2026 (6) TMI 1321

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....Abhijit, Sr.DR ORDER PER SANJAY GARG, JUDICIAL MEMBER: The present appeal has been preferred by the Assessee against the order of the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as 'CIT(A)'] dated 09.12.2025 for the Assessment Year (AY) 2018-19. 2. The assessee in this appeal raised following grounds of appeal: ....

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.... legally unsustainable. 4. The learned CIT(A) erred in relying upon third-party statements and general observations without providing the appellant an effective opportunity to cross-examine the persons whose statements were relied upon, in gross violation of the principles of natural justice. 5. The appellant craves leave to add, amend, modify, or withdraw any of the above ground....

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....on available, the five entities as mentioned in the assessment order were involved in providing accommodation entries by way of fictitious/bogus invoices. The AO found that the Assessee had made total purchases of Rs. 50,33,695/- from the alleged entities involved in providing bogus billings. He added the entire purchases of Rs. 50,33,695 /- into the income of the Assessee. The Ld. CIT(A) confirme....

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....dly involved in providing bogus billing etc., the probability at the most can be that the Assessee might have made purchases from the grey market at a lower rate and would have obtained bogus bills at a higher rate from the alleged entities to suppress his profits. Under the circumstances, as held time and again by various courts of law, only the profit element embedded in such purchase/sales tran....