Section 153C Valid, Bogus Purchases Fully Taxable Section 153D Approval Upheld – Assessee Loses on All Fronts

Karan Israni Vs DCIT (ITAT Delhi) ITAT Delhi dismissed the assessee’s appeal for AY 2019-20, upholding the 153C assessment and addition of ₹7.16 crore on account of bogus purchases / accommodation entries. The case arose from a search u/s 132 in Sanjay Jain / Mehta Group, where Tally data (Annexure A-31) showing cash commission and bogus billing was seized, directly implicating the assessee. On jurisdiction, the Tribunal rejected the plea of delayed satisfaction note, holding that recording satisfaction within eight months of completion of searched person’s assessment was reasonable and ...