ITO Vs Mukesh Hirachand Sanghvi (ITAT Mumbai)
The present cross appeals were filed by both the assessee and the Revenue against the order dated 16 June 2025 passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, arising out of a reassessment completed under section 143(3) read with section 147 of the Income-tax Act, 1961 for Assessment Year 2010–11. Since both appeals arose from the same appellate order and involved identical issues, they were heard together and disposed of by a consolidated order of the Income Tax Appellate Tribunal Mumbai.
The sole issue for adjudication concerned an addition made on account of alleged bogus purchases. During reassessment proceedings, the Assessing Officer treated purchases made by the assessee from certain parties as non-genuine based on information received from the Investigation Wing, which relied on data from the Sales Tax Department, Government of Maharashtra. The information suggested that several dealers were engaged in issuing accommodation purchase bills without actual supply of goods. Relying on this information, the Assessing Officer noted that the assessee had made purchases aggregating to ₹5,68,98,134 from twenty-six such parties.
The assessee had originally filed its return of income on 1 October 2010 declaring total income of ₹1,11,68,137, which was processed under section 143(1). Subsequently, the assessment was reopened under section 147 based on the above information.
