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1,004 results for “bogus purchases”+ Section 3clear

Sorted by relevance

Mumbai6,309Delhi2,909Kolkata1,004Jaipur680Ahmedabad669Chennai595Surat464Pune419Bangalore392Chandigarh300Hyderabad244Indore217Raipur174Rajkot145Karnataka128Amritsar120Nagpur120Visakhapatnam87Lucknow82Guwahati76Cuttack70Cochin67Calcutta67Agra54Jodhpur51Patna38Allahabad35Ranchi32Telangana20Dehradun19Jabalpur14Varanasi8SC7Panaji5Orissa3Gauhati2Bombay1Rajasthan1ASHOK BHAN DALVEER BHANDARI1Punjab & Haryana1

Key Topics

Section 147114Section 14892Addition to Income82Section 6868Section 143(3)59Section 25031Section 26327Section 143(2)24Unexplained Cash Credit

INCOME TAX OFFICER-WARD-12(1), KOLKATA, KOLKATA vs. M/S STANDARD LEATHER PVT. LTD., KOLKATA

In the result, Revenue’s appeal stands dismissed

ITA 2620/KOL/2013[2010-2011]Status: DisposedITAT Kolkata07 Sept 2016AY 2010-2011

Bench: Shri Waseem Ahmed & Shri S.S.Viswanethra Raviassessment Years:2010-11

Section 133(6)Section 143(3)Section 40A(3)

3) of the Act. In the first place, the appellant has amply demonstrated by producing material evidence that the purchases supported with corresponding manufacture and sales are genuine. Secondly, merely because the notices under sec. 133(6) issued to the sellers/ producers of hides and skin render the purchases bogus, and if at all rendered bogus, provisions of section

DCIT, CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. BALAJEE MINI STEELS & REROLLING PRIVATE LIMITED , PATNA

In the result, the appeals of the Revenue are dismissed

Showing 1–20 of 1,004 · Page 1 of 51

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24
Section 10(38)22
Disallowance22
Limitation/Time-bar19
ITA 1688/KOL/2025[2015-16]Status: DisposedITAT Kolkata15 Dec 2025AY 2015-16

Bench: Shri Rajesh Kumar, Am\Nand\Nshripradip Kumar Choubey, Jm\Nita Nos.1688 To 1691/Kol/2025\N(Assessment Years: 2015-16 To 2018-19)\Nita No. 1725/Kol/2025\N(Assessment Year: 2016-17)\Ndcit, Central Circle 4(3)\Nbalajee Mini Steels & Rerolling\Naaykar Bhawan Poorva, 110,\Nprivate Limited\Nshantipally, Kolkata-700107,\N603, Shantikunj Apartment,\Nkolkata\Nphulwanipatna, G.P.O.800001,\N(Appellant)\Nvs.\Npatna\Npan No. Aabcb7265J\N(Respondent)\Nassessee By\N: Shri Manish Rastogi, Ar\Nrevenue By\N: S/Shri Praveen Kishore &\Npradeep Dungdung, Drs\Ndate Of Hearing:\N01.12.2025\Ndate Of Pronouncement: 15.12.2025\Norder\Nper Rajesh Kumar, Am:\Nthese Appeals Preferred By The Revenue Against The Orders Of The Commissioner Of Income-Tax (Appeals), Kolkata-27 (Hereinafter Referred To As The “Ld. Cit(A)”] Dated 13.04.2025 For The Ays 2015-16 To 2018-19.\N2.\Nas The Facts & Issues In All The Appeals Of Revenue Are Exactly Identical, Hence, For The Sake Of Brevity, We Take Ita No. 1688/Kol/2025 For A.Y. 2015-16 & Decide The Issue Accordingly.\Nα.Υ. 2015-16\N3.\Nthe Only Issue Raised By The Revenue Is Against The Deletion Of Addition By The Id. Cit (A) Of ₹1,07,03,817/- As Made By The Id. Ao On Account Of Suppression Of Income In Respect Of Bogus Purchases.\N3.

Section 132Section 139(1)Section 147

3% of the bogus purchases on the ground that these purchases were to cover the purchases made from the grey market which were purchased at a much lesser price than the purchases made from the open market.\nThe CIT in exercise of his revisionary powers under section

DCIT, CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. BALAJEE MINI STEELS & REROLLING PRIVATE LIMITED , PATNA

In the result, the appeals of the Revenue are dismissed

ITA 1725/KOL/2025[2016-17]Status: DisposedITAT Kolkata15 Dec 2025AY 2016-17

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm

For Appellant: Shri Manish Rastogi, ARFor Respondent: S/Shri Praveen Kishore &
Section 132Section 139(1)Section 147

3% of the bogus purchases on the ground that these purchases were to cover the purchases made from the grey market which were purchased at a much lesser price than the purchases made from the open market. The CIT in exercise of his revisionary powers under section

OM FORGING & ENGINEERING PRIVATE LIMITED,KOLKATA vs. THE PR. CIT-1, KOLKATA, KOLKATA

In the result the appeals are allowed

ITA 509/KOL/2017[2010-11]Status: DisposedITAT Kolkata13 Dec 2017AY 2010-11

Bench: Hon’Ble Shri N.V.Vasudevan, Jm & Dr.Arjun Lal Saini, Am ]

For Appellant: Shri A.K.Tibrewal, FCAFor Respondent: Md.Usman, CIT(DR)
Section 143(2)Section 147Section 263

bogus purchases worth Rs.72,84,304/-. The following were the relevant observations of the AO in this regard :- A.Y.2010-11 “However as per information received from the sales tax department communicated by the DGIT ( Inv.\). Mumbai as mentioned earlier, the assessee company has inflated its purchase by procuring false purchase bills from the concern called Divya Enterprise and Kamal Traders during

DCIT, CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. BALMUKUND CEMENT & ROOFINGS PRIVATE LIMITED , KOLKATA

The appeal of the revenue is dismissed

ITA 1702/KOL/2025[2018-19]Status: DisposedITAT Kolkata09 Dec 2025AY 2018-19

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Manish Rastogi, ARFor Respondent: Shri Pankaj Pandey, DR
Section 115JSection 132Section 147Section 148Section 69A

3% of the bogus purchases on the ground that these purchases were to cover the purchases made from the grey market which were purchased at a much lesser price than the purchases made from the open market. The CIT in exercise of his revisionary powers under section

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. BALMUKUND SPONGE AND IRON PRIVATE LIMITED, PATNA

The appeal of the revenue is dismissed

ITA 1596/KOL/2025[2016-17]Status: DisposedITAT Kolkata09 Dec 2025AY 2016-17

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Manish Rastogi, ARFor Respondent: Shri Pankaj Pandey, DR
Section 115JSection 132Section 147Section 148Section 69A

3% of the bogus purchases on the ground that these purchases were to cover the purchases made from the grey market which were purchased at a much lesser price than the purchases made from the open market. The CIT in exercise of his revisionary powers under section

DCIT, CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. BALMUKUND CEMENT & ROOFINGS PRIVATE LIMITED , KOLKATA

The appeal of the revenue is dismissed

ITA 1703/KOL/2025[2020-21]Status: DisposedITAT Kolkata09 Dec 2025AY 2020-21

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Manish Rastogi, ARFor Respondent: Shri Pankaj Pandey, DR
Section 115JSection 132Section 147Section 148Section 69A

3% of the bogus purchases on the ground that these purchases were to cover the purchases made from the grey market which were purchased at a much lesser price than the purchases made from the open market. The CIT in exercise of his revisionary powers under section

DCIT, CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. BALMUKUND CEMENT & ROOFINGS PRIVATE LIMITED , KOLKATA

The appeal of the revenue is dismissed

ITA 1699/KOL/2025[2015-16]Status: DisposedITAT Kolkata09 Dec 2025AY 2015-16

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Manish Rastogi, ARFor Respondent: Shri Pankaj Pandey, DR
Section 115JSection 132Section 147Section 148Section 69A

3% of the bogus purchases on the ground that these purchases were to cover the purchases made from the grey market which were purchased at a much lesser price than the purchases made from the open market. The CIT in exercise of his revisionary powers under section

GOPAL & SONS HUF,KOLKATA vs. I.T.O., WARD - 32(1), KOLKATA, KOLKATA

The appeal of the revenue is dismissed

ITA 1701/KOL/2024[2006-2007]Status: DisposedITAT Kolkata08 Jan 2025AY 2006-2007

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Manish Rastogi, ARFor Respondent: Shri Pankaj Pandey, DR
Section 115JSection 132Section 147Section 148Section 69A

3% of the bogus purchases on the ground that these purchases were to cover the purchases made from the grey market which were purchased at a much lesser price than the purchases made from the open market. The CIT in exercise of his revisionary powers under section

SANDIP KUMAR TEKRIWAL HUF,KOLKATA vs. PRINCIPAL CIT - 10, KOLKATA , KOLKATA

In the result, these three appeals of three assessees are allowed

ITA 1135/KOL/2018[2010-11]Status: DisposedITAT Kolkata22 Jan 2020AY 2010-11

Bench: Shri S.S.Godara, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.1134/Kol/2018 ("नधा"रणवष" / Assessment Year:2010-11)

For Appellant: Shri Pramod Himat Singhka, FCAFor Respondent: Shri Radhey Shyam, CIT
Section 143(1)Section 263

3% on account of bogus purchases which is quite reasonable, hence order passed by Assessing Officer is neither erroneous nor prejudicial to the interest of Revenue. We note that just to gather more material to prove the claim of the assessee wrong, is not the object of section

SHRI PRAMOD KUMAR TEKRIWAL,KOLKATA vs. PRINCIPAL CIT - 10, KOLKATA , KOLKATA

In the result, these three appeals of three assessees are allowed

ITA 1136/KOL/2018[2010-11]Status: DisposedITAT Kolkata22 Jan 2020AY 2010-11

Bench: Shri S.S.Godara, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.1134/Kol/2018 ("नधा"रणवष" / Assessment Year:2010-11)

For Appellant: Shri Pramod Himat Singhka, FCAFor Respondent: Shri Radhey Shyam, CIT
Section 143(1)Section 263

3% on account of bogus purchases which is quite reasonable, hence order passed by Assessing Officer is neither erroneous nor prejudicial to the interest of Revenue. We note that just to gather more material to prove the claim of the assessee wrong, is not the object of section

BINOD KUMAR TEKRIWAL HUF,KOLKATA vs. PRINCIPAL CIT - 10, KOLKATA , KOLKATA

In the result, these three appeals of three assessees are allowed

ITA 1134/KOL/2018[2010-11]Status: DisposedITAT Kolkata22 Jan 2020AY 2010-11

Bench: Shri S.S.Godara, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.1134/Kol/2018 ("नधा"रणवष" / Assessment Year:2010-11)

For Appellant: Shri Pramod Himat Singhka, FCAFor Respondent: Shri Radhey Shyam, CIT
Section 143(1)Section 263

3% on account of bogus purchases which is quite reasonable, hence order passed by Assessing Officer is neither erroneous nor prejudicial to the interest of Revenue. We note that just to gather more material to prove the claim of the assessee wrong, is not the object of section

ACIT, CIRCLE - 34, KOLKATA , KOLKATA vs. BHAWARLAL ALOKE KUMAR , KOLKATA

Appeal is dismissed

ITA 779/KOL/2018[2014-15]Status: DisposedITAT Kolkata03 May 2019AY 2014-15

Bench: Shri S.S.Godara & Dr. A.L. Sainiassessment Year :2014-15 Acit, Cicle-34, V/S. Bhawarlal Aloke Kumar Aayakar Poorva, 7Th P-12, New Howrah Bridge Approach Road, 4Th Floor, Floor, 110, Shantipally, Kolkatka-107 Kolkta-700001 [Pan No.Aadfb 0620 N] .. अपीलाथ" /Appellant ""यथ"/Respondent Shri Robin Choudhury, Addl. Cit-Dr अपीलाथ" क" ओर से/By Appellant None ""यथ" क" ओर से/By Respondent 04-02-2019 सुनवाई क" तार"ख/Date Of Hearing 03-05-2019 घोषणा क" तार"ख/Date Of Pronouncement आदेश /O R D E R Per S.S.Godara:- This Assessee‘S Appeal For Assessment Year 2014-15 Arises Against The Commissioner Of Income Tax (Appeals)-10, Kolkata’S Order Dated 23.01.2018 Passed In Case No.224/Cit(A)-10/C-34/14-15/16-17/Kol, Involving Proceedings U/S 143(3) Of The Income Tax Act, 1961; In Short ‘The Act’. Case Called Twice. None Appears At The Assessee’S Behest Despite The Registry Having Sent An Rpad Notice. It Is Accordingly Proceeded Ex Parte. 2. Revenue’S Sole Substantive Grievance Raised In The Instant Appeal Seeks To Challenge Correctness Of Cit(A)’S Action Partly Upholding Assessing Officer’S Findings Disallowing Assessee’S Purchase(S) Of ₹3,22,28,000/- Only To The Extent Of 15% Vide Impugned Following Detailed Discussion:- “06. Findings &. Decision:

Section 143(3)

section 143(3) of the Income Tax Act and the profit ratios after addition of the entire alleged bogus purchases

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. BALMUKUND SPONGE AND IRON PRIVATE LIMITED, PATNA

The appeal of the Revenue is dismissed

ITA 1597/KOL/2025[2017-18]Status: DisposedITAT Kolkata09 Dec 2025AY 2017-18
Section 115JSection 132Section 147Section 148Section 69A

3% of the bogus purchases on the ground that these\npurchases were to cover the purchases made from the grey market which were\npurchased at a much lesser price than the purchases made from the open market.\nThe CIT in exercise of his revisionary powers under section

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. BALMUKUND SPONGE AND IRON PRIVATE LIMITED , PATNA

The appeal of the Revenue is dismissed

ITA 1595/KOL/2025[2015-16]Status: DisposedITAT Kolkata09 Dec 2025AY 2015-16
Section 115JSection 132Section 147Section 148Section 69A

3% of the bogus purchases on the ground that these\npurchases were to cover the purchases made from the grey market which were\npurchased at a much lesser price than the purchases made from the open market.\nThe CIT in exercise of his revisionary powers under section

DCIT, CENTRAL CIRCLE- 4(3), KOLKATA, KOLKATA vs. BALMUKUND CEMENT & ROOFINGS PRIVATE LIMITED , KOLKATA

The appeal of the Revenue is dismissed

ITA 1700/KOL/2025[2016-17]Status: DisposedITAT Kolkata09 Dec 2025AY 2016-17
For Appellant: Shri Manish Rastogi, ARFor Respondent: Shri Pankaj Pandey, DR
Section 115JSection 132Section 147Section 148Section 69A

3% of the bogus purchases on the ground that these\npurchases were to cover the purchases made from the grey market which were\npurchased at a much lesser price than the purchases made from the open market.\nThe CIT in exercise of his revisionary powers under section

DCIT, CENTRAL CIRCLE- 4(3), KOLKATA, KOLKATA vs. BALAJEE MINI STEELS & REROLLING PRIVATE LIMITED , PATNA

In the result, the appeals of the Revenue are dismissed

ITA 1691/KOL/2025[2018-19]Status: DisposedITAT Kolkata15 Dec 2025AY 2018-19

Bench: Shri Rajesh Kumar, Am\Nand\Nshripradip Kumar Choubey, Jm\Nita Nos.1688 To 1691/Kol/2025\N(Assessment Years: 2015-16 To 2018-19)\Nita No. 1725/Kol/2025\N(Assessment Year: 2016-17)\Ndcit, Central Circle 4(3)\Nbalajee Mini Steels & Rerolling\Naaykar Bhawan Poorva, 110,\Nprivate Limited\Nshantipally, Kolkata-700107,\N603, Shantikunj Apartment,\Nkolkata\Nphulwanipatna, G.P.O.800001,\Nvs.\N(Appellant)\Npatna\N(Respondent)\Npan No. Aabcb7265J\Nassessee By\N:\Nshri Manish Rastogi, Ar\Nrevenue By\N:\Ns/Shri Praveen Kishore &\Npradeep Dungdung, Drs\Ndate Of Hearing:\N01.12.2025\Ndate Of Pronouncement:\N15.12.2025\Norder\Nper Rajesh Kumar, Am:\Nthese Are Appeals Preferred By The Revenue Against The Orders Of The Commissioner Of Income-Tax (Appeals), Kolkata-27 (Hereinafter Referred To As The “Ld. Cit(A)"] Dated 13.04.2025 For The Ays 2015-16 To 2018-19.\Nas The Facts & Issues In All The Appeals Of Revenue Are Exactly Identical, Hence, For The Sake Of Brevity, We Take Ita No. 1688/Kol/2025 For A.Y. 2015-16 & Decide The Issue Accordingly.\Nα.Υ. 2015-16\Npage 2\Nita Nos.1688 To 1691/Kol/2025&1725/Kol/2025\Nbalajee Mini Steels & Rerolling Private Limited; Ays 2015-16 To 2018-19\Nita No. 1688/Kol/2025\N3.\Nthe Only Issue Raised By The Revenue Is Against The Deletion Of Addition By The Id. Cit (A) Of ₹1,07,03,817/- As Made By The Id. Ao On Account Of Suppression Of Income In Respect Of Bogus Purchases.\N3.

Section 132Section 139(1)Section 147

3% of\nthe bogus purchases on the ground that these purchases were to cover the\npurchases made from the grey market which were purchased at a much lesser\nprice than the purchases made from the open market.\nThe CIT in exercise of his revisionary powers under section

DCIT, CENTRAL CIRCLE-4(3), KOLKATA , KOLKATA vs. BALAJEE MINI STEELS & REROLLING PRIVATE LIMITED , PATNA

In the result, the appeals of the Revenue are dismissed

ITA 1689/KOL/2025[2016-17]Status: DisposedITAT Kolkata15 Dec 2025AY 2016-17

Bench: Shri Rajesh Kumar, Am\Nand\Nshripradip Kumar Choubey, Jm\Nita Nos.1688 To 1691/Kol/2025\N(Assessment Years: 2015-16 To 2018-19)\Nita No. 1725/Kol/2025\N(Assessment Year: 2016-17)\Ndcit, Central Circle 4(3)\Nbalajee Mini Steels & Rerolling\Naaykar Bhawan Poorva, 110,\Nprivate Limited\Nshantipally, Kolkata-700107,\N603, Shantikunj Apartment,\Nkolkata\Nvs.\Nphulwanipatna, G.P.O.800001,\N(Appellant)\Npatna\N(Respondent)\Npan No. Aabcb7265J\Nassessee By\Nshri Manish Rastogi, Ar\Nrevenue By\Ns/Shri Praveen Kishore &\Npradeep Dungdung, Drs\Ndate Of Hearing: 01.12.2025\Ndate Of Pronouncement: 15.12.2025\Norder\Nper Rajesh Kumar, Am:\Nthese Are Appeals Preferred By The Revenue Against The Orders Of\Nthe Commissioner Of Income-Tax (Appeals), Kolkata-27 (Hereinafter\Nreferred To As The “Ld. Cit(A)"] Dated 13.04.2025 For The Ays 2015-16\Nto 2018-19.\Nas The Facts & Issues In All The Appeals Of Revenue Are Exactly\Nidentical, Hence, For The Sake Of Brevity, We Take Ita No.\N1688/Kol/2025 For A.Y. 2015-16 & Decide The Issue Accordingly.\Nα.Υ. 2015-16\Npage 2\Nita Nos.1688 To 1691/Kol/2025&1725/Kol/2025\Nbalajee Mini Steels & Rerolling Private Limited; Ays 2015-16 To 2018-19\Nita No. 1688/Kol/2025\N3.\Nthe Only Issue Raised By The Revenue Is Against The Deletion Of\Naddition By The Id. Cit (A) Of ₹1,07,03,817/- As Made By The Id. Ao\Non Account Of Suppression Of Income In Respect Of Bogus Purchases.\N3.

Section 132Section 139(1)Section 147

3% of\nthe bogus purchases on the ground that these purchases were to cover the\npurchases made from the grey market which were purchased at a much lesser\nprice than the purchases made from the open market.\nThe CIT in exercise of his revisionary powers under section

DCIT, CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. BALAJEE MINI STEELS & REROLLING PRIVATE LIMITED , PATNA

In the result, the appeals of the Revenue are dismissed

ITA 1690/KOL/2025[2017-18]Status: DisposedITAT Kolkata15 Dec 2025AY 2017-18

Bench: Shri Rajesh Kumar, Am\Nand\Nshripradip Kumar Choubey, Jm\Nita Nos.1688 To 1691/Kol/2025\N(Assessment Years: 2015-16 To 2018-19)\Nita No. 1725/Kol/2025\N(Assessment Year: 2016-17)\Ndcit, Central Circle 4(3)\Nbalajee Mini Steels & Rerolling\Naaykar Bhawan Poorva, 110,\Nprivate Limited\Nshantipally, Kolkata-700107,\N603, Shantikunj Apartment,\Nkolkata\Nphulwanipatna, G.P.O.800001,\N(Appellant)\Nvs.\Npatna\N(Respondent)\Npan No. Aabcb7265J\Nassessee By : Shri Manish Rastogi, Ar\Nrevenue By : S/Shri Praveen Kishore &\Npradeep Dungdung, Drs\Ndate Of Hearing: 01.12.2025\Ndate Of Pronouncement: 15.12.2025\Norder\Nper Rajesh Kumar, Am:\Nthese Are Appeals Preferred By The Revenue Against The Orders Of\Nthe Commissioner Of Income-Tax (Appeals), Kolkata-27 (Hereinafter\Nreferred To As The “Ld. Cit(A)"] Dated 13.04.2025 For The Ays 2015-16\Nto 2018-19.\Nas The Facts & Issues In All The Appeals Of Revenue Are Exactly\Nidentical, Hence, For The Sake Of Brevity, We Take Ita No.\N1688/Kol/2025 For A.Y. 2015-16 & Decide The Issue Accordingly.\Nα.Υ. 2015-16\Npage 2\Nita Nos.1688 To 1691/Kol/2025&1725/Kol/2025\Nbalajee Mini Steels & Rerolling Private Limited; Ays 2015-16 To 2018-19\Nita No. 1688/Kol/2025\N3.\Nthe Only Issue Raised By The Revenue Is Against The Deletion Of\Naddition By The Id. Cit (A) Of ₹1,07,03,817/- As Made By The Id. Ao\Non Account Of Suppression Of Income In Respect Of Bogus Purchases.\N3.

For Appellant: Shri Manish Rastogi, ARFor Respondent: S/Shri Praveen Kishore &
Section 132Section 139(1)Section 147

3% of\nthe bogus purchases on the ground that these purchases were to cover the\npurchases made from the grey market which were purchased at a much lesser\nprice than the purchases made from the open market.\nThe CIT in exercise of his revisionary powers under section

DCIT, CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. BALMUKUND CEMENT & ROOFINGS PRIVATE LIMITED , KOLKATA

The appeal of the Revenue is dismissed

ITA 1704/KOL/2025[2023-24]Status: DisposedITAT Kolkata09 Dec 2025AY 2023-24
Section 115JSection 132Section 147Section 148Section 69A

3% of the bogus purchases on the ground that these\npurchases were to cover the purchases made from the grey market which were\npurchased at a much lesser price than the purchases made from the open market.\nThe CIT in exercise of his revisionary powers under section