2026 (6) TMI 607

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....Shri Hiren Vepari, A.R. For the Respondent : Shri Ajay Uke, Sr. DR ORDER PER SHRI NARENDRA PRASAD SINHA, AM: This appeal is filed by the assessee against the order of the Commissioner of Income Tax, Appeal, ADDL/JCIT (A)-1, Delhi, (in short 'the CIT(A)'), dated 29.09.2025 for the Assessment Year 2011-12 in the proceedings under Section 147 read with Section 143(3) of the Income Tax Act....

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.... 4. Now, the assessee is second appeal before us. 5. Shri Hiren Vepari, Ld. AR appearing for the assessee submitted that the Ld. CIT(A) was not correct in confirming the addition of entire purchase of Rs. 5,95,728/- made from M/s. Ankita Exports, alleged to have been operated by Shri Bhanvarlal Jain Group. He submitted that the disallowance in the case of unexplained purchases should have be....

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....ders could be added and upheld the addition of 12.5% sustained by the Tribunal. In the case of Bholanath Poly Fab P. Ltd. (40 taxmann.com 494 (Guj,)) also, the Hon'ble Gujarat High Court had reiterated that only profit margin embedded in bogus purchases could be subjected to tax and not the entire purchases. Similarly, Hon'ble Gujarat High Court in the case of Kesari Exports, (174 taxmann.com 162)....