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ITAT Delhi Deletes Rs 10.13 Crore Bogus Purchase Disallowance Based on Mere Allegations

Case Law Details

TaxGuru Citation
2026 taxguru.in 12119
Case Name
Jammu Pigments Limited Vs Assessment Unit (ITAT Delhi)
Date of Judgement/Order
Only available for paid members
Related Assessment Year
2018-19
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Jammu Pigments Limited Vs Assessment Unit (ITAT Delhi)

Summary: The appeal was filed by Jammu Pigments Limited against the order dated 12.09.2025 passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, arising from the assessment order dated 19.03.2025 passed under Sections 147 read with 144B of the Income Tax Act, 1961 for Assessment Year 2018-19.

The assessee was engaged in manufacturing and trading of Lead metal Ingots & Alloys, Zinc oxide, chemicals and transportation. It had filed its return on 28.10.2018 declaring total income of INR 8,48,94,303/-. The Assessing Officer initiated proceedings under Section 148A after receiving information concerning alleged diversion of 22 consignments of Lead dross amounting to INR 5,20,83,109/-. The AO alleged that the goods had not been used by the assessee in manufacturing, had instead been transferred to brokers and sold outside the books, with incorrect input tax credit claimed under the GST Act.

The AO also alleged that purchases of INR 27,83,45,325/- from Shri Ajit Singh were accommodation entries because Shri Ajit Singh had allegedly purchased goods from Shri Dinesh Chand, proprietor of Manvee Traders, who was stated to be involved in issuing fake invoices. The assessee furnished details concerning the disputed purchases and submitted that the Lead dross was of inferior quality and had therefore been sent for re-job work. It also maintained that no incorrect input tax credit had been claimed.

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