Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.266/Ran/2023 Assessment Year: 2018-19 Rajendra Shangari, Jamshedpur.................…...........................……….……Appellant Plot 9, Bhuiyadih, Agrico, Jamshedpur – 831009. [Pan: Alcps6310F] Vs. Dcit, Circle-1, Jamshedpur.....…..….…..….........……........……...…..…..Respondent Appearances By: Shri Akshay Ringasia, Ar, Appeared On Behalf Of The Appellant. Shri Vinod Agarwal, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : July 09, 2025 Date Of Pronouncing The Order : July 15, 2025 Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against An Order Dated 16.11.2023 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. Brief Facts Of The Case Are That The Assessee Is An Individual Who Is Engaged In Contractual Jobs To Tata Steel & State Government Wherein The Final Job Is Subject To Strict Scrutiny By Officials & Government Inspectors & Filed Return Of Income Declaring An Income Of Rs.2,58,20,920/- For The Assessment Year 2018-19. Subsequently, In The Case Of The Assessee, The Assessing Officer Invoked Section 148 Proceedings & Completed The Assessment U/S 147 R.W.S. 144B Of The Act By Adding An Amount Of Rs.38,46,188/- To The Income Of The Assessee Stating That The Alleged Sum Was Bogus Purchase. 3. Dissatisfied With The Above Order, The Assessee Preferred An Appeal Before The Ld. Cit(A) Against The Reassessment Order, Where The Ld. Cit(A)

58,20,920/- for the assessment year 2018-19. Subsequently, in the case of the assessee, the Assessing Officer invoked section 148 proceedings and completed the assessment u/s 147 r.w.s. 144B of the Act by adding an amount of Rs.38,46,188/- to the income of the assessee stating that the alleged sum was bogus purchase. 3. Dissatisfied with