ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1(1), RAIPUR vs. MESERS TIRUPATI BALAJI FOOD PRIVATE LIMITED, TILDA

In the result, appeal of the revenue in ITA No

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.202/Rpr/2018 "नधा"रण वष" / Assessment Year : 2014-15 The Assistant Commissioner Of Income Tax-1(1), Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. Tirupati Balaji Foods Pvt. Ltd., Tilda-Neora, Raipur (C.G.) Pan : Aacct7476L ……""यथ" / Respondent आयकर अपील सं. / Ita No.13/Rpr/2019 "नधा"रण वष" / Assessment Year : 2015-16 The Assistant Commissioner Of Income Tax-1(1), Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. Tirupati Balaji Foods Pvt. Ltd., Tilda-Neora, Raipur (C.G.) Pan : Aacct7476L ……""यथ" / Respondent

bogus bills only?" 3. "Whether on points of law and on fact & circumstances of the case, the Ld.CIT(A) was justified in ignoring the ratio of the ITAT Mumbai in the case of Soman Sun City Vs. JCIT, wherein it was held that purchases could not be treated as genuine even if the purchase bill produced and payment is made

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1(1), RAIPUR vs. MESERS TIRUPATI BALAJI FOOD PRIVATE LIMITED, TILDA

In the result, appeal of the revenue in ITA No

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.202/Rpr/2018 "नधा"रण वष" / Assessment Year : 2014-15 The Assistant Commissioner Of Income Tax-1(1), Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. Tirupati Balaji Foods Pvt. Ltd., Tilda-Neora, Raipur (C.G.) Pan : Aacct7476L ……""यथ" / Respondent आयकर अपील सं. / Ita No.13/Rpr/2019 "नधा"रण वष" / Assessment Year : 2015-16 The Assistant Commissioner Of Income Tax-1(1), Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. Tirupati Balaji Foods Pvt. Ltd., Tilda-Neora, Raipur (C.G.) Pan : Aacct7476L ……""यथ" / Respondent

bogus bills only?" 3. "Whether on points of law and on fact & circumstances of the case, the Ld.CIT(A) was justified in ignoring the ratio of the ITAT Mumbai in the case of Soman Sun City Vs. JCIT, wherein it was held that purchases could not be treated as genuine even if the purchase bill produced and payment is made

ASHOK KUMAR WADHWANI, RAIPUR,RAIPUR vs. INCOME TAX OFFICER, WARD-1(2), RAIPUR, RAIPUR

In the result, appeal in ITA No

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं./Ita Nos.117 &118/Rpr/2024 "नधा"रण वष" /Assessment Year: 2014-15 & 2016-17 Ashok Kumar Wadhwani, Ujwal Udyog, Sinodha, Neora, Tilda, Raipur, Chhattisgarh. Pan: Aahpw1400B .......अपीलाथ" / Appellant बनाम / V/S.

69C of the Income tax Act, 1961” The assessee stated vide order sheet dated 07/12/2016 that:- "all the purchase and sale made by the assesses during the F.Y. 2013- 14 is genuine, stock of material has been duly received & dispatched. Further, such transactions are recorded properly in the books of accounts and stock register of F.Y. 2013-14. The assessee

ASHOK KUMAR WADHWANI, RAIPUR,RAIPUR vs. INCOME TAX OFFICER, WARD-1(2), RAIPUR, RAIPUR

In the result, appeal in ITA No

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं./Ita Nos.117 &118/Rpr/2024 "नधा"रण वष" /Assessment Year: 2014-15 & 2016-17 Ashok Kumar Wadhwani, Ujwal Udyog, Sinodha, Neora, Tilda, Raipur, Chhattisgarh. Pan: Aahpw1400B .......अपीलाथ" / Appellant बनाम / V/S.

69C of the Income tax Act, 1961” The assessee stated vide order sheet dated 07/12/2016 that:- "all the purchase and sale made by the assesses during the F.Y. 2013- 14 is genuine, stock of material has been duly received & dispatched. Further, such transactions are recorded properly in the books of accounts and stock register of F.Y. 2013-14. The assessee

DEPUTY COMMISSIONER OF INCOME TAX-(1), RAIPUR, RAIPUR vs. RAJESH KUMAR SINGH, RAIPUR

In the result, this appeal of Revenue is allowed for statistical purposes

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita No: 455/Rpr/2025 (िनधा"रण वष" Assessment Year: 2022-23) Deputy Commissioner Of Income Tax, Vs Rajesh Kumar Singh, New Purena, Circle-1(1), Aaykar Bhawan, Ravigram, Ravigram S O, Civil Lines, Raipur, C. G., 492001. Raipur, Chhattisgarh, 492001 Pan: Ajnps2776H (अपीलाथ"/Appellant) (""थ" / Respondent) : िनधा"रती की ओर से / Assessee By : Shri Suraj Gupta, Advocate (Virtually) राज" की ओर से / Revenue By : Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 03/02/2026 घोषणा की तारीख / Date Of : 19/02/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: This Appeal For Assessment Year (‘Ay’) 2022-23 Filed By The Revenue Is Directed Against The Order Dated 13.05.2025 Of The Commissioner Of Income Tax (Appeals), [‘Cit(A)’], National Faceless Appeal Centre (‘Nfac’), Delhi Passed Under Section 250 Of The Income Tax Act, 1961 (‘Act’).

bogus purchases only on the basis of information received from the Verification Unit & non-compliance of suppliers to notices issued u/s 133(6) of the Act. 14 DCIT, Circle-1(1) vs. Rajesh Kumar Singh 10. The business income is computed in accordance with the provisions of section 28 to 44DB of the Act as these are enabling provisions

SHIV TRADING CO., RAIGARH,RAIGARH vs. INCOME TAX OFFICER, NFAC, DELHI

In the result, appeal of the assessee is allowed for statistical purposes in terms of my aforesaid observations

Bench: Shri Ravish Soodआयकर अपील सं./ Ita No.101/Rpr/2023 "नधा"रण वष" / Assessment Year : 2013-14 Shiv Trading Co. Saranggarh Road, Chhatamuda Chowk, Raigarh-496 001 (C.G.) Pan : Aaqfs3990K .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Nfac, Delhi. ……""यथ" / Respondent

section 69C of the income tax act, 1961. 2. The learned CIT(A) erred in sustaining the disallowance of Rs.26,88,000/- made on account of bogus purchases

SHREE SHYAM SALES CORPORATION,RAIPUR vs. INCOME TAX OFFICER, WARD -1(2), RAIPUR. (C.G.), RAIPUR

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 188/Rpr/2024 (िनधा"रण वष" Assessment Year: 2018-19)

69C in respect Of entire purchases instead of restricting the addition/disallowance to reasonable percentage of alleged bogus purchases in accordance with Law. 4. That the leaned assessing officer has erred for disallowing whole purchases by invoking section

INCOME TAX OFFICER-4(1), RAIPUR, CIVIL LINES, RAIPUR vs. SMITA MUKESH KEDIA, RAIPUR

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 451/Rpr/2025 (िनधा"रण वष" Assessment Year: 2019-20)

bogus purchases plus 6% of profit calculated by the assessee on the provisions of section 44AD of the Act and, therefore, the taxable income was reduced by Rs. 2,89,890/-. 5 ITO-4(1), Raipur Vs. Smita Mukesh Kedia 4. Being aggrieved with the aforesaid additions u/s 69C

SHANKAR RICE MILL, MAHASAMUND, MAHASAMUND vs. ITO, MAHASAMUND, MAHASAMUND

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

Bench: Shri Partha Sarathi Chaudhury & Shri Avdhesh Kumar Mishraआयकर अपील सं. / Ita No.628/Rpr/2025 "नधा"रण वष" / Assessment Year : 2014-15 Shankar Rice Mill Kh. No.161, Lakhagarh, Kishanpur B.O., Shanti Nagar, Pithora, Mahasamund Pan: Acffs3275C

purchased any bogus bills. In the absence of documentary evidence, a sum of Rs.66,50,000/- was assessed as Unexplained 3 Shankar Rice Mill Vs ITO, Mahasamund expenditure u/s. 69C of the Act and added to the income of the assessee. The A.O completed the assessment u/s.143(3) read with section

SATISH KUMAR AGRAWAL, BHILAI,DURG vs. INCOME TAX OFFICER, WARD-2(1), BHILAI, DURG

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.145/Rpr/2024 "नधा"रण वष" / Assessment Year : 2018-19 Satish Kumar Agrawal 3B, Heav Industrial Area, Hathkhoj, Bhilai, Dist. Durg-490 026 (C.G.) Pan: Adqpa1785K

purchases of Rs.1,80,84,701/- as the assessee’s unexplained investment u/s. 69C of the Act. Apart from that, the A.O holding a conviction that the assessee would have incurred expenditure/charges for procuring the accommodation entries, made an addition towards unexplained commission expenses of Rs.90,423/- i.e. @0.5% of Rs.1,80,84,701/- u/s. 69C

INCOME TAX OFFICER-2(1),BHILAI, BHILAI vs. ASHISH GUPTA, DURG

In the result, appeal of the Revenue is dismissed

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.624/Rpr/2025 "नधा"रण वष" /Assessment Year : 2010-11

69C of the Income Tax Act, 1961 ( for short ‘the Act’) as unexplained expenditure in view of the alleged bogus purchases by the assessee from M/s. Laxmi Trading Company, Raipur. The A.O in the assessment order has held and observed as follows: “In this case return of income was filed on 09/10/2010 showing total income at Rs.601110/-. The office

KAMLESH KUKREJA, RAIPUR,RAIPUR vs. ITO, WARD-1(1), RAIPUR, RAIPUR

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

Bench: Shri R. K. Panda & Shri Partha Sarathi Chaudhuryassessment Year : 2016-17 Kamlesh Kukreja Ito, Ward-1(1), Raipur Prop. Anmol Industries, Vs. Surajpura Road, Bhatapara, Raipur – 493118 Ahvpk6618C (Appellant) (Respondent) Assessee By : Shri Sunil Kumar Agrawal Department By : Dr. Priyanka Patel, Sr. Dr Date Of Hearing : 14-11-2025 Date Of Pronouncement : 01-01-2026 O R D E R Per R.K. Panda, Vp:

purchases from the various concerns of Deepak Nanjyani remained unexplained and unverifiable, the Assessing Officer, invoking the provisions of section 69C of the Act made addition of Rs.2,59,23,992/-. The Assessing Officer further made addition of Rs.2,59,240/- being the commission incurred by the assessee for the accommodation entries being @ 1% of the total accommodation entries

INCOME TAX OFFICER-1(1), BILASPUR vs. MUSADDILAL MANSARAM INFRASTRUCTURE PVT. LTD. , BILASPUR

The appeal of the assessee is allowed, whereas the appeal of revenue stands dismissed

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 160/Rpr/2025 (िनधा"रण वष" Assessment Year: 2015-16)

purchase price as per section 50C of the Act, by applying a 10% tolerance limit retrospectively, and further erred in holding that the correct provision applicable was section 56(2)(vii)(b) of the Act instead of section 69, despite the fact that section 56(2)(vii)(b) is applicable only to individuals and Hindu Undivided Families (HUFs) for Assessment

MUSADDILAL MANSARAM INFRASTRUCTURE PVT. LTD., BILASPUR,BILASPUR vs. INCOME TAX OFFICER, WARD-1(1), BILASPUR, BILASPUR

The appeal of the assessee is allowed, whereas the appeal of revenue stands dismissed

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 160/Rpr/2025 (िनधा"रण वष" Assessment Year: 2015-16)

purchase price as per section 50C of the Act, by applying a 10% tolerance limit retrospectively, and further erred in holding that the correct provision applicable was section 56(2)(vii)(b) of the Act instead of section 69, despite the fact that section 56(2)(vii)(b) is applicable only to individuals and Hindu Undivided Families (HUFs) for Assessment

SAGAR KUKREJA,BHILAI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1(1), BHILAI, BHILAI

In the result, the appellant's appeal is dismissed

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.508/Rpr/2024 "नधा"रण वष" / Assessment Year : 2018-19 Sagar Kukreja Plot No.33-34, Baba Deep Singh Nagar, Behind Sindhu Bhawan Bhilai, Supela, Bhilai (C.G.) Pan: Asmpk7043F

bogus ITC on fake sale bills for F.Y.2017-18 amounting to Rs.69,01,873/- to the assessee to claim fraudulent Input Tax Credit (ITC) and to dispose their output GST liability with the help of fake input credit as well as suppress their income by claiming fake/bogus purchases as their expenses, initiated proceedings u/s. 147 of the Act. Notice

INCOME TAX OFFICER-1(2), RAIPUR vs. KANHA GRAIN PROCESS, RAIPUR

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

Bench: Shri R. K. Panda & Shri Partha Sarathi Chaudhuryassessment Year : 2015-16 Ito, Ward 1(2), Raipur Kanha Grain Process Vs. Station Road, Tilda Neora, Raipur – 493114 Pan: Aaifk3222G (Appellant) (Respondent) Assessee By : Shri Sunil Kumar Agrawal Department By : Dr. Priyanka Patel, Sr. Dr Date Of Hearing : 14-11-2025 Date Of Pronouncement : 01-01-2026 O R D E R Per R.K. Panda, Vp:

69C of the Act on account of bogus purchases. 4. Before the Ld. CIT(A) / NFAC, the assessee apart from challenging the addition on merit, challenged the validity of re-assessment proceedings. The Ld. CIT(A) / NFAC held that the Additional Solicitor General of India, on behalf of the Revenue agreed that the notice issued

FIVE STARCONSTRUCTION COMPANY,BHILAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 1(1), BHILAI

The appeal of the assessee is partly allowed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.45/Rpr/2018 "नधा"रण वष" / Assessment Year : 2014-15 Five Star Construction Company Plot No.96-97, Light Industrial Area, Chawani Chowk, Bhilai (C.G)-490026 Pan : Aaaff4316L .......अपीलाथ" / Appellant बनाम / V/S. The Deputy Commissioner Of Income Tax-1(1), Bhilai (C.G.) ……""यथ" / Respondent

bogus cash credit under Sec.68 of 4,82,840/- the Act. 8. Addition towards unexplained cash credit under 10,00,000/- Sec.68 of the Act. 9. Addition of undisclosed contract/hiring receipts. 27,88,260/- 10. Addition of the unrecorded sale proceeds of a motor 8,10,000/- car. 11. Addition under Sec. 69C of the Act towards

VINOD KUMAR KESHARWANI, BHATAPARA,BHATAPARA vs. INCOME TAX OFFICER-1(1), RAIPUR, RAIPUR

In the result, appeal of the assessee is dismissed

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita No.80/Rpr/2025 "नधा"रण वष" / Assessment Year : 2016-17 Vinod Kumar Keshwani Vinod Dal Mill, Village: Khokhali, Bhatapara (C.G.)-493 118 Pan: Aewpk4399C

bogus purchases treating it to be unexplained expenditure u/s. 69C. The addition made by the AO is illegal, arbitrary, baseless and not justified. 2. The notice issued u/s.148 and consequent reassessment order passed by AO is illegal inasmuch as the sanction u/s. 151 from specified authority is not as per law and without jurisdiction. 3. The initiation of re-assessment