Shairul Impex Vs ITO (ITAT Mumbai)
The assessee filed an appeal against the order dated 22.08.2025 passed by the Commissioner of Income Tax (Appeals), NFAC, Delhi, for Assessment Year 2014–15, arising from an assessment order passed under sections 147 read with 144 of the Income Tax Act dated 11.05.2023. The appeal involved both legal challenges to reassessment proceedings and objections to the addition of ₹3,02,93,611 on account of alleged bogus purchases.
At the outset, the assessee chose not to press certain grounds relating to the validity of the notice under section 148 on account of alleged violations of section 151A and CBDT Circular No. 19 of 2019. Accordingly, those grounds were dismissed as not pressed.
The facts of the case indicate that the assessee, a partnership firm, had filed its return of income declaring ₹12,69,240. Based on information received during search and seizure operations on the Rajendra Jain Group, the Assessing Officer formed a belief that the assessee had obtained accommodation entries in the nature of bogus purchases from two entities amounting to ₹3,02,93,611. Consequently, notice under section 148 was issued on 19.04.2021 after recording reasons and obtaining approval. Subsequent proceedings were carried out in accordance with the amended regime, and notices under sections 143(2) and 142(1) were issued and responded to by the assessee.
