Bogus Entry Network Exposed in Survey Justifies Reassessment: ITAT Delhi

M.R. Overseas Pvt. Ltd. Vs DCIT (ITAT Delhi) Material Facts The appeals for AYs 2012-13 to 2014-15, 2017-18 and 2018-19 arose from reassessments under Sections 147 and 143(3). A survey in the case of Mr. Ashok Kumar Gupta allegedly revealed a network providing bogus purchase and sales entries through various entities, with the assessee identified as one of the beneficiaries. The Assessing Officer made additions representing the difference between purchases and sales from those entities and also estimated commission at 3%, which were upheld by the CIT(A). Procedural History The assessee challen...