2026 (7) TMI 398

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....T(A) has manifestly erred in sustaining disallowance of Rs. 1,92,47,792/- on account of purchases of jewellery as made by the AO by alleging the same to be in the nature of bogus purchases. 2. That on the facts and circumstances of the case and in the law the CIT(A) has manifestly erred in sustaining disallowance of Rs. 1,92,47,792/- on account of purchase of jewellery when as a matter of fact the said purchases have been incorporated in sales to the extent of Rs. 53,88,946/- inclusive of gross profit and in the closing stock to the extent of Rs. 1,48,74,451/- and that the quantitative details with respect to purchase of jewellery have also been accepted by the concerned VAT authorities and the books of accounts of assessee having ....

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....re the AO from time to time have been accepted by the AO and not rejected by invoking the provision of section 145(3) of the Act. Further the quantitative details with respect to purchases etc. have also been accepted by the concerned VAT authorities. The return of income was e-filed on 19.9.2017 showing total income of Rs. 1688080/-. The AO completed the assessment u/s. 143(3) on income of Rs. 20935870/- after making addition of Rs. 19247792/- for bogus purchases against which the assessee preferred appeal before the Ld. CIT(A). The Ld. CIT(A) upheld the action of the AO by dismissing the appeal of the assessee. Aggrieved, assessee is in appeal before us. 3. Ld. AR submitted that Ld. CIT(A) has erred in sustaining disallowance of Rs. 1,....

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....he case of Balaji Rice Industries vs. ITO (2025) 171 taxmann.com 612. - Decision of Gujarat High Court in the case of PCIT vs. Rakesh Kailashchand Jain (2023) 156 taxmann.com 82 (Guj) - Decision of Gujarat High Court in the case of PCIT vs. Mohit Pukhraj Kawdiya (2025) 181 taxmann.com 712 (Guj.) - Decision of Gujarat High Court in the case of Vijay Trading Co. vs. ITO (2016) 76 taxmann.com 366 (Guj.) - Decision of Delhi ITAT in the case of DCIT vs. Sharp Mint Ltd. (2024) 159 taxmann.com 1381 - Decision of Mumbai ITAT in the case of Indravadan Hanjarimal Jain vs. DCIT (2025) 180 taxmann.com 308. - Decision of Surat ITAT in the case of DCIT vs. Center Point Gems (P) Ltd. (2024) 164 taxmann....