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    <title>2025 (8) TMI 764 - ITAT PUNE</title>
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    <description>The ITAT Pune upheld the CIT(A)/NFAC order rejecting the Revenue&#039;s reopening of assessment under section 147 and addition under section 68, finding no sufficient evidence that the assessee made bogus purchases in FY 2013-14. The AO failed to conduct adequate inquiry despite the assessee producing books, vouchers, and bank statements. The statement of the entry provider indicated such bogus bills were supplied only from 2018 onwards, not during the relevant year. The assessee&#039;s excess application of income under section 12A further negated the possibility of fictitious transactions. Consequently, the addition was deleted, and the penalty under section 271(1)(c) imposed by the AO was also deleted, with the ITAT dismissing the Revenue&#039;s grounds and rendering the assessee&#039;s cross-objection infructuous.</description>
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    <pubDate>Mon, 11 Aug 2025 00:00:00 +0530</pubDate>
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      <title>2025 (8) TMI 764 - ITAT PUNE</title>
      <link>https://www.taxtmi.com/caselaws?id=776576</link>
      <description>The ITAT Pune upheld the CIT(A)/NFAC order rejecting the Revenue&#039;s reopening of assessment under section 147 and addition under section 68, finding no sufficient evidence that the assessee made bogus purchases in FY 2013-14. The AO failed to conduct adequate inquiry despite the assessee producing books, vouchers, and bank statements. The statement of the entry provider indicated such bogus bills were supplied only from 2018 onwards, not during the relevant year. The assessee&#039;s excess application of income under section 12A further negated the possibility of fictitious transactions. Consequently, the addition was deleted, and the penalty under section 271(1)(c) imposed by the AO was also deleted, with the ITAT dismissing the Revenue&#039;s grounds and rendering the assessee&#039;s cross-objection infructuous.</description>
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      <pubDate>Mon, 11 Aug 2025 00:00:00 +0530</pubDate>
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