GST billing. The assessee had received Bogus purchase entries of Rs.50,35,980/- thereby reducing its tax liability. The modus operandi adopted was that the fictitious bills/invoices were generated along with ... were routed through layering and after deducting commission the amounts were paid back in cash. As per the commercial taxes department, the parties claim bogus purchases in their books of accounts and inflated expenses. The assessee is one of the beneficiary of bogus GST billing and received bogus purchase entries