2025 (12) TMI 424

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....) upholding the addition of Rs. 26,07,801/- as made by the learned AO u/s 69C of the Act by treating the purchases from M/s Ultra Trade Mart as unexplained expenditure. 4. The facts in brief are that the learned AO noted that the as per the information flagged on insight portal, the assessee is a beneficiary of accommodation entries from M/s Ultra Trade Mart. Accordingly, the case of the assessee was reopened u/s 147 of the Act by issuing notice u/s 148 of the Act on 29.03.2023, after passing the order u/s 148A(d) of the Act. Thereafter, statutory notices along with questionnaire were issued and served upon the assessee. The learned AO noted that as per the information, the assessee was engaged in providing bogus GST Invoices for passing....

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....essee has furnished the copy of purchase bills, e-way bills, consignment notes, ledger copy of M/s Ultra Trade Mart along with relevant portion of bank statement evidencing the payment through banking channels, which are available at page no.31 to 50 of the Paper Book. We note that these evidences were also available before the authorities below. Considering these evidences on record we find that the purchases made by the assessee were used in the manufacturing process and the ld. AO has not brought on record any other evidences other than the report of the CGST qua the assessee that it is engaged in the bogus/ fake purchases invoices. Consequently, we set aside the order of ld. CIT(A) and direct the ld. AO to delete the addition. The groun....

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.... the rival contentions and perusing the materials available on record, we find that the assessee inter alia has raised unsecured loans from five parties namely Budapest Traders, Emperor Marketing, Essence Dealmarks Pvt. Ltd., Megha Associates and VKS Jaiswal, aggregating to Rs. 2,21,00,000/-. The assessee filed before the ld. AO as well as before the ld. CIT(A) copies of ITRs, confirmation of accounts, bank statements etc. the copies of which are available from page no.52 to 76 of the Paper Book. The assessee also submitted that it had filed the written submissions before the ld. CIT(A), a copies of which are attached at page no.102 to 110. The written submissions are dated 16.06.2025 and 23.06.2026. We note that the assessee has furnished ....