2026 (4) TMI 1399

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....nnavaram Kosuri, SR. AR ORDER PER AMIT SHUKLA (J.M): The present appeal has been preferred by the Revenue assailing the impugned order dated 21.10.2025 passed by the learned Addl./JCIT(A)-7, Kolkata, arising out of the assessment framed under section 143(3) read with section 147 of the Income Tax Act, 1961 for the assessment year 2011-12. 2. The solitary grievance raised by the Revenue....

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....d a belief that the assessee had obtained accommodation entries in the garb of purchases from certain parties, aggregating to Rs. 1,23,750/-. Proceeding on this premise, the Assessing Officer disallowed the entire purchases treating the same as non-genuine. 4. The learned CIT(A), however, after considering the material on record and following the ratio laid down by the Hon'ble jurisdictional Hi....

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....ails of purchases and corresponding sales, ledger accounts of the suppliers, as well as sales invoices raised on third parties to whom the goods were ultimately sold, along with evidence of receipt of sale consideration through banking channels. 6. Not only this, it is an undisputed position that the Assessing Officer has accepted the corresponding sales declared by the assessee, which, in itse....

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....entire addition appears to have been made in a mechanical manner, solely on the basis of third-party information, without affording proper opportunity to the assessee to rebut the same, thereby falling short of the requirements of principles of natural justice. 8. In this backdrop, once the assessee has demonstrated, through cogent documentary evidences, that the purchases are duly recorded in ....