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Accommodation Entry Purchases Confirmed for Lack of Proof

Case Law Details

TaxGuru Citation
2025 taxguru.in 13708
Case Name
Amrit Varsha Udyog Ltd. Vs DCIT (ITAT Dehradun)
Date of Judgement/Order
Only available for paid members
Related Assessment Year
2018-19
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Amrit Varsha Udyog Ltd. Vs DCIT (ITAT Dehradun)

Bogus Purchases Proven, Bank Payments Not Enough: ITAT Dehradun Upholds ₹68.10 Lakh Addition

Dehradun ITAT, in Amrit Varsha Udyog Ltd. vs. DCIT (ITA No.2/DDN/2025, AY 2018-19, order dated 23.12.2025), dismissed the assessee’s appeal and upheld addition on account of bogus purchases, confirming the findings of the AO and the CIT(A).

The case involved multiple reassessment proceedings based on information from DDIT (Investigation) that certain entities—Shri Ganpati Enterprises, M/s Delhi Steel Trading Co. and M/s New India Traders—were non-existent concerns providing accommodation entries. Statements of the proprietors Irfan Malik & Irshad Malik, recorded during investigation, clearly admitted that no goods were ever supplied and invoices were issued only to facilitate bogus claims.

During reassessment, the AO treated purchases aggregating to ₹1.17 crore as bogus. The CIT(A) granted partial relief but confirmed additions of ₹15.10 lakh and ₹53.00 lakh relating to purchases from Delhi Steel Trading Co. and New India Traders, holding that the assessee failed to produce confirmations, supplier ledgers, transport evidence or any proof of actual delivery of goods. Mere payment through banking channels was held to be insufficient to establish genuineness.

Before the Tribunal, no one appeared on behalf of the assessee, despite repeated opportunities. The ITAT held that the AO had conducted proper enquiries, relied on sworn statements and corroborative investigation material, and correctly applied the principles laid down by the Supreme Court in Durga Prasad More and Sumati Dayal.

In the absence of any rebuttal or contrary evidence from the assessee, the Tribunal found no infirmity in the order of the CIT(A) and dismissed the appeal, confirming the sustained additions towards bogus purchases.

FULL TEXT OF THE ORDER OF ITAT DEHRADUN

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Author Info

CA Vijayakumar Shetty
Qualification: CA in Practice
Company: Shetty & Co, Chartered Accountants, Mangalore
Location: Mangalore, Karnataka
Articles Published: 6,187

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