“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

Mukesh Jain HUF, Jaipur vs. DCIT, Jaipur

In the result, the appeal of the assessee is allowed

ITA 620/JPR/2025[2010-11]Status: DisposedITAT Jaipur06 Aug 2025AY 2010-11

Bench: Reopening The Assessment & Without Independent Application Of Mind. Thus, The Action Of The Ld. Ao In Reopening The Assessment U/S 148 & The Consequent Reassessment Order So Passed Deserves To Be Held Bad In Law.

For Appellant: Sh. Tarun Mittal, CAFor Respondent: MS. Alka Gautam, CIT-DR

Section 143(3)Section 147Section 148Section 68

case of CIT vs Odeon Builders Pvt. Ltd. in Civil Appeal No. 9604-9605 of 2018 has held as under: S. 68/69 Bogus Purchases: Disallowance cannot be made solely on third party information without subjecting it to further scrutiny. The assessee has prima facie discharged the initial burden of substantiating

Jajoo Rashmi Refractories Limited, Jaipur, Rajasthan vs. DCIT, Circle 4-Jaipur, Jaipur, Rajasthan

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

ITA 209/JPR/2025[2018-19]Status: DisposedITAT Jaipur06 Aug 2025AY 2018-19

For Appellant: Ms. Prabha Rana, AdvocateFor Respondent: Shri Gaurav Awasthi, JCIT-DR

Section 131Section 145Section 147Section 69C

addition u/s 69C of Rs.1,82,05,040/-holding that the assessee has taken only accommodation entry of genuine purchase by alleging as bogus purchase/ transactions is bad in law and facts. 8. Not considering the ground of the assesove that not exercising property the vested powers of Civil Court ... this ground of appeal, as brought out in the assessment order During the assessment proceedings, AO observed that the assessee had assessee engaged in bogus purchase of Rs.1,82,05,040/-. The assessee failed to give a reply and provide any required details. Hence, the A.O. completed the assessment

Goel Jewellery & Mart P. Ltd., New Delhi vs. ITO, Ward- 10(2), New Delhi

In the result, appeal of the assessee is partly allowed as indicated above

ITA 6686/DEL/2017[2007-08]Status: DisposedITAT Delhi06 Aug 2025AY 2007-08

Bench: Shri Shamim Yahya & Shri Sudhir Pareek

For Appellant: Shri Satyen Sethi, Adv. &For Respondent: Shri Om Parkash, Sr. DR

Section 147Section 68

confirmed that the assessee has taken 5 ITA No.-6686/Del/2017 Goel Jewellery & Mart P. Ltd. accommodation entry of Rs 23,70,740/- against bogus purchase bills issued by the Little Diam, as the assessee failed to filed details which can substantiate its claims of purchasing diamonds from M/S Little ... Jain and his sons. It is also relevant to note that the name of assessee figures as one of the beneficiaries of these alleged bogus purchased given by the Directorate after making the necessary enquires. 9. From the facts mentioned hereinbefore, we do not find any error committed

Swamy Holagundi, Huvina Hadagali vs. Income Tax Officer, Ward-1 & Tps, Hospet

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

ITA 1767/BANG/2024[2018-2019]Status: DisposedITAT Bangalore05 Aug 2025AY 2018-2019

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2018-19 Swamy Holagundi Prop: Raviteja Traders 7C/10, 3Rd Ward Ito Bangarappanagar Vs. Ward-1 & Tps Karnataka 583 219 Hospet Pan: Dwjps7047P Appellant Respondent Appellant By : Sri V. Srinivasan, Advocate, A.R Respondent By : Sri Subramanian S., Jcit D.R. Date Of Hearing : 08.05.2025 Date Of Pronouncement : 05.08.2025 O R D E R Per Keshav Dubey: This Appeal At The Instance Of The Assessee Is Directed Against The Order Of The Ld. Cit(A)/Nfac Dated 19.07.2024Vide Din & Order No. Itba/Nfac/S/250/2-24-25/1066829871(1) Passed U/S.250 Of The Income Tax Act, 1961 (In Short “The Act”) For The Assessment Year 2018-19. 2. The Assessee Has Raised The Following Grounds Of Appeal: -

For Appellant: Sri V. Srinivasan, Advocate, A.RFor Respondent: Sri Subramanian S., JCIT D.R

Section 147Section 250Section 69C

bogus in nature is upheld. However, the Ld. CIT(A)/NFAC was of the opinion that treating the entire bogus purchases of Rs. 8,07,30,850/- to be the income of the assessee is ill-founded. The Ld. CIT(A)/NFAC relying on the decision

Agrawal Ramesh Murlidhar HUF, Mumbai vs. Income Tax Officer - 19(3)(1), Mumbai

In the result, grounds of appeal of assessee raised by the assessee are partly

ITA 2370/MUM/2025[2011-12]Status: DisposedITAT Mumbai05 Aug 2025AY 2011-12

Bench: Shri Pawan Singh(Physical Hearing) Agrawal Ramesh Murlidhar (Huf) Ito – 19(3)(1), Mumbai 328, Panchratna, 3Rd Floor, Vs Piramal Chambers, Lalbaug, Opera House, Mumbai – 400004. Mumbai - 400012. [Pan: Aaaha0529A] Appellant / Assessee Respondent / Revenue

Section 144Section 254(1)

facts in confirming the action of Ld. Assessing Officer in making addition amounting to Rs. 13,82,306/-, being the amount of alleged bogus purchases, without appreciating the facts and circumstances of the case and without providing the Appellant adequate opportunity of being heard. (b) The Ld. CIT(A) erred ... appeal is dismissed as not pressed. Ground no. 2 relates to addition of Rs. 13,82,306/- on account of alleged bogus purchases shown from Adi Impex an entity managed by Rajendra Jain and his associates. The Assessing Officer made disallowance or entire purchases from Adi Impex

ACIT, Mumbai vs. Ramchandra Keshav and Company, Mumbai

In the result, grounds of appeal of revenue

ITA 2210/MUM/2025[2010-11]Status: DisposedITAT Mumbai05 Aug 2025AY 2010-11

Bench: Shri Pawan Singh(Hybrid Hearing) Acit – 19(3), Mumbai Ramchandra Keshav & Company Room No. 513, 5Th Floor, Vs 53, Mohan Building, 162, J.S.S. Road, Piramal Chamber, Girgaum, Mumbai – 400004. Mumbai – 400012. [Pan: Aaafr1124J] Appellant / Revenue Respondent / Assessee

Section 143(3)Section 254(1)

revenue has raised multiple grounds of appeal, however, in my considered view, the substantial grounds of appeal relates to restricting the disallowance of alleged bogus purchases to the extent of 12.5% of such purchases. 2. Rival submissions of both the parties have been heard and record perused. The learned Senior

DCIT, Central Circle-1, Ludhiana vs. M/S Ritish Agro Private Limited, Ludhiana

Appeal stand dismissed

ITA 638/CHANDI/2022[2019-20]Status: DisposedITAT Chandigarh04 Aug 2025AY 2019-20

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am Physical Hearing 1. आयकरअपीलसं./ Ita No. 633/Chandi/2022 (िनधा"रण वष" / Assessment Year: 2019-20) M/S Ritish Agro Private Ltd. Dcit-Central Circle-1 बनाम/ Vs. Malerkotla Road, Rasulra Ludhiana Khanna – 141 401 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaccr-7743-J (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकरअपीलसं./ Ita No.638/Chandi/2022 (िनधा"रण वष" / Assessment Year: 2019-20) Dcit-Central Circle-1 M/S Ritish Agro Private Ltd. बनाम/ Vs. Ludhiana Malerkotla Road, Rasulra Khanna – 141 401 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaccr-7743-J (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Ashwani Kumar (Ca) & Ms. Muskan Garg (Ca) – Ld. Ars ""थ"कीओरसे/Respondent By : Ms. Tarundeep Kaur (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 24-06-2025 घोषणाकीतारीख /Date Of Pronouncement : 04-08-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1.1 Aforesaid Cross-Appeals Arises Out Of The Order Of Learned Commissioner Of Income Tax (Appeals)-5, Ludhiana Dated 26-07-2022

For Appellant: Shri Ashwani Kumar (CA) & MsFor Respondent: Ms. Tarundeep Kaur (CIT) – Ld. DR

Section 143(3)Section 145(3)Section 250(6)Section 36(1)(iii)Section 68

case, the ld. CIT(A) was justified in deleting the addition of Rs.1,91,38,676/- made by the A.O. on account of bogus purchases u/s 68 of the I.T. Act, 1961 without appreciating that in view of non-existent creditors or paper creditors without financial or commercial substance ... discharged? 4.Whether in the facts and circumstances of the case, the Ld. CIT(A) was justified in deleting the additions made on account of bogus purchases u/s 68 r.w.s. 69C in view of the judgement of the Hon'ble Supreme Court in the case of Sumit Dayal Vs. Commissioner

M/S Ritish Agro Private Limited, Khanna vs. DCIT, Central Circle-1, Ludhiana

Appeal stand dismissed

ITA 633/CHANDI/2022[2019-20]Status: DisposedITAT Chandigarh04 Aug 2025AY 2019-20

For Appellant: Shri Ashwani Kumar (CA) & MsFor Respondent: Ms. Tarundeep Kaur (CIT) – Ld. DR

Section 143(3)Section 145(3)Section 250(6)Section 36(1)(iii)Section 68

Radiant Gems, Mumbai vs. The Income Tax Officer Ward 34(3)(2), Mumbai

In the result, both the appeals filed by the assessee are allowed

ITA 2075/MUM/2025[2013-14]Status: DisposedITAT Mumbai04 Aug 2025AY 2013-14

Bench: Hon’Ble Shri Sandeep Gosain & Shri Girish Agrawal

Section 250Section 271(1)(c)

records and stock register showing monthwise receipt and consumption of materials. So under these circumstances it is settled position now that entire alleged bogus purchases can not added to the income of the assessee as it would affect the profits of the assesse unrealistically and unreasonably. Therefore under such circumstances ... only profit margin on those bogus purchases can at the most be added. Accordingly we set aside the order of id CIT(A) on this issue and direct the AO to apply a profit rate of 5% on the bogus purchases of Rs.9,14,75,919/-. The appeal

Radiant Gems, Mumbai vs. The Income Tax Officer Ward 34(3)(2), Mumbai

In the result, both the appeals filed by the assessee are allowed

ITA 2074/MUM/2025[2012-13]Status: DisposedITAT Mumbai04 Aug 2025AY 2012-13

Bench: Hon’Ble Shri Sandeep Gosain & Shri Girish Agrawal

Section 250Section 271(1)(c)

ITO-41(1)(3), Mumbai vs. Pravin Manilal Panchal, Mumbai

In the result, grounds of appal of revenue is

ITA 5252/MUM/2024[2011-12]Status: DisposedITAT Mumbai01 Aug 2025AY 2011-12

Bench: Shri Pawan Singh(Physical Hearing) Ito – 41(1)(3), Mumbai Pravin Manilal Panchal Kautilya Bhavan, Vs (Legal Heir: Hasumati Pravin Panchal) Bandra Kurla Complex, 8A-Vaibhav Industrial Estate, Bandra (East), Saki Vihar Road, Sakinaka, Andheri (E), Mumbai – 400051. Mumbai – 400072. [Pan: Aabpp5448E] Appellant / Revenue Respondent / Assessee

Section 254(1)

facts and in the circumstances of the case and in law, the Ld.CIT(A)has erred in restricted the addition @ 12.5% of alleged bogus purchases as against the addition made by the Assessing Officer by disallowing the total non- genuine purchases debited by the assessee, ignoring the facts that ... account of disallowance of certain purchases. The assessing officer disallowed 100% of purchases shown from alleged hawala dealers. The assessee has shown such bogus purchases only to inflate the expenses. During assessment, the assessing officer gave clear finding about non- existence of dealers, from whom the assessee has shown purchases

Shital Vipulkumar Dholakia, Ahmedabad vs. The Income Tax Officer, Ward-1(1)(3), Ahmedabad

ITA 259/AHD/2024[2021-22]Status: DisposedITAT Ahmedabad31 Jul 2025AY 2021-22

Bench: Ms.Suchitra R. Kamble & Shri Makarand V.Mahadeokar

For Appellant: Shri Tushar Hemani, Sr. Advocate andFor Respondent: Shri Sher Singh, CIT-DR

Section 133(6)Section 142(1)Section 143(3)Section 144BSection 250Section 40A(3)

against effecting purchases from unregistered dealers, and in any case, the disallowance made in the present case was not on account of bogus purchases but was specifically made by invoking the provisions of section 40A(3). It was argued that such disallowance is impermissible, as all payments were made through

Krypton Industries Limited, Falta vs. DCIT, Circle 1(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1186/KOL/2025[2014-2015]Status: DisposedITAT Kolkata31 Jul 2025AY 2014-2015

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.1186/Kol/2025 Assessment Year: 2014-15 Krypton Industries Ltd.…………………..……..…………………....Appellant Plot 31 & 32, Sector-1, Falta, 24 North Parganas, W.B – 743504. [Pan: Aabck0868N] Vs. Dcit, Circle-1(1), Kolkata……………....…..………………….…..... Respondent Appearances By: Shri Akkal Dudhwewala & Vidhi Ladia, Ar, Appeared On Behalf Of The Appellant. Smt. Ranu Biswas, Addl. Cit- Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : July 31, 2025 Date Of Pronouncing The Order : July 31, 2025 आदेश / Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) [Cit(A)], Kolkata, Dated 31.03.2025, Passed Against The Assessment Order Under Section 147/143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Year 2014–15. 2. Brief Facts Of The Case Are That Information Was Received From The Investigation Wing, Kolkata, Indicating That The Assessee-Company Had Taken Bogus Purchases From One Shri Sanjiw Kumar Singh To Reduce Its Taxable Income. A Search Under Section 132 Of The Act Was Conducted On The Said Person & His Statement Was Recorded. Based On The Appraisal Report & Material Found During The Search, It Was Alleged That The Assessee Was One Of The Beneficiaries Of Such Bogus

Section 132Section 143(2)Section 143(3)Section 147Section 148Section 154

Brief facts of the case are that information was received from the Investigation Wing, Kolkata, indicating that the assessee-company had taken bogus purchases from one Shri Sanjiw Kumar Singh to reduce its taxable income. A search under section 132 of the Act was conducted on the said person

Income Tax Officer, Mumbai vs. Sanghvi Plywood & Timber Private Limited, Mumbai

Accordingly, all the contentions raised by the Revenue in the present appeal are rejected as being without merit. In terms of above, Ground No.1 to 4 raised by the Revenue are dismissed

ITA 3098/MUM/2025[2010-11]Status: DisposedITAT Mumbai31 Jul 2025AY 2010-11

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: NoneFor Respondent: Shri Pravin Salunkhe

Section 143(3)Section 147Section 250Section 69C

erred in law in restricting the addition to 12.50% of the alleged amount of purchases of Rs.45,991/- being profit/GP rate qua alleged bogus purchases shown by the assessee, though the Ld. Addl/JCIT(A) itself had agreed that the assessee had failed to prove the genuiness of the purchase transactions ... facts and circumstances of the case, the Ld. Addl/JCIT(A) erred in law in restricting the addition to 12.50% of the alleged amount of bogus purchases without appreciating the fact that in the case of NK Protein Ltd. Vs. DCIT (2017) 292 CTR 354 (SC) where the Hon’ble Supreme

Varsha Mills Private Limited, Mumbai vs. Income Tax Officer Ward 4(3)(1), Mumbai

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

ITA 2703/MUM/2025[2018-19]Status: DisposedITAT Mumbai31 Jul 2025AY 2018-19

Bench: MS. KAVITHA RAJAGOPAL (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

For Appellant: Ms. Darshana BhaiyaFor Respondent: Shri Vivek Perampura, (CIT-DR)

Section 115BSection 139(1)Section 143(1)Section 147Section 148Section 148ASection 250Section 69C

vide notice u/s. 148 dated 29.03.2022, for the reason that the assessee was one of the beneficiaries of availing accommodation entries by way of bogus purchases from the supplier companies aggregating to Rs. 24,14,30,244/- which according to the learned Assessing Officer ('ld. A.O.' for short

Income Tax Officer, Mumbai vs. Mahesh K Josi(HUF), Mumbai

In the result, the grounds of a In the result, the grounds of appeal of the assessee are allowed ppeal of the assessee are allowed for statistical purposes

ITA 2241/MUM/2025[2010-11]Status: DisposedITAT Mumbai31 Jul 2025AY 2010-11

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2010-11 Ito Mahesh K Joshi (Huf), 503, 5Th Floor, Piramal Chambers, 43, A/3, 479, Jariwala Bldg. Vs. Lalbaug, Arther Raod Tardeo, Mumbai-400012. Mumbai-400034. Pan No. Aadhm 4623 G Appellant Respondent

For Appellant: Mr. Aditya Rai, Sr. DRFor Respondent: None

Section 69

bogus operators and was involved in the business almost 347 bogus operators and was involved in the business of providing accommodations entries of bogus purchases and of providing accommodations entries of bogus purchases and of providing accommodations entries of bogus purchases and assessee was found ... business of providing accommodation entries of bogus the business of providing accommodation entries of bogus the business of providing accommodation entries of bogus purchases ? 5. The tax effect involved in this case is Rs. 14,79,600/ 5. The tax effect involved in this case

Ace Electromagnetics Private Limited, Mumbai vs. ITO, WD 9(1)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 1865/MUM/2025[2011-12]Status: DisposedITAT Mumbai31 Jul 2025AY 2011-12

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2011-12

For Appellant: Ms. Kinjal Bhuta, AdvocateFor Respondent: Shri Aditya M. Rai, Sr. DR

Section 145(3)Section 148Section 271(1)Section 271(1)(c)Section 271(1)(e)

information received from DGIT, Mumbai from the Sales Tax Department. Assessment was completed by making an addition of Rs. 52,50,000/- for alleging bogus purchases made by the assessee from three parties. Books of account were rejected u/s 145(3) and the additions were made. In the course ... said addition. Assessee went in appeal before the ld. CIT(A) who restricted the addition so made to profit element embedded in the alleged bogus purchases by taking rate of 12.5% on the said alleged bogus purchases. He thus, sustained the addition of Rs. 6,56,250/- and the balance

Asian Clousers Ltd( Since Amalgamated With M/S Asian Consolidated Inds.Ltd), Rewari vs. DCIT, Circle-3(2), New Delhi

In the result, appeal of assessee in ITA No

ITA 7252/DEL/2017[1992-93]Status: DisposedITAT Delhi31 Jul 2025AY 1992-93

Bench: Shri Anubhav Sharma & Shri Amitabh Shuklam/S Asian Closures Ltd. Vs. The Dy. C.I.T (Since Amalgamated With Asian Circle 3(2) Consolidated Industries Ltd.) C.R. Building, 96Th Mile, Delhi Jaipur I.P. Estate, Highway, Village Bawal, New Delhi Distt. Rewari, Haryana

For Appellant: Sh. Ved Jain, AdvFor Respondent: Ms. Monika Singh, CIT, DR

Section 143(3)Section 40(3)Section 40A(3)

that these purchases were considered as paper transactions, and it was inferred that the assessee had introduced its own income in the garb of bogus purchases. 12. At the very outset, the ld. counsel for the assessee submitted that the purchases from M/s Babbar Industrial and Trading Co., Amritsar, were ... regard. 14. It has also been alleged by the Assessing Officer that the assessee company introduced its own unaccounted income under the guise of bogus purchases. However, it was submitted that the burden of proof lies on the party making the allegations. While completing the assessment

DCIT, CC-2(4), Kolkata vs. M/S Balaji Agro Pvt. Ltd., Kolkata

In the result, the appeal of the Revenue is dismissed

ITA 842/KOL/2025[2019-20]Status: DisposedITAT Kolkata30 Jul 2025AY 2019-20

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm Dcit, Central Circle-2(4), M/S Balaji Agro Pvt. Ltd. Aaykar Bhavan Poorva, A5-6 Sarkarpool Maheshtala, 4Th Floor, 110 Shantipally, E.M. New Budge Budge Trunk Rd. Vs. Bypass, Kolkata-700107 Gopalpur 24 Paraganas South West Bengal Kolkata-700143, West Bengal (Appellant) (Respondent) Pan No. Aabcb9078M Assessee By : Shri Miraj D Shah, Ar Revenue By : Shri Raja Sengupta, Dr Date Of Hearing: 16.07.2025 Date Of Pronouncement: 30.07.2025

For Appellant: Shri Miraj D Shah, ARFor Respondent: Shri Raja Sengupta, DR

Section 132Section 133(6)Section 139(1)Section 143(2)Section 153ASection 43ASection 68Section 69C

issue raised in ground no. 5 is against the order of the ld. CIT (A) restricting the disallowance of 5% on account of bogus purchase to the tune of ₹37,46,308/- from Pushpadham Heights (P) Ltd. 5.1. The facts in brief are that in the assessment proceeding ... made an addition on account of bogus purchases of ₹37,46,308/- then the assessee failed to substantiate the identity ITA No.842 KOL 2025 Balaji Agro Pvt. Ltd.; A.Y. 2019-20 and genuineness of the transactions with the supporting vouchers. 5.2. In the appellate proceedings, the ld. CIT (A) uphold

Vikramkumar, Chennai vs. DCIT, Chennnai

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

ITA 569/CHNY/2025[2021-22]Status: DisposedITAT Chennai30 Jul 2025AY 2021-22

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita No.569/Chny/2025 िनधा9रण वष9 /Assessment Year: 2021-22 Vikram Kumar, The Dy. Commissioner Of 15, Lakshmi Nagar Extension, Vs. Income Tax, Vadaperumbakkam, Non Corporate Circle-6(1), Chennai – 600 060. Chennai. [Pan: Bjopk 1906R]

For Appellant: Shri Pradeep Kumar, C.A GHFor Respondent: Shri A.T. Krishnamoorthy, JCIT

Section 143(3)

return of income declaring total income of Rs.4,98,220/-. The A.O, in the assessment order has made addition on account of profit on bogus purchases of Rs. 1,14,03,831/-. Aggrieved by the addition, the assessee preferred an appeal before ... observed that the assessee has not produced stock register, date of purchase, payment and bank details etc., and concluded that the assessee has made bogus purchases to the tune of Rs. 6,33,54,620/-. The A.O accordingly has made addition of 18% of the bogus purchases in the income