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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

Rajendrakumar Chhanalal Shah, Mehsana vs. The ITO, Ward-1, Patan

In the result, the appeal of the assessee is allowed

ITA 1865/AHD/2024[2021-22]Status: DisposedITAT Ahmedabad02 May 2025AY 2021-22

Bench: Dr. B.R.R. Kumar, Vice-Shri T.R. Senthil Kumar

For Appellant: Shri Mehul K. Patel, AdvocateFor Respondent: Shri Ankit Jain, Sr DR
Section 133(6)Section 250

evidence on record, the learned NFAC has grievously erred in confirming the disallowance @ 2% (out of 3.92% made by AO) of the alleged bogus purchases of Rs.12,61,68,630/- without any basis and on presumption only. 2. That on facts, in law, and on evidence on record, the learned ... NFAC ought to have deleted the entire addition in respect of alleged bogus purchases, as prayed for.” 3. The brief facts of the case are that the assessee has been carrying on wholesale business in Jeera, Souff, Oil Seeds, Methi, Isabgul, Coriander, Suva, Magaj Tarabuj etc.. The assessee

Dy. Commissioner of Income Tax, Central Circle-2(1), Chennai vs. Radiance Realty Developers India Ltd., Chennai

ITA 2982/CHNY/2024[2020-21]Status: DisposedITAT Chennai02 May 2025AY 2020-21

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.T.Banusekar, Advocate
Section 132Section 143(3)Section 148

Unaccounted scrap sales in cash 5. Addition of - - - - 8,34,67,815 8,34,67,815 4,40,20,400 15,96,75,209 bogus purchases from suppliers of steel 6. Disallowance ... Realty from FY 2013 the unaccounted sales of M/s Radiance Realty from FY 2013-14 to FY 22-23. And with respect to the Bogus purchase as stated by you, I 23. And with respect to the Bogus purchase as stated by you, I 23. And with respect

Kandarp Hasmukh Sheth, Mumbai vs. Income Tax Officer Ward 32 2 2 Mumbai, Mumbai

In the result, the appeal is accordingly dismissed in above terms

ITA 4457/MUM/2024[2010-2011]Status: DisposedITAT Mumbai02 May 2025AY 2010-2011

Bench: Ms. Padmavathy S & Shri Raj Kumar Chauhan

Section 133(6)Section 143(1)Section 147Section 148Section 250Section 69C

Subsequently, an information was received from Sales Tax Department and DGIT(Inv.), Mumbai that some businessman had indulged in the acceptance of bogus purchase bills from the bogus hawala bill providers and assessee is one the beneficiary of such bogus purchase bills and during the year under considering, the assessee ... same were bogus and non- genuine and these purchases made from these parties amounting to Rs. 1,28,93,048/- is treated as bogus purchase. The Ld. AO estimated the gross profit on the above said bogus purchases @ 13.5% being the possible profit out of the purchases made through

Earth Homes Private Limited, Faridabad vs. ITO, Ward-8(1), New Delhi

ITA 833/DEL/2020[2013-14]Status: DisposedITAT Delhi01 May 2025AY 2013-14

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwalita No. 832/Del/2025 : Asstt. Year : 2018-19 Ita No. 833/Del/2025 : Asstt. Year : 2019-20 Ita No. 834/Del/2025 : Asstt. Year : 2020-21 M/S S. N. Malhotra & Sons, Vs Dcit, 760, Ramesh Nagar, Central Circle-30, New Delhi-110015 New Delhi110055 (Appellant) (Respondent) Pan No. Aabfs6724N Assessee By : Sh. Dhani Ram Anthwal, Adv. & Sh. Rakesh, Adv. Revenue By : Sh. Dayainder Singh Sidhu, Cit-Dr Date Of Hearing: 29.09.2025 Date Of Pronouncement: 29.09.2025 Order Per Satbeer Singh Godara: These Assessee’S Three Appeals In Ita Nos. 832, 833 & 834/Del/2025 For Assessment Years 2018-19, 2019-20 & 2020- 21 Arise Against The Cit(A)-30, New Delhi’S Din & Order No. Itba/Apl/M/250/2024-25/1071341134(1), 1071341700(1) & 1071341990(1) All Dated 18.12.2024, In Proceedings U/S 153C R.W.S. 143(3) Of The Income Tax Act, 1961 (In Short “The Act”), Respectively.

For Appellant: Sh. Dhani Ram Anthwal, Adv. &For Respondent: Sh. Dayainder Singh Sidhu, CIT-DR
Section 132Section 153C

emerges during the course of hearing that the assessee’s instant three appeals raise an identical issue of S. N. Malhotra & Sons disallowance of bogus purchases made by both the learned lower authorities; involving varying sums, in their respective assessments as upheld in the lower appellate discussion. 4. That being ... raised by the assessee emerged therefrom is that whether the Ld. CIT(A) is justified in applying Gross Profit (‘GP’) @ 20% of the said bogus purchases of Rs.43,16,444/-. 3. The relevant facts giving rise to this appeal are that the assesseeappellant filed its Income Tax Return

Assistant Commissioner of Income Tax, Central Circle - 4(1), Kolkata vs. Sendoz Commercials Private Limited, Kolkata

The appeal of the revenue is hereby dismissed

ITA 28/KOL/2025[2017]Status: DisposedITAT Kolkata30 Apr 2025

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.28/Kol/2025 Assessment Year: 2017-18 Acit, Central Circle-4(1), Kolkata ………………………………….…..……Appellant Vs. Sendoz Commercials Pvt. Ltd…………..……...........……........……...…..…..Respondent 644, Marshall House, 25, Strand Road, Kol-1. [Pan: Aagcs5174E] C.O. No.12/Kol/2025 (Arising Out Of I.T.A. No.28/Kol/2025) Assessment Year: 2017-18 Sendoz Commercials Pvt. Ltd …………..………….………………..….…..Cross-Objector 644, Marshall House, 25, Strand Road, Kol-1. [Pan: Aagcs5174E] Vs. Acit, Central Circle-4(1), Kolkata.............................……........……...…..…..Respondent Appearances By: Shri A. K. Tulsyan, Fca & Deepak Mudhra, Aca, Appeared On Behalf Of The Assessee. Shri Prabhakar Prakash Ranjan, Sr. Dr, Appeared On Behalf Of The Revenue. Date Of Concluding The Hearing : April 30, 2025 Date Of Pronouncing The Order : April 30, 2025 Order Per Sonjoy Sarma: The Revenue Has Filed An Appeal & The Assessee Has Filed The Corresponding Cross-Objection Against The Same Order Dated 27.08.2024 By The Commissioner Of Income Tax (Appeals)-27, Kolkata [Hereinafter Referred To As The ‘Cit(A)’] Relating To Assessment Year 2017-18. 2. At The Outset, The Registry Has Informed That There Is A Delay Of 37 Days In Filing The Present Appeal. The Revenue Filed An Application For Condonation Of Delay Stating Reasons For Such Delay. After Considering The Application, We Condone The Delay In Filing The Appeal & Adjudicate The Appeal On Merits Of The Case.

Section 115BSection 133(6)Section 143(2)Section 143(3)Section 148Section 69C

some extent, with the business of the assessee. The assessee, during quantum proceedings itself fled revised computation of income after disallowing the alleged bogus purchases by citing the reason that the suppliers were not traceable during assessment proceedings. Nevertheless, the assessee was in possession of vital evidences in his possession

Virmabhai Ajabaji Patel, Mumbai vs. ITO 19(3)(5), Mumbai

In the result, the appeal is accordingly allowed in the above terms

ITA 544/MUM/2025[2009-2010]Status: DisposedITAT Mumbai30 Apr 2025AY 2009-2010

Bench: Om Prakash Kant & Shri Raj Kumar Chauhanvirmabhai Ajabbaji Patel Vs. Ito – 19(3)(5) Room No. 201, Matru 156, Room No. 6, Mistry Mandir Bldg, Tardeo Bldg, 2Nd Kumbharwala Road, Mumbai. (Vijesh Metal) – 400004. Pan/Gir No. Agkpp3389B (Applicant) (Respondent)

Section 133(6)Section 142(1)Section 143(1)Section 147Section 148Section 250bSection 271(1)(c)

style of proprietorship concern “M/s Vijesh Metal (Ind)” and as per the information received from DGIT (Inv), Mumbai, the assessee was beneficiary of bogus purchases through bogus bills and conducting various non genuine transactions. Subsequently notice u/s 142(1) of the Act dated 11.07.2014 was issued to the assessee ... Kalash Enterprises and (3) M/s. Daksh Diamonds which aggregates to Rs.2,47,45,023/-- The ld. A.O. held the same to be bogus purchase on the premise that the assessee has received accommodation entries from the above mentioned entities which are sought to be managed and controlled by Bhanwarlal Jain

Parekh Marketing Limited, Mumbai vs. Deputy Commissioner of Income-Tax Circle 1(2)(1), Mumbai

Appeal is allowed for statistical purposes

ITA 376/MUM/2025[1998-99]Status: DisposedITAT Mumbai30 Apr 2025AY 1998-99

Bench: Shri Sandeep Gosain (Jm) & Shri Omkareshwar Chidara (Am) Parekh Marketing Limited Dcit-1(2)(1) 2Nd Floor, Mafatlal House Room No. 535 Backbay Reclamation Vs. Aayakar Bhavan, M.K. Mumbai-400 020. Road,Mumbai-400 020 Pan : Aaacp7917J Appellant Respondent

For Appellant: Shri H.M. BhattFor Respondent: Shri Deepak Jain
Section 133(6)

Chidara (AM) :- The appellant filed this appeal for A.Y. 1998-99 and raised following grounds of appeal :- A. DISALLOWANCE OF GIFT ITEMS TREATED AS BOGUS PURCHASES: 1. On the facts and in the circumstances of the case and in law, the Learned National Faceless Appeal Centre, Delhi/Commissioner of Income ... Appellate Tribunal, Mumbai ("ITAT") given vide Order dated 10.02.2009 and confirming the disallowance of Rs. 7,78.929 by treating reimbursement for gift Hems as bogus purchases as treated by the Assessing Officer and without appreciating the submissions and evidences filed by the Appellant and without following the orders

Anatek Services Pvt Ltd, Mumbai vs. ITO Ward 14(1)(1), Mumbai

In the result, the appeal filed by the assessee is dismissed

ITA 368/MUM/2025[2002-03]Status: DisposedITAT Mumbai30 Apr 2025AY 2002-03

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

Section 133Section 143(1)Section 143(3)Section 250Section 271(1)(c)Section 274

penalty for concealment of income or not. There is no denial of fact that the assessee has availed accommodation entry by way of bogus purchases which was subsequently offered to tax after the survey action conducted in the case of the assessee u/s.133A of the Act. The ld. AR placed

Anatek Services Pvt Ltd, Mumbai vs. Income Tax Officer 14(1)(1), Mumbai

In the result, the appeal filed by the assessee is dismissed

ITA 367/MUM/2025[2001-02]Status: DisposedITAT Mumbai30 Apr 2025AY 2001-02

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

Section 133Section 143(1)Section 143(3)Section 250Section 271(1)(c)Section 274

penalty for concealment of income or not. There is no denial of fact that the assessee has availed accommodation entry by way of bogus purchases which was subsequently offered to tax after the survey action conducted in the case of the assessee u/s.133A of the Act. The ld. AR placed

Anatek Services Pvt Ltd, Mumbai vs. Income Tax Officer -14(1)(1), Mumbai

In the result, the appeal filed by the assessee is dismissed

ITA 366/MUM/2025[1999-00]Status: DisposedITAT Mumbai30 Apr 2025AY 1999-00

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

For Appellant: Shri. Haridas BhatFor Respondent: Shri. Ram Krishn Kedia (SR. DR.)
Section 133Section 143(1)Section 143(3)Section 250Section 271(1)(c)Section 274

penalty for concealment of income or not. There is no denial of fact that the assessee has availed accommodation entry by way of bogus purchases which was subsequently offered to tax after the survey action conducted in the case of the assessee u/s. 133A

Income Tax Officer, Ward-1, Faridkot, Bsnl Building vs. M/S Vohra Solvex Pvt. Ltd, Sadiq Road

In the result, C.O. filed by the assessee is allowed

ITA 588/ASR/2024[2014-15]Status: DisposedITAT Amritsar29 Apr 2025AY 2014-15

Bench: Sh. Udayan Dasgupta & Sh. Krinwant Sahay

For Appellant: Sh. Sudhir Sehgal, A.R
Section 143(3)Section 148Section 250(6)Section 69C

form 36 are as follows: “1. The Ld. CIT(A) has erred in limiting the addition only to the extent of 1.2% of bogus purchases as against 100% made by the AO u/s 69C of the Act by not appreciating the judgment of the Hon'ble Hon'ble Supreme Court ... assessee against the decision of the Gujarat High Court [N.K. Industries Ltd. v. DCIT (2016) 72 taxmann.com 289 (Gujarat)] wherein 100% of bogus purchases were added to the total income of the assessee. 2. The Ld. CIT(A) has erred in limiting the addition only to the extent

Jai Prakash Shahani, Indore vs. Income Tax Officer - NFAC, Delhi

In the result, appeal of the assessee is allowed

ITA 524/IND/2023[2014-15]Status: DisposedITAT Indore29 Apr 2025AY 2014-15

Bench: Shri Manish Boradjai Prakashshahani, Income Tax Officer, Prop. M/S Jai Prakash Impex, Nfac, Delhi Vs. 73, New Palasia, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Apqps7948G Assessee By Ms. Ruchira Singhal, Ar Revenue By Shri Ashish Porwal, Sr.Dr Date Of Hearing 27.02.2025 Date Of Pronouncement 29.04.2025

Section 139(1)Section 143(3)Section 144BSection 147Section 148Section 37

reasons 4 Jai PrakashShahani– A.Y 2014-15 on the basis of which the case of the assessee has been reopened are regarding alleged bogus purchase transaction of Rs.1,94,07,890/- escaped from levy of tax but Ld. A.O has finally accepted the genuineness of the purchases made from ... examined the Income Tax Return filed by the assessee as well as the assessment records. I observe that in the reasons recorded alleges that bogus purchases of Rs.1,94,07,890/- has escaped the assessment. Before alleging bogus purchases, Ld. A.O is certainly expected to have levelled such allegation against

Rajesh Shivji Shah, Mumbai vs. 20(3)(1), Mumbai

In the result the appeal filed by the assessee stands partly allowed

ITA 525/MUM/2025[2011-2012]Status: HeardITAT Mumbai29 Apr 2025AY 2011-2012

Bench: Hon’Ble Shri Sandeep Gosainrajesh Shivji Shah Vs. Ito – 20(3)(1) Room No. 10, 2Nd Floor, 142 2Nd Floor, Piramal Chakan Niwas, St. Paul St. Chambers, Lower Parel Hindmata, Dadar (E), 400013. Mumbai – 400014. Pan/Gir No. Aafps4342A (Applicant) (Respondent)

Section 147Section 250Section 69C

Nikunj Eximp Enterprises [2015] 372 ITR 619 (Bom HC). 10. From the facts I also found that there is no direct finding of bogus purchases in Sales Tax proceedings and mere VAT assessment does not established that the asessee’s transactions with the purchases parties were fictitious. In the present

Mital Polyplast Pvt Ltd, Mumbai vs. ITO Ward 2(2)(3), Mumbai

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

ITA 109/MUM/2025[2010-11]Status: DisposedITAT Mumbai29 Apr 2025AY 2010-11
For Appellant: Shri M.S. MathuriaFor Respondent: Shri R.K. Makwana, Addl.CIT
Section 143(1)Section 143(3)Section 69C

Rs.1,08,51,009/- for A.Y. 2010-11, sustained by the learned CIT(A) on account of bogus purchases by applying the peak of aggregate purchases made from alleged parties who were in the list of Hawala Operators. 3. The brief facts of the case are that the assessee-company ... Thereafter, the assessee's case was reopened on the basis of information received from DGIT (Inv.) that the assessee is involved in bogus purchases and AO formed an opinion that the income of Rs.1,69,02,364/- has escaped assessment. In the reasons recorded, the AO noted that there

Mital Polyplast Pvt Ltd, Mumbai vs. ITO Ward 2(2)(3), Mumbai

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

ITA 108/MUM/2025[2009-10]Status: DisposedITAT Mumbai29 Apr 2025AY 2009-10
Section 143(1)Section 143(3)Section 69C

Rs.1,08,51,009/- for A.Y. 2010-11, sustained by the learned CIT(A) on account of bogus purchases by applying the peak of aggregate purchases made from alleged parties who were in the list of Hawala Operators. 3. The brief facts of the case are that the assessee-company ... Thereafter, the assessee's case was reopened on the basis of information received from DGIT (Inv.) that the assessee is involved in bogus purchases and AO formed an opinion that the income of Rs.1,69,02,364/- has escaped assessment. In the reasons recorded, the AO noted that there

Vijaygroup Housing Private Limited, Mumbai vs. NFAC CIT(A), Mumbai

In the result, appeal of the assessee is dismissed

ITA 5281/MUM/2024[2016-17]Status: DisposedITAT Mumbai29 Apr 2025AY 2016-17

Bench: Raj Kumar Chauhan & Shri Om Prakash Kant

Section 14Section 143(1)Section 144B(8)Section 148Section 250

that CA Sanjay Shah was one of the Vijaygroup Housing Pvt. Ltd. intermediaries who had sourced and provided accommodation entries of different types like bogus purchases, bogus trading income, bogus long term capital gain, etc. 3. It is further noticed that, CA Sanjay Shah has arranged accommodation entries

Vijaygroup Housing Pvt Ltd, Mumbai vs. NFAC CIT(A), Mumbai

In the result, appeal of the assessee is dismissed

ITA 5280/MUM/2024[2019-20]Status: DisposedITAT Mumbai29 Apr 2025AY 2019-20

Bench: Raj Kumar Chauhan & Shri Om Prakash Kant

Section 14Section 143(1)Section 144B(8)Section 148Section 250

that CA Sanjay Shah was one of the Vijaygroup Housing Pvt. Ltd. intermediaries who had sourced and provided accommodation entries of different types like bogus purchases, bogus trading income, bogus long term capital gain, etc. 3. It is further noticed that, CA Sanjay Shah has arranged accommodation entries

Manoj Narandas Bha vs. Ar, Bhayandar West Thanevs.Income Tax Officer, Thane West

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

ITA 2644/MUM/2023[2010-2011]Status: DisposedITAT Mumbai29 Apr 2025AY 2010-2011

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2010-11 Manoj Narandas Bhavsar, Ito, A-405, Mahavir Jyot, Station Road, Room No. 16, B Wing, 6Th Floor, Bhayandar West, Vs. Ashar It Park, Road No. 16Z, Maharashtra-401101. Midc, Thane West-401101. Pan No. Aczpb 2228 E Appellant Respondent Assessee By : Mr. Rahul Hakani Revenue By : Mr. Kiran Unavekar, Sr. Dr

For Appellant: Mr. Rahul HakaniFor Respondent: Mr. Kiran Unavekar, Sr. DR
Section 133(6)Section 148Section 271(1)(c)Section 69C

under: Manoj Narandas Bhavsar 2 1) The Learned CIT(A)/NFAC erred in confirming addition of Rs 28,46,688/- u/s 69C being alleged bogus purchases from AG Corporation Rs 96,200/-, Nimesh Trading Co Rs 4,23,800/- and Shreeji Enterprises Rs 23,26,688/- without appreciating that Section ... prejudice to above, entire purchases of Rs 28,46,688/- cannot be disallowed and the disallowance may be restricted to 2% of the alleged bogus purchases or any other reasonable percentage. 2. Briefly stated, facts of the case are that the assessee is a engaged in the business of manufacturing

Vimal Chand Gokharoo, Surat vs. ITO 3(3)(1), Surat

In the result, appeal of the appellant is allowed

ITA 42/SRT/2025[2013-14]Status: DisposedITAT Surat28 Apr 2025AY 2013-14

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.40 To 42/Srt/2024 Assessment Years:(2011-12 To 2013-14) (Hybrid Hearing) Vimal Chand Gokharoo, Vs. The Ito, 16Th Floor, D Wing, Trade World, Ward – 3(3)(1), Kamala Mills, Compound, Senapati Surat Bapat Marg, Lower Parel, Mumbai - 400013 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Acupj0819L (Appellant) (Respondent) Appellant By Shri Himashu Gandhi, Ca Respondent By Ms Jayshree Thakur, Sr. Dr Date Of Hearing 24/04/2025 Date Of Pronouncement 28/04/2025

Section 132Section 143(3)Section 271(1)(c)Section 274

purchases of Rs.9,12,55,927/- from the concerns of Rajendra Jain Group, who were found to have provided accommodation entries by way of bogus purchase, sale and unsecured loan to various parties. It was so established due to a search and seizure operation conducted ... Rajendra Jain group, Shri Dharmichand Jain group and Shri Sanjay Chaudhary group. On appeal, the CIT(A) restricted the addition to 5% of the bogus purchases. On further appeal, the ITAT, Surat vide order dated 13.12.2022 sustained addition @ 6% of total purchase of Rs.9,12,55,927/-. Thereafter, penalty

Vimal Chand Gokharoo, Surat vs. ITO 3(3)(1), Surat

In the result, appeal of the appellant is allowed

ITA 41/SRT/2025[2012-13]Status: DisposedITAT Surat28 Apr 2025AY 2012-13

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.40 To 42/Srt/2024 Assessment Years:(2011-12 To 2013-14) (Hybrid Hearing) Vimal Chand Gokharoo, Vs. The Ito, 16Th Floor, D Wing, Trade World, Ward – 3(3)(1), Kamala Mills, Compound, Senapati Surat Bapat Marg, Lower Parel, Mumbai - 400013 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Acupj0819L (Appellant) (Respondent) Appellant By Shri Himashu Gandhi, Ca Respondent By Ms Jayshree Thakur, Sr. Dr Date Of Hearing 24/04/2025 Date Of Pronouncement 28/04/2025

Section 132Section 143(3)Section 271(1)(c)Section 274

purchases of Rs.9,12,55,927/- from the concerns of Rajendra Jain Group, who were found to have provided accommodation entries by way of bogus purchase, sale and unsecured loan to various parties. It was so established due to a search and seizure operation conducted ... Rajendra Jain group, Shri Dharmichand Jain group and Shri Sanjay Chaudhary group. On appeal, the CIT(A) restricted the addition to 5% of the bogus purchases. On further appeal, the ITAT, Surat vide order dated 13.12.2022 sustained addition @ 6% of total purchase of Rs.9,12,55,927/-. Thereafter, penalty