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of <h1>ITAT upholds deletion of bogus purchase additions with solid documentary proof under relevant tax provisions</h1> <h3>ITO-Ward 25 (2) (1), Mumbai Versus Smt. Anuradha R. Dalmia</h3> ITO-Ward 25 (2) (1), Mumbai Versus Smt. Anuradha R. Dalmia - TMI The Revenue appealed against the CIT(A)'s order deleting additions made on account of alleged bogus purchases of Rs. 67,11,021/- from M/s. Arun Paper & Iron Traders, a declared hawala operator, for AY 2011-12. The Assessing Officer had disallowed the purchases, estimating a 25% profit margin embedded therein, relying on the supplier's non-cooperation and returned summons under section 133(6) of the Income Tax Act. The CIT(A) remanded the matter, considering additional documents furnished by the assessee, including purchase bills, bank statements, and confirmation from the supplier. The remand report revealed that the supplier, Arun Aggarwal, confirmed the sales and supported the transactions with ledger and bank records. Notably, in AY 2009-10, additions on similar grounds were deleted after the supplier's statement confirmed genuine transactions. The Tribunal found that the assessee discharged the onus of proving the genuineness of purchases and supplier by producing relevant documentary evidence and supplier confirmation. Consequently, the Tribunal upheld the CIT(A)'s order and dismissed the Revenue's appeal as 'sans-merit,' emphasizing the absence of infirmity in the impugned order. The decision underscores the principle that where the assessee substantiates transactions with credible evidence and supplier confirmation, additions on the basis of alleged bogus purchases cannot be sustained.
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