2025 (10) TMI 412

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.... Virabhadra S. Mahajan, Sr. DR ORDER PER RENU JAUHRI [A.M.] :- The present appeal filed by the assessee emanates from the Revision order u/s 263 of the Income-tax Act, 1961 [hereinafter referred to as "Act"] dated 31.03.2025 passed by the Pr. Commissioner of Income-tax, Thane - 1 [hereinafter referred to 'PCIT'] pertaining to assessment order passed u/s. 143(3) of the Income-tax Act, 1961....

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....Tax Act 1961 on 12.12.2022 and issuing direction to add entire of amount of alleged bogus purchases of Rs. 9,33,49.090/- u/s. 69C r.w.s. 115BBE of the Act. 2. The brief facts of the case are that the assessee filed return declaring loss of Rs. 6,54,10,276/- on 13.02.2021 for A.Y. 2020-2021. The case was selected for scrutiny and Ld. AO noticed that the assessee has shown bogus purchases to the ....

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....dated 31.03.2025, the Ld. PCIT set aside the AO's Order dated 12.12.2022 and directed to add the entire amount of Rs. 9,33,49,090/- under section 69C r.w.s 115BBE of the Act. Aggrieved with the order of PCIT, the assessee has preferred an appeal before the Tribunal. 4. We have heard the rival submissions and perused the material available before us. At the outset, Ld.AR has pointed out t....

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....) and restore the matter back to him for deciding afresh after considering the submission of the assessee and pass a reasoned order on the grounds raised by the assessee before him. Ld. DR, on the other hand, strongly relied on the order of Ld. PCIT. 5. After careful consideration of the peculiar facts and circumstances of this case, we are of the view that the issue regarding addition in re....