2026 (2) TMI 1052

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Shri Virabhadra Mahajan, Sr. DR ORDER PER SANDEEP SINGH KARHAIL, J.M. The assessee has filed the present appeals against the separate impugned orders of even date 19.09.2025, passed under section 250 of the Income Tax Act, 1961 ("the Act") by the learned Additional / Joint Commissioner of Income Tax (Appeals)-1, Vadodara ["learned Addl./Joint CIT(A)"], which in turn arose from the separat....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....nt order passed under section 143(3) read with section 147 of the Act, the Assessing Officer ("AO") made an addition of 12.5% of the total non-genuine purchases by the assessee. In further appeal, the learned CIT(A) confirmed the addition made by the AO. The Coordinate Bench of the Tribunal, in further appeal by the assessee in quantum proceedings, vide order dated 11.09.2019 passed in ITAs No. 13....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... proceedings, on account of bogus purchases by bringing to tax the estimated profit element embedded in such purchases, being 12.5% of the total non-genuine purchases by the assessee in the years under consideration, which was further reduced by the Tribunal to 5%. Therefore, the entire addition for the years under consideration has been made solely on the basis of estimates. 6. We find that th....