TaxTMI 
TaxTMI 
2026 (9) TMI 1881
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.... DR ORDER PER SUDHIR KUMAR, JUDICIAL MEMBER: This appeal by the assessee is directed against the order of the National Faceless Appeal Centre (NFAC) Delhi [hereinafter referred to as ("Ld. NFAC)"] vide order dated 05-01-2026 arising out of the order of the Assessing Officer vide order dated 18-03- 2024 for A.Y. 2019-20. 2. The assessee has raised the following grounds in appeal:- ....
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....as carried out in the case of Ashok Kumar Gupta on 30-11-2018. During course of survey proceedings Shri Ashok Kumar Gupta has admitted on oath that the he is engaged in providing accommodation entries of non-genuine purchases and non-genuine sales through various entities managed by Shri Ashok Kumar Gupta and his family members. The case of the assessee was reopened based on the information gather....
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....) has observed in his order as under: 6.5 In this case the AO has not disputed the sales or rejected the books. Therefore, to realise sales of Rs. 14,06,46,095(SHB Agro Foods), purchases amounting to Rs. 3,10,50,000/- could not have been wholly bogus. In this case purchasing from non- genuine suppliers, or from the grey market at lower rates and recording same at inflated price in books o....
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....to the various parties and payment was received in bank account of the assessee. The AO accepted the sales made by assessee. Without purchases no sale can be made. He further submitted that the 12.5 % gross profit on the alleged purchases was wrongly made. The Ld. Departmental Representative submitted that the because the AO has disallowed the bogus purchases on account of bogus expenses under bus....