2025 (5) TMI 2052 - AT - Income Tax

Tax Appeals Dismissed: Bogus Purchases Exposed, Income Tax Additions Upheld Under Section 69A Without Credible Rebuttal

Pooja Enterprises Versus ACIT, Central Circle-14, Delhi.

ITAT Delhi dismissed tax appeals after assessee's non-appearance. Search and survey evidence revealed bogus purchases, leading to income tax additions ... Additions arise out of the search action carried out by authorities under the CGST Department and also survey conducted u/s 133A at the office premises of the assessee - HELD THAT:- Based upon the incriminating evidences found during the search and survey operations, the issue of bogus purchases was examined leading to disallowances under various heads and also additions u/s 69A of the Act. After going through the impugned orders, we find that the ld. tax authorities have duly appreciated the incriminating materials for drawing inferences and in the absence of any factual assistance to counter the findings of ld. tax authorities, we find no reason to interfere. The grounds have no substance. Both the appeals are dismissed. The Appellate Tribunal (ITAT Delhi) dismissed the assessee's appeals against the Commissioner of Income-tax (Appeals)-26 orders dated 28.03.2024 and 02.04.2024, arising from assessments under sections 153A read with 143(3) and 143(3) of the Income Tax Act, 1961. Despite repeated notices, the assessee failed to appear before the Tribunal. The additions challenged primarily stemmed from a search and survey under section 133A, conducted by the CGST Department, which revealed incriminating evidence of bogus purchases, resulting in disallowances and additions under section 69A. The Tribunal held that the tax authorities 'have duly appreciated the incriminating materials for drawing inferences' and, in the absence of any factual rebuttal from the assessee, found 'no reason to interfere.' Consequently, the appeals were dismissed.