Redeem Exports Pvt. Ltd. Vs ITO (ITAT Surat)
The appeal before the Income Tax Appellate Tribunal (Surat) concerned the addition of Rs. 1,15,80,000 made by the Assessing Officer (AO) on account of alleged bogus purchases for Assessment Year 2017–18. The assessee, engaged in trading of rough and polished diamonds, had filed its return declaring income of Rs. 75,200. During assessment, the AO relied on statements recorded during a survey under Section 133A in another case, where it was admitted that certain entities, including the assessee’s suppliers, were paper concerns providing accommodation entries. Based on this, the AO treated purchases from two suppliers as bogus and made addition under Section 68.
The assessee contended that purchases were genuine, supported by confirmations, and payments were made through RTGS, duly reflected in bank accounts. It also argued that it was not provided copies of documents or statements relied upon by the AO and was denied the opportunity for cross-examination. Despite these submissions, the Commissioner (Appeals) upheld the addition.
Before the Tribunal, the assessee submitted additional evidence, including ledger confirmations, purchase invoices, income tax returns of suppliers, stock registers, bank statements, and sales and purchase registers. It was explained that these records were not produced earlier as they were old documents. The assessee requested that the matter be remanded to the Commissioner (Appeals) for proper verification of these evidences.
