TaxTMI 
TaxTMI 
2026 (6) TMI 552
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.... orders of the ld. Assessing Officer (hereinafter referred to as the Ld. AO, for short) passed u/s 153C r.w.s 153A of the Income-tax Act, 1961 (hereafter referred to as 'the Act'). Further details of the orders of the lower authorities are as under: - ITA No. & AY Ld. FAA who passed the appellate order Appeal No. & Date of order of the Ld. FAA AO who passed the assessment order & Date of order 8537/D/25 2019-20 CIT(A)-30, New Delhi DIN No : ITBA/APL/M/250/2025-26/1082630383(1) Dated 14.11.2025 ACIT, CC-31, New Delhi Dated 30.03.2024 8538/D/25 2020-21 CIT(A)-30, New Delhi DIN No : ITBA/APL/M/250/2025-26/1082547995(1) Dated 12.11.2025 DCIT, CC-31, New Delhi Dated 29.03.2024 2. Heard and perused the recor....
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....atisfaction dated 05.08.2022 that the seized documents, being ledgers of the assessee in seized tally data and the information contained in the ledgers relates to a person other than the searched person i.e.Ahluwalia Contracts India Ltd (the assessee). 4. On perusal of the ledgers of the assessee, ld. AO concluded that the assessee made purchases from M/s Shri Lakshmi Associates, M/s Forever Exim India Pvt. Ltd., M/s Jain Cement Udyog and M/s Mahaveer Associates during F.Ys. 2018-19 and 2019-20. The stated entities were controlled and managed by Shri Sanjay Jain for bogus billing and the same had also been admitted by Shri Sanjay Jain in his statement. Further, on perusal of statement of Shri Sanjay Jain recorded on oath u/s 131 of the A....
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....r Exim India Private Limited." 6. However, ld. AO concluded that quantitative details and movement of goods has been proved. However, the admission made by Shri Sanjay Jain cannot be ignored. Under these circumstances, it is understood that it is a case of untested purchases wherein actual purchases are made from grey market in cash and bills and vouchers for purchase are obtained from bill providers accommodation entry to suppress profit. To further verify this fact, notice u/s 142(1) dated 02.05.2023 was issued to the assessee to furnish comparative price of Cement purchased from Forever Exim India Private Limited, M/s Jain Cement Udyog, M/s Mahaveer Associates and M/s Shri Lakshmi Associates and other vendors. In response to the notic....
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....ledgers, account confirmations, e-way bills, bank statements highlighting payments, cement stock registers, gate entry registers, store entry records with details like MR No., Date GR No., and evidence of utilization in construction. The appellant argues that suspicion based on information from another authority is not a basis for addition, and cites judicial precedents where courts have held that even in cases of bogus purchases, only the profit element embedded therein should be added as income. 7.1 Upon detailed examination of the AO's order and the record, it is evident that the assessee was afforded full opportunity during assessment to substantiate the transactions. The documents submitted were evaluated but found lacking....
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....re amount, especially when quantitative details of opening stock, purchases, and manufacturing support that goods were obtained but through unrecorded means. Here, the addition stems from incriminating material seized during a search u/s 132, including the direct admission by Shri Sanjay Jain the alleged supplier/entry provider) that bogus bills were issued without actual supply, and the assessee was given opportunity for cross-examination which it declined. Thus, the AO's findings are based on concrete evidence from the search, not mere external information, and the appellant has failed to discharge the onus under a post-search assessment. Accordingly, the grounds lack merit and are accordingly dismissed." 8. The primary contention ....