Bogus Purchase Addition Fails Without Incriminating Material Under Section 153A

PCIT Vs J Kumar Infraprojects Ltd. (Bombay High Court)

The Bombay High Court dismissed the Revenue’s appeal, holding that it raised no substantial question of law. Although the tax effect was below ₹2 crore, the Revenue argued that the case involved bogus purchases and therefore fell within the exceptions under CBDT circulars. Without deciding whether such exceptions applied, the Court examined the matter on merits.

In the assessment, the Assessing Officer made a 100% addition in one transaction and a 20% addition in another. The Commissioner (Appeals) r

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