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876 results for “bogus purchases”+ Section 263clear

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Key Topics

Section 263187Section 143(3)90Section 14781Addition to Income63Section 6835Section 14834Section 13231Section 115J27Disallowance27Section 153A

VAKSONS METAPLAST PVT LTD,DELHI vs. PCIT(CENTRAL), DELHI

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

ITA 2217/DEL/2025[2018-19]Status: DisposedITAT Delhi05 Dec 2025AY 2018-19

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Smt. Rano Jain, AdvocateFor Respondent: Shri Amit Jain, CIT DR
Section 115BSection 132Section 139Section 143Section 153Section 153CSection 234ASection 263Section 69C

263 of the Act. We further observed that the incriminating material found during the search not only discloses the details of bogus purchases and also disclosed details about bogus sales. Ld. PCIT is silent on this aspect. 10. Further we observed that Assessing Officer had not dealt with the issue of section

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VAKSONS METAPLAST PVT LTD,DELHI vs. PCIT(CENTRAL), DELHI

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

ITA 2216/DEL/2025[2017-18]Status: DisposedITAT Delhi05 Dec 2025AY 2017-18

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Smt. Rano Jain, AdvocateFor Respondent: Shri Amit Jain, CIT DR
Section 115BSection 132Section 139Section 143Section 153Section 153CSection 234ASection 263Section 69C

263 of the Act. We further observed that the incriminating material found during the search not only discloses the details of bogus purchases and also disclosed details about bogus sales. Ld. PCIT is silent on this aspect. 10. Further we observed that Assessing Officer had not dealt with the issue of section

VAKSONS METAPLAST PVT LTD,DELHI vs. PCIT(CENTRAL), DELHI

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

ITA 2218/DEL/2025[2019-20]Status: DisposedITAT Delhi05 Dec 2025AY 2019-20

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Smt. Rano Jain, AdvocateFor Respondent: Shri Amit Jain, CIT DR
Section 115BSection 132Section 139Section 143Section 153Section 153CSection 234ASection 263Section 69C

263 of the Act. We further observed that the incriminating material found during the search not only discloses the details of bogus purchases and also disclosed details about bogus sales. Ld. PCIT is silent on this aspect. 10. Further we observed that Assessing Officer had not dealt with the issue of section

HORIZON DWELLINGS PRIVATE LIMITED,BAREILLY vs. PCIT, BAREILLY

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

ITA 77/LKW/2022[2017-2018]Status: DisposedITAT Lucknow06 Jan 2025AY 2017-2018

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguriahorizon Dwellings Pvt Ltd V. Pcit, Bareilly, Navjeevan Appartments, Income Tax Department, Opposite Parag Factory, Bareilly (Up)-243001. Badaun Road, Kargaina, Bareilly-243001. Pan:Aacch6839F (Appellant) (Respondent) Appellant By: Shri Rakesh Garg, Adv. Respondent By: Shri Sunil Kumar Rajwanshi, Addl. Cit(Dr) O R D E R

For Appellant: Shri Rakesh Garg, AdvFor Respondent: Shri Sunil Kumar Rajwanshi, Addl
Section 143(3)Section 263

purchases by the assessee from Jour parties mentioned by the DIT (Investigation) Mumbai in its report were bogus. The decision of the Mumbai and Delhi ITAT in the case of M/s. Shri Narayan Tatu Rane (supra) and M/s. Amira Pure Foods (P) Ltd. (supra) cited by the Ld. AR clearly supports the view that Explanation-2 to sec. 263

M/S. MUKKA PROTEINS LIMITED (FORMERLY KNOW AS MUKKA SEA FOOD INDUSTRIES LTD., ),MANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, , MANGALURU

In the result, appeals of the assessee in ITA Nos

ITA 431/BANG/2024[2013-14]Status: DisposedITAT Bangalore03 Jul 2024AY 2013-14

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Sri Narendra Sharma, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 132Section 132(4)Section 153ASection 153DSection 234A

purchase price being inflated cannot be ruled out and there is no material to dislodge such finding. The issue is not whether the purchase price reflected in the books of account matches the purchase price stated to have been paid to other persons. The issue is whether the purchase price paid by the assessee is reflected as receipts

DEPUTY COMMISSIONER OF INCOME TAX-1(1), RAIPUR vs. SHANTA TECHNO PRIVATE LIMITED, RAIPUR

ITA 155/RPR/2025[2018-19]Status: DisposedITAT Raipur18 Jun 2025AY 2018-19

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 155/Rpr/2025 (िनधा"रण वष" Assessment Year: 2018-19)

For Appellant: NoneFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 142(1)Section 147Section 148Section 250Section 69C

section 145(3) of the Act, the Assessing Officer acquired the mandate even to add the whole amount of purchases found as bogus to the total income of the assessee. One such case was Sri Ganesh Rice Mills Vs. CIT 294 ITR 316 (All) wherein the entire amount of bogus purchases, from 5 parties, was disallowed and same was also

SILMOHAN GEMS PVT LTD. COMPANY,MUMBAI vs. DCIT, CIRCLE-5(3)(1), MUMBAI

In the result, the appeals of the assessee

ITA 472/MUM/2023[2012-13]Status: DisposedITAT Mumbai13 Jun 2023AY 2012-13

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Appellant: Ms. Mitali Mehta a/wFor Respondent: Dr. Kishor Dhule, CIT-DR
Section 40A(3)Section 69C

section 69C of the Act and for which no evidence has been 69C of the Act and for which no evidence has been 69C of the Act and for which no evidence has been furnished to the contrary in the support of the claim of the furnished to the contrary in the support of the claim of the furnished

SILMOHAN GEMS PVT LTD. COMPANY,MUMBAI vs. DCIT, CIRCLE-5(3)(1), MUMBAI

In the result, the appeals of the assessee

ITA 471/MUM/2023[2013-14]Status: DisposedITAT Mumbai13 Jun 2023AY 2013-14

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Appellant: Ms. Mitali Mehta a/wFor Respondent: Dr. Kishor Dhule, CIT-DR
Section 40A(3)Section 69C

section 69C of the Act and for which no evidence has been 69C of the Act and for which no evidence has been 69C of the Act and for which no evidence has been furnished to the contrary in the support of the claim of the furnished to the contrary in the support of the claim of the furnished

DCIT 5(3)(1), MUMBAI vs. SILMOHAN GEMS PRIVATE LIMITED, MUMBAI

In the result, the appeals of the assessee

ITA 449/MUM/2023[2013-2014]Status: DisposedITAT Mumbai13 Jun 2023AY 2013-2014

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Appellant: Ms. Mitali Mehta a/wFor Respondent: Dr. Kishor Dhule, CIT-DR
Section 40A(3)Section 69C

section 69C of the Act and for which no evidence has been 69C of the Act and for which no evidence has been 69C of the Act and for which no evidence has been furnished to the contrary in the support of the claim of the furnished to the contrary in the support of the claim of the furnished

DCIT 5(3)(1), MUMBAI vs. SILMOHAN GEMS PRIVATE LIMTED , MUMBAI

In the result, the appeals of the assessee

ITA 450/MUM/2023[2012-2013]Status: DisposedITAT Mumbai13 Jun 2023AY 2012-2013

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Appellant: Ms. Mitali Mehta a/wFor Respondent: Dr. Kishor Dhule, CIT-DR
Section 40A(3)Section 69C

section 69C of the Act and for which no evidence has been 69C of the Act and for which no evidence has been 69C of the Act and for which no evidence has been furnished to the contrary in the support of the claim of the furnished to the contrary in the support of the claim of the furnished

JALALABAD SOLVEX PRIVATE LTD,JALALABAD vs. PR COMMISSIONER OF INCOME TAX , AMRITSAR-1, PR COMMISSIONER OF INCOME TAX

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

ITA 117/ASR/2024[2014-2015]Status: DisposedITAT Amritsar29 Jan 2025AY 2014-2015

Bench: Sh. Udayan Dasgupta & Sh. Krinwant Sahay

For Appellant: Sh. Ashwani Kalia, C.A
Section 143(1)Section 143(3)Section 144BSection 147Section 148Section 263Section 263(1)

section 263(1) of the Act, 1961 and as per the opinion of the Ld . PCIT, the assessment order has been passed without making inquiries or verification which should have been made, and he has observed, that the AO had concluded that the appellant had made bogus purchase

M/S RADHISHWARI DEVLOPERS P LTD,INDORE vs. PR CIT -2 INDORE, INDORE

In the result, Assessee’s appeal in ITANo

ITA 493/IND/2018[13-14]Status: DisposedITAT Indore20 Jul 2021

Bench: Hon’Ble Rajpal Yadav & Hon’Ble Manish Boradvirtual Hearing Assessment Year 2013-14 M/S. Radhishwari Developers P. Ltd. (Now Known As R.C. Warehousing Pvt. Ltd. ) Indore : Appellant Pan :Aafcr1916A V/S Pr. Cito-2 : Respondent Indore Appellant By S/Shri Sumit Nema Sr. Adv. With Gagan Tiwari & Piyush Parashar Advs. Revenue By Shri S.S. Mantri, Cit-Dr Date Of Hearing 24.05.2021 Date Of Pronouncement 20.07.2021

Section 133(6)Section 143(2)Section 143(3)Section 263

bogus nature of the subject transactions. This, under such circumstances the order passed by the learned Assessing Officer u/s 143(3) cannot be said as prejudicial to the interest of the revenue and thus, needs to be quashed. M/s. Radheshwari Developers Pvt. Ltd. Without prejudice further, to the above it is submitted that the recourse to section 263

HMA AGRO INDUSTRIES LIMITED,AGRA vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE, AGRA, AGRA

In the result, ground no.1 raised by the Revenue is accordingly dismissed

ITA 251/AGR/2025[2018-2019]Status: DisposedITAT Agra04 Dec 2025AY 2018-2019

Bench: Shris.Rifaur Rahman & Shri Sunil Kumar Singhhma Agro Industries Limited, Vs. Dcit, Central Circle, 2/220, 2Nd Floor, Glory Plaza, Agra. Opp. Soor Sadan, M.G. Road, Agra – 282 002. (Pan :Aacch0450J)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Arun Kumar Yadav, CIT DR
Section 143(3)Section 147Section 148Section 263Section 40ASection 68

section 263 read with explanation 2(a). Therefore, he supported the detailed findings in revision order. 7. Considered the rival submissions and material available on record. We observed that the assessee is in the business of exporting meat and meat products. It purchases livestock from various suppliers in turn they purchases the same from the local market or directly from

ACIT, CC, AGRA, AGRA vs. HMA AGRO INDUSTRIES LIMITED,, AGRA

In the result, ground no.1 raised by the Revenue is accordingly dismissed

ITA 303/AGR/2025[2023-24]Status: DisposedITAT Agra04 Dec 2025AY 2023-24

Bench: Shris.Rifaur Rahman & Shri Sunil Kumar Singhhma Agro Industries Limited, Vs. Dcit, Central Circle, 2/220, 2Nd Floor, Glory Plaza, Agra. Opp. Soor Sadan, M.G. Road, Agra – 282 002. (Pan :Aacch0450J)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Arun Kumar Yadav, CIT DR
Section 143(3)Section 147Section 148Section 263Section 40ASection 68

section 263 read with explanation 2(a). Therefore, he supported the detailed findings in revision order. 7. Considered the rival submissions and material available on record. We observed that the assessee is in the business of exporting meat and meat products. It purchases livestock from various suppliers in turn they purchases the same from the local market or directly from

ACIT, CC, AGRA, AGRA vs. HMA AGRO INDUSTRIES LIMITED,, AGRA

In the result, ground no.1 raised by the Revenue is accordingly dismissed

ITA 301/AGR/2025[2021-22]Status: DisposedITAT Agra04 Dec 2025AY 2021-22

Bench: Shris.Rifaur Rahman & Shri Sunil Kumar Singhhma Agro Industries Limited, Vs. Dcit, Central Circle, 2/220, 2Nd Floor, Glory Plaza, Agra. Opp. Soor Sadan, M.G. Road, Agra – 282 002. (Pan :Aacch0450J)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Arun Kumar Yadav, CIT DR
Section 143(3)Section 147Section 148Section 263Section 40ASection 68

section 263 read with explanation 2(a). Therefore, he supported the detailed findings in revision order. 7. Considered the rival submissions and material available on record. We observed that the assessee is in the business of exporting meat and meat products. It purchases livestock from various suppliers in turn they purchases the same from the local market or directly from

M/S DIN DAYAL PURSOTAM LAL,SIRSA vs. PR.CIT, ROHTAK

ITA 148/CHANDI/2021[2016-17]Status: DisposedITAT Chandigarh04 Mar 2024AY 2016-17

Bench: SHRI A.D.JAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Gautam Jain, Advocate &For Respondent: Shri Rohit Sharma, CIT-DR
Section 147Section 263Section 40A(3)

bogus purchases had been ITA 146,147 & 148/CHD/2021 A.Y. 2011-12, 2015-16 & 2016-17 31 made; that since the additions in such type of cases depend on the facts of each case, the provisions of Section 263

M/S DIN DAYAL PURSOTAM LAL,SIRSA vs. PR.CIT, ROHTAK

ITA 146/CHANDI/2021[2011-12]Status: DisposedITAT Chandigarh04 Mar 2024AY 2011-12

Bench: SHRI A.D.JAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Gautam Jain, Advocate &For Respondent: Shri Rohit Sharma, CIT-DR
Section 147Section 263Section 40A(3)

bogus purchases had been ITA 146,147 & 148/CHD/2021 A.Y. 2011-12, 2015-16 & 2016-17 31 made; that since the additions in such type of cases depend on the facts of each case, the provisions of Section 263

M/S DIN DAYAL PURSOTAM LAL,SIRSA vs. PR.CIT, ROHTAK

ITA 147/CHANDI/2021[2015-16]Status: DisposedITAT Chandigarh04 Mar 2024AY 2015-16

Bench: SHRI A.D.JAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Gautam Jain, Advocate &For Respondent: Shri Rohit Sharma, CIT-DR
Section 147Section 263Section 40A(3)

bogus purchases had been ITA 146,147 & 148/CHD/2021 A.Y. 2011-12, 2015-16 & 2016-17 31 made; that since the additions in such type of cases depend on the facts of each case, the provisions of Section 263

SHIVAM READYMIX PRIVATE LIMITED,NEEMUCH vs. THE PCIT(CENTRAL), JAIPUR

In the result, the appeal of the assessee is allowed

ITA 412/JPR/2024[2013-14]Status: DisposedITAT Jaipur12 Nov 2024AY 2013-14

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Tarun Mittal (C.A.)For Respondent: Ms. Alka Gautam (CIT)
Section 143(3)Section 153ASection 153DSection 263Section 69C

bogus purchases as compared to G.P. on normal purchases In the present case also, since the ld. AO has examined the profit worked out on unaccounted purchases and has accepted such working prepared by assessee by observing that : “It is also submitted that assessee company has now offered the additional undisclosed income based on GP rate of its business activity

ACIT, CC, AGRA, AGRA vs. HMA AGRO INDUSTRIES LIMITED,, AGRA

In the result, appeal filed by the assessee for AY 2019-20 is\nallowed and appeals filed by the Revenue in AYs 2021-22, 2022-23 and\n2023-24 are dismissed

ITA 302/AGR/2025[2022-23]Status: DisposedITAT Agra04 Dec 2025AY 2022-23
Section 143(3)Section 147Section 148Section 263Section 40ASection 68

bogus purchases from Md. Irfan. The Assessing Officer (AO) initially accepted the purchases as genuine after investigations, but the Principal Commissioner (PCIT) initiated revision proceedings u/s 263, viewing the AO's assessment as erroneous and prejudicial.", "held": "The Tribunal held that the PCIT had erred in invoking Section