DCIT Vs Akshray investment (ITAT Mumbai)
The Income Tax Appellate Tribunal (ITAT), Mumbai Bench, was dealing with a batch of seventeen appeals along with connected cross-objections involving a common issue relating to minor additions on account of alleged bogus purchases. These additions were inferred primarily on the basis of certain emails of an employee pertaining to Assessment Year (A.Y.) 2018-19, along with some other minor additions. The matter was earlier heard on 05.01.2026.
During the earlier hearing, the Authorised Representative submitted that the Assessing Officer had extrapolated and estimated alleged bogus purchases not only for A.Y. 2018-19 but also for A.Ys. 2013-14 to 2017-18. It was pointed out that the Commissioner of Income Tax (Appeals) had deleted the additions on merits. In the cross-objections, the assessee contended that for A.Ys. 2013-14 to 2017-18, there was admittedly no incriminating material, a position reflected in both the assessment and appellate orders.
On 05.01.2026, the CIT-DR sought adjournment to prepare the matter and obtain comments or reports from the Assessing Officer. Considering that the appeals involved a common issue and fell within the roster period for disposal, the Bench made it clear that the matter was expected to be argued within the roster period. However, in the interest of fairness, three weeks’ time was granted and the case was fixed for hearing on 28.01.2026.
