2025 (7) TMI 312

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....ditya M. Rai, Sr.DR ORDER PER SANDEEP SINGH KARHAIL, J.M. The present appeal has been filed by the assessee challenging the impugned order dated 11/02/2025 passed under section 250 of the Income Tax Act, 1961 ("the Act") by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, ["learned CIT(A)"], for the assessment year 2011-12, which in turn arose from....

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....d is a proprietor of M/s Saba Engg Works, which is engaged in the business of manufacturing washers. For the year under consideration, the assessee filed its return of income on 30/09/2011, declaring a total income of INR 5,54,960. The return filed by the assessee was processed under section 143(1) of the Act. Subsequently, based on the information received from DGIT (Investigation), Mumbai, it wa....

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....6 passed under section 143(3) read with section 147 of the Act concluded that purchases made by the assessee from these parties are bogus and non-genuine, and therefore, the purchase rate mentioned in the alleged sales bills cannot be accepted. The AO, on the basis that the goods purchased were consumed for manufacturing the goods sold by the assessee, held that only the profit element embedded in....

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.... evident from the record that the AO treated 25% of the alleged bogus purchases as bogus and non-genuine, which was further reduced by the learned CIT(A) to 12.5%. Therefore, the entire addition has been made merely on the basis of estimation. 7. We find that the Hon'ble Rajasthan High Court in CIT v/s Krishi Tyre Retreading and Rubber Industries, reported in [2014] 360 ITR 580 (Raj.) held ....