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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

ITO-19(3)(1), Mumbai vs. Spark Gems, Mumbai

In the result appeal of the Revenue is dismissed

ITA 3617/MUM/2024[2012-13]Status: FixedITAT Mumbai13 Dec 2024AY 2012-13

Bench: SHRI AMIT SHUKLA (Judicial Member), MS PADMAVATHY S (Accountant Member)

Section 147Section 148Section 271(1)(c)

reducing the addition to Rs.24,72,470 as against addition of Rs.7,83,88,794/- made by the AO on account of alleged bogus purchases. 3. None appeared on behalf of the respondent assessee despite service of notices sent on the registered e-mail ID and RPAD. Accordingly, the appeal ... assessee. Ld. AO has made the addition of Rs. 7,83,88,794/- purely relying on the information received that assessee has made alleged bogus purchases from Shri Bhawarlal Jain controlled entities without even verifying whether assessee has actually made any such purchases for that amount or not . Since assessee

Income Tax Officer-19(3)(1), Mumbai vs. Spark Gems, Mumbai

In the result appeal of the Revenue is dismissed

ITA 3616/MUM/2024[2012-13]Status: FixedITAT Mumbai13 Dec 2024AY 2012-13
Section 147Section 148Section 271(1)(c)

reducing the addition to Rs.24,72,470 as against addition of Rs.7,83,88,794/- made by the AO on account of alleged bogus purchases. 3. None appeared on behalf of the respondent assessee despite service of notices sent on the registered e-mail ID and RPAD. Accordingly, the appeal ... assessee. Ld. AO has made the addition of Rs. 7,83,88,794/- purely relying on the information received that assessee has made alleged bogus purchases from Shri Bhawarlal Jain controlled entities without even verifying whether assessee has actually made any such purchases for that amount or not . Since assessee

Nehasach Impex Pvt. Ltd., Delhi vs. ITO, Ward- 18(1), Delhi

Appeal is allowed for statistical purposes in above terms

ITA 3707/DEL/2024[2021-22]Status: DisposedITAT Delhi13 Dec 2024AY 2021-22

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganeshita No. 3707/Del/2024 : Asstt. Year : 2021-22 Nehasach Impex Pvt. Ltd., Vs Income Tax Officer, Plot No. 245-246, 1St Floor, Jarodha Ward-18(1), Dairy, Sant Nagar, Village Burari, New Delhi-110002 New Delhi-110084 (Appellant) (Respondent) Pan No. Aahcn1557F Assessee By : Sh. Vijay Singhla, Ca Revenue By : Ms. Baljeet Kaur, Cit-Dr Date Of Hearing: 04.12.2024 Date Of Pronouncement: 13.12.2024 Order Per Satbeer Singh Godara: This Assessee’S Appeal For Assessment Year 2021-22, Arises Against The Cit(A)/Nfac, Delhi’S Order Dated 27.01.2024 In Din & Order No. Itba/Nfac/S/250/2023-24/1060166113(1) In Proceedings U/S 143(3) Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Vijay Singhla, CAFor Respondent: Ms. Baljeet Kaur, CIT-DR
Section 143(3)Section 250(6)Section 37(1)

noticed at the outset that the learned CIT(A)/NFAC herein has affirmed the Assessing Officer’s action making the alleged bogus purchases addition u/s 37(1) of the Act amounting to Rs.20,92,16,097/- in assessment order dated 28.12.2022, vide its ex-parte lower appellate discussion. 2 Nehasach

M/S Unijules Life Sciences Ltd., Nagpur vs. DCIT Central Circle-2(1), Nagpur

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

ITA 381/NAG/2024[2013-14]Status: HeardITAT Nagpur12 Dec 2024AY 2013-14

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Kapil HiraniFor Respondent: Shri Sandipkumar Salunke
Section 14Section 143(3)Section 7

treating the purchases made by the Appellant to that extent as 2 M/s. Unijules Life Sciences Ltd. ITA no.381/Nag./2024 bogus purchases which is illegal and the addition so made deserves to be deleted as per law. 4) On the facts and circumstances of the case

Dinesh M. Semlani, Mumbai vs. Income Tax Officer, Mumbai

In the result, the appeal filed by the assessee is partly allowed

ITA 4758/MUM/2024[2021-22]Status: DisposedITAT Mumbai12 Dec 2024AY 2021-22

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri B.R. Baskaranassessment Year : 2021-22 Dinesh M. Semlani, Income Tax Officer, A/501, Harsh Kushal Ward-42(1)(2), Co-Op. Hsg, Vs. Kautilya Bhavan, Ashokvan, Dahisar East, Bandra Kurla Complex, Mumbai. Bandra East, Pan : Amwps3986R Mumbai. (Appellant) (Respondent)

For Appellant: Shri M.S. MathuriaFor Respondent: Smt. Sanyogita Nagpal, CIT-DR
Section 133(6)Section 69Section 69C

Apex Court had upheld the decision of Hon‟ble Gujarat High Court in confirming the disallowance of 100% of the value of bogus purchases. Accordingly, the AO disallowed entire amount of purchases made from above said two parties as bogus in nature and accordingly disallowed the purchases amount of Rs.32 ... High Court in the case of Mohamed Haji Qadam has held that the difference between the regular profit margin and the margin on alleged bogus purchases should be added. He submitted that no addition would be warranted, if the above said decision of the Hon‟ble Bombay High Court

Manish P. Lathia, HUF, Mumbai vs. Income Tax Officer 27 (2) (2), Mumbai

In the result, the appeal filed by the Assessee is partly allowed

ITA 2906/MUM/2024[2009-10]Status: DisposedITAT Mumbai12 Dec 2024AY 2009-10

Bench: Shri Narender Kumar Choudhryassessment Year: 2009-10

For Appellant: Shri Mehul Shah, Ld. A.RFor Respondent: Shri V.K. Chaturvedi, Sr. D.R
Section 250

Lathia, HUF 2. Considering the peculiar facts and circumstances specifically to the effect that the Ld. Commissioner has affirmed the addition @ 12.5% of the bogus purchases and the Assessee is engaged in the business of ferrous articles and there are various judgments by the Jurisdictional Tribunal, wherein the addition ... therefore, in the considered opinion of this Court, it would be appropriate to restrict the addition being the gross profit @ 5% of the alleged bogus purchases instead of 12.5% as made by the Assessing Officer (AO) and affirmed by the Ld. Commissioner. Thus, the AO is directed to verify “whether

Vinesh Arvindkumar Shah, Mumbai City vs. ITO- Ward 19(3)(1), Mumbai

In the result, the appeal filed by the Assessee stands partly allowed

ITA 2121/MUM/2024[2011-12]Status: DisposedITAT Mumbai12 Dec 2024AY 2011-12

Bench: Shri Narender Kumar Choudhryassessment Year: 2011-12

For Appellant: Ms. Tisha Bagh, Ld. A.RFor Respondent: Shri V.K. Chaturvedi, Sr. D.R
Section 144Section 250

Department. On perusal of the above documents, it is noted that there is clear evidence that appellant has indulged in accommodation bills through booking bogus purchases thereby reducing profit and thus evaded taxes. There are no evidences for bogus sales. Appellant also not submitted any evidence like Purchase and Sales ... rights of the Assessee, if addition is to be affirmed then 100% cannot be made, as the profit element embedded in the bogus purchases can only be added in view of the judgment passed by the Hon’ble Jurisdictional High Court in the case of Pr. CIT vs. M/s. Mohammad

Gaurika Multitrade Private Limited, Mumbai vs. PCIT, Mumbai-8, Mumbai

In the result, appeal of the assessee is allowed

ITA 1977/MUM/2024[2017-18]Status: DisposedITAT Mumbai12 Dec 2024AY 2017-18

Bench: SHRI AMIT SHUKLA (Judicial Member)

Section 133(6)Section 133ASection 144Section 147Section 148Section 2(23)Section 263

pages 135 to 148. The ld. AO after examining all these documents accepted the returned income and no addition was made on account of bogus purchases once it was found to be genuine in light of these documents. 4. The ld. PCIT on perusal of the assessment records noted that ... perused the relevant material placed on record. As discussed above, the assessee’s case was reopened u/.147 specifically to enquire upon the alleged bogus purchases made from Kusum Multitrade Pvt. Ltd. The assessee in response to the notices issued by the ld. AO has filed all the replies alongwith

Neetu, Faridabad vs. Income Tax Officer Ward - 2(1), Faridabad, Haryana

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

ITA 1230/DEL/2024[2021-22]Status: DisposedITAT Delhi12 Dec 2024AY 2021-22

Bench: Ms. Madhumita Roy & Smt Renu Jauhriassessment Year : 2021-22

For Respondent: Sh. Amit Katoch, SR DR

erred in upholding the order of the assessing officer with respect to addition of Rs. 3,01,34,118/-, being 25% of the alleged bogus purchase without appreciating the evidence filed on record. 2. That in the facts and circumstances of the case and in law, the Ld. CIT (Appeals ... erred in upholding the order of the assessing officer with respect to addition of Rs. 11,10,532/-, being 100% of the alleged bogus purchase with Mr. Raju merely due to his denial of the transaction. 3. That in the facts and circumstances of the case and in law, without

Hari Krushna Machintech Private Ltd., Ahmedabad vs. The Dy.CIT, Circle-2(1)(1), Ahmedabad

In the result, all the three appeals filed by the assessee are partly allowed for statistical purposes

ITA 1616/AHD/2024[2014-15]Status: DisposedITAT Ahmedabad11 Dec 2024AY 2014-15

Bench: Dr. Brr Kumar & Ms. Suchitra Kamble

Section 143(3)

erred in confirming the addition of Rs.11,84,57,168/- made by the Assessing Officer treating the purchases from A.V. Sales as alleged bogus purchases holding that the A.V. Sales has not carried out any purchase and sales during the year. 7. The Learned Commissioner of Income Tax (Appeals), National ... genuineness of the purchases made and no reply was filed, the said purchase of Rs.11.84,57,168/- from AV Sales was only a bogus purchase to reduce income. Thus, addition of Rs.11,84,57,168/-was made to the total income of the assessee vide Assessment Order dated

Hari Krushna Machintech Private Ltd., Ahmedabad vs. The Dy.CIT, Circle-2(1)(1), Ahmedabad

In the result, all the three appeals filed by the assessee are partly allowed for statistical purposes

ITA 1554/AHD/2024[2014-15]Status: DisposedITAT Ahmedabad11 Dec 2024AY 2014-15

Bench: Dr. Brr Kumar & Ms. Suchitra Kamble

Section 143(3)

erred in confirming the addition of Rs.11,84,57,168/- made by the Assessing Officer treating the purchases from A.V. Sales as alleged bogus purchases holding that the A.V. Sales has not carried out any purchase and sales during the year. 7. The Learned Commissioner of Income Tax (Appeals), National ... genuineness of the purchases made and no reply was filed, the said purchase of Rs.11.84,57,168/- from AV Sales was only a bogus purchase to reduce income. Thus, addition of Rs.11,84,57,168/-was made to the total income of the assessee vide Assessment Order dated

Hari Krushna Machintech Private Ltd., Ahmedabad vs. The Dy.CIT, Circle-2(1)(1), Ahmedabad

In the result, all the three appeals filed by the assessee are partly allowed for statistical purposes

ITA 1553/AHD/2024[2012-13]Status: DisposedITAT Ahmedabad11 Dec 2024AY 2012-13

Bench: Dr. Brr Kumar & Ms. Suchitra Kamble

Section 143(3)

erred in confirming the addition of Rs.11,84,57,168/- made by the Assessing Officer treating the purchases from A.V. Sales as alleged bogus purchases holding that the A.V. Sales has not carried out any purchase and sales during the year. 7. The Learned Commissioner of Income Tax (Appeals), National ... genuineness of the purchases made and no reply was filed, the said purchase of Rs.11.84,57,168/- from AV Sales was only a bogus purchase to reduce income. Thus, addition of Rs.11,84,57,168/-was made to the total income of the assessee vide Assessment Order dated

Rajeshbhai Mohanbhai Prajapati, Ahmedabad vs. The Income Tax Officer, Ward-3(3)(5), Ahmedabad

In the result, both appeals of the assessee are partly allowed for statistical purposes, subject to the levy of costs

ITA 1098/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad11 Dec 2024AY 2017-18

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.1097/Ahd/2024 & 1098/Ahd/2024 िनधा"रण वष" /Assessment Years : 2016-17 & 2017-18 Respectively Rajeshbhai Mohanbhai Prajapati The Ito बनाम/ D-Ff 108 Pushp Business Ward-3(3)(5) V/S. Campus Ahmedabad Vastral Cross Roads Sp Ring Road, Vastral Ahmedabad – 382 445 (Gujarat) "थायी लेखा सं./Pan:Atspp 0059 P अपीलाथ%/ (Appellant) &' यथ%/ (Respondent) Assessee By : Shri Jignesh Shah, Adv. Revenue By : Shri V. Nandakumar, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 10/12/2024 घोषणा की तारीख /Date Of Pronouncement: 11/12/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

For Appellant: Shri Jignesh Shah, AdvFor Respondent: Shri V. Nandakumar, CIT-DR
Section 115BSection 142(1)Section 144Section 147Section 148Section 250Section 68

wholly illegal, unlawful and against the principles of natural justice. 2. The NFAC erred in disallowing the appellant's claim for alleged bogus purchases without considering that the Ld. AO had accepted the corresponding sales made by the appellant. When sales have been accepted, corresponding purchases should have been accepted

Rajeshbhai Mohanbhai Prajapati, Ahmedabad vs. The Income Tax Officer, Ward-3(3)(5), Ahmedabad

In the result, both appeals of the assessee are partly allowed for statistical purposes, subject to the levy of costs

ITA 1097/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad11 Dec 2024AY 2016-17

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.1097/Ahd/2024 & 1098/Ahd/2024 िनधा"रण वष" /Assessment Years : 2016-17 & 2017-18 Respectively Rajeshbhai Mohanbhai Prajapati The Ito बनाम/ D-Ff 108 Pushp Business Ward-3(3)(5) V/S. Campus Ahmedabad Vastral Cross Roads Sp Ring Road, Vastral Ahmedabad – 382 445 (Gujarat) "थायी लेखा सं./Pan:Atspp 0059 P अपीलाथ%/ (Appellant) &' यथ%/ (Respondent) Assessee By : Shri Jignesh Shah, Adv. Revenue By : Shri V. Nandakumar, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 10/12/2024 घोषणा की तारीख /Date Of Pronouncement: 11/12/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

For Appellant: Shri Jignesh Shah, AdvFor Respondent: Shri V. Nandakumar, CIT-DR
Section 115BSection 142(1)Section 144Section 147Section 148Section 250Section 68

wholly illegal, unlawful and against the principles of natural justice. 2. The NFAC erred in disallowing the appellant's claim for alleged bogus purchases without considering that the Ld. AO had accepted the corresponding sales made by the appellant. When sales have been accepted, corresponding purchases should have been accepted

Finesse Jewels Private Limited, Jaipur vs. Deputy Commissioner of Income, Circle 1, Jpr, Jaipur

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

ITA 1249/JPR/2024[2012-13]Status: DisposedITAT Jaipur11 Dec 2024AY 2012-13

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyalfinesse Jewels Private Limited, A-467 Jaipur, Vidhyut Nagar, Jaipur, Ajmer Road- 302 021. Pan No.: Aabcf 4438R ..... Appellant Vs. Dcit, Circle-1, Jaipur – 302 021. ..... Respondent

For Appellant: Mr. Mukesh Kumar Sharma, Adv., Ld. ARFor Respondent: Mr. Gautam Singh Choudhary, JCIT, DR
Section 143(3)Section 250Section 271(1)(c)

making an addition of Rs. 12,20,250/-. This addition was made on account of disallowance @ 25% on alleged bogus purchase of Rs. 48,81,000/- and commission paid on the same @ 2% amounting to Rs. 9,762/-. 3. The assessee being aggrieved party, preferred an appeal before ... order of the Ld. CIT (A) and submissions of the assessee alongwith grounds taken before us. It is observed that amount of alleged bogus purchase is not under challenge neither by the assessee nor by the revenue. Other point to be considered is that the entry provider already accepted

Manoj Shantilal Mehta, Mumbai vs. ITO, Ward, 27(2)(2), Mumbai

In the result, the appeal of the assessee is allowed

ITA 5636/MUM/2024[20009-10]Status: DisposedITAT Mumbai11 Dec 2024

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri B.R. Baskaranassessment Year : 2009-10 Manoj Shantilal Mehta, Income Tax Officer, B-504, Rajshree Residency, Ward-27(2)(2), Mavroji Cross Lane, Vs. 4Th Floor, Ghatkopar (West), Vashi Railway Station, Mumbai. Navi Mumbai. Pan : Acjpm8523H (Appellant) (Respondent) For Assessee : Shri Ketan Gada For Revenue : Shri R.R. Makwana, Sr.Dr Date Of Hearing : 11-12-2024 Date Of Pronouncement : 11-12-2024

For Appellant: Shri Ketan GadaFor Respondent: Shri R.R. Makwana, Sr.DR
Section 271(1)(c)

reopened the assessment of the year under consideration on the reasoning that the assessee has availed accommodation bills in the form of bogus purchases and disallowed purchase value of Rs.1.65 crores. When the matter reached ITAT, the 2 Tribunal, vide its order dt.29-05-2018 passed in ITA No. 1227/Mum/2016 and C.O.No ... 267/Mum/2017, restricted the addition to 4% of the value of the alleged bogus purchases. Thereafter, the AO levied a penalty u/s. 271(1)(c) of the Act of Rs.5,12,499/- on the addition so sustained by the ITAT. The said penalty was confirmed by the Ld.CIT

Income Tax Officer 42(1)(2), Mumbai, Bandra Kurla Complex vs. Dilip Ramniklal Bania, Mumbai

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

ITA 3733/MUM/2023[2011-12]Status: DisposedITAT Mumbai11 Dec 2024AY 2011-12

Bench: Shri Narender Kumar Choudhryassessment Year: 2011-12

For Appellant: NoneFor Respondent: Shri V.K. Chaturvedi, Sr. D.R
Section 133(6)Section 142(1)Section 144Section 145(3)Section 147Section 148Section 250Section 69C

involved in the business of issuing bogus bills for commission, without actually entering into actual business and the Assessee was also beneficiary of such bogus purchase bills during the 2 Shri Dilip Ramniklal Bania assessment year under consideration, allegedly accepted from the following parties: Name of the party ... case of CIT vs La Medica and Allahabad High Court in the case of Sri Ganesh Rice Mills Vs CIT where disallowance of bogus purchase of these concerns was confirmed by the Hon'ble High Courts.” 4. The AO ultimately treated the purchases made from the above 4 parties amounting

Income Tax Officer, Ward 7(2)(1), Mumbai vs. Magnetic Properties Exim Pvt. Ltd., Mumbai

In the result, the appeal of the Revenue is dismissed

ITA 2617/MUM/2023[2011-12]Status: DisposedITAT Mumbai11 Dec 2024AY 2011-12

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri B.R. Baskaranassessment Year : 2011-12 Income Tax Officer, Magnetic Properties Exim Pvt. Ward-7(2)(1), Ltd., Room No. 126-H, Vs. 477, Babyloan Building, Aayakar Bhavan, Adenwala Road, Maharshi Karve Road, Matunga, Mumbai. Mumbai. Pan : Aagcm8999K (Appellant) (Respondent) For Assessee : Shri Neelkanth Khandelwal For Revenue : Shri R.R. Makwana, Sr.Dr Date Of Hearing : 05-12-2024 Date Of Pronouncement : 11-12-2024 O R D E R Per B.R. Baskaran, A.M :

For Appellant: Shri Neelkanth KhandelwalFor Respondent: Shri R.R. Makwana, Sr.DR
Section 147Section 148Section 68

AAGCM8999K). The following details were provided by the Investigation Wing in which the assessee company was termed as the beneficiary, in respect of bogus purchases made by the company through the following entities which are as under. S.No. Name of the Hawala Entity as PAN Amount (Rs.) per list ... reopened the assessment on the basis of information received from the Investigation Wing that the assessee is a beneficiary by way of bogus purchases made from two companies mentioned above. The aggregate sum of purchases was mentioned by the AO as Rs.2,05,00,000/- in the reasons recorded

Ashok Kumar Gupta, Delhi vs. ITO Ward 56(4), Delhi

In the result, the appeal of the assessee is allowed

ITA 3657/DEL/2019[2010-11]Status: DisposedITAT Delhi10 Dec 2024AY 2010-11

Bench: Shri Satbeer Singh Godara & Shri M. Balaganeshashok Kumar Gupta, Vs. Ito, B-3, West Gorkh Park, Ward-56(4), Shahadra, Delhi New Delhi (Appellant) (Respondent) Pan: Agjpg4741M

For Appellant: Shri Prince Mohan Singh, AdvFor Respondent: Shri Poojan Rana, Sr. DR
Section 143(3)Section 147

accordingly they had supplied bogus bills to the assessee and assessee had transacted with them by obtaining accommodation entry in the form of bogus purchases for which purpose the assessee‟s case was sought to be reopened. The reasons recorded by the Learned AO for reopening the assessment are reproduced ... form of sale/purchase of products, My assessee, Sh. Ashok Kumar Gupta has taken accommodation entry of Rs. 7,88,910/- by making bogus purchases from non existed entity. In view of the above facts and observation, I have reason to believe that income of Rs. 7,88,910/- the assessee

ACIT-3(1)(1), Ambawadi vs. Omshiv Fabricshub Pvt. Ltd., Navrangpura

In the result, the appeal of the Revenue is dismissed

ITA 1098/AHD/2023[2013-14]Status: DisposedITAT Ahmedabad09 Dec 2024AY 2013-14

Bench: Ms. Suchitra Kamble & Shri Makarand Vasant Mahadeokarआयकर अपील सं./Ita No. 1098/Ahd/2023 िनधा"रण वष" / Asstt. Year: 2013-2014

For Appellant: Shri Tushar Hemani, Sr. Advocate with Shri Parimalsinh B Parmar, ARFor Respondent: Shri RN Dsouza, CIT. DR
Section 129Section 131Section 132(4)Section 142(1)Section 143(3)Section 147Section 148Section 68

facts in not considering that all the concerns through which the assessee had entered into circular trading transactions would show bogus purchases, bogus sales and bogus expenditure to accommodate the assessee. 4. The appellant craves leave to add, alter and/or to amend all or any of the ground before ... ascertained nor the assessee came forward to explain the same. Thus, the assessee entered into circular trading transactions which shows it as bogus purchases, bogus sales and bogus expenditure to accommodate the assessee. The Ld. DR submitted that the CIT(A) relied upon the order of the Hon’ble Settlement