Ramjibhai Kesaraji Patel Vs ITO (ITAT Ahmedabad)
In a recent ruling, the Income Tax Appellate Tribunal (ITAT) Ahmedabad Bench has partly allowed an appeal filed by Ramjibhai Kesaraji Patel, significantly reducing an addition made by the Assessing Officer (AO) for alleged bogus purchases. The ITAT’s decision, issued on July 17, 2025, addresses both procedural issues, specifically the delay in filing the appeal before the Commissioner of Income-tax (Appeals) [CIT(A)], and the substantive matter of bogus purchase disallowance.
The case for Assessment Year (AY) 2018-19 began with the assessee filing a return declaring an income of ₹4,96,960. Subsequently, the case was reopened under Section 147 of the Income-tax Act, 1961, and reassessment was completed on March 15, 2023. During this reassessment, the AO determined the total income at ₹21,25,604, making an addition of ₹15,28,644 under Section 69C, citing alleged bogus purchases from entities including Raghav Traders, Helly Enterprises, and Laxmiraj Enterprises.
When the assessee appealed to the CIT(A), the appeal was dismissed in limine, meaning it was rejected at the outset, due to a delay in filing without any explanation provided by the assessee.
Assessee’s Arguments and Documentary Evidence
Before the ITAT, the assessee’s authorized representative (AR) argued that the purchases in question were genuine. The AR highlighted that during the original assessment proceedings, complete details of purchases from Laxmiraj Enterprises and Raghav Traders were submitted to the AO via a paper book uploaded on February 17, 2023. These submissions included VAT invoices, bank statements, and audited books of accounts, which, according to the AR, substantiated the genuineness of the transactions.
