Case Law Details
Anowar Hossain Mondal Vs ITO (ITAT Kolkata)
Summary : The Income Tax Appellate Tribunal, Kolkata Bench, dismissed the assessee’s appeal and upheld the addition of ₹15.08 lakh as unexplained expenditure under Section 69C arising from alleged bogus purchases made from a supplier identified as a paper entity engaged in issuing fake GST invoices. The assessee, engaged in hardware supply to Gram Panchayats, argued that purchases were supported by invoices, bank payments, GST details, confirmations, and accepted sales records. However, the Tribunal observed that the supplier was found non-existent, notices issued under Section 133(6) remained unserved, transport details were unverifiable, and no independent evidence of actual delivery of goods was produced. Relying on recent Bombay High Court rulings in Kanak Impex and Drisha Impex, as well as Calcutta High Court precedent, the Tribunal held that once purchases are proved bogus, the entire amount—not merely profit element—must be added under Section 69C. The Tribunal rejected the plea for estimating only additional profit and confirmed the reassessment and full addition.
Core Issue: The principal issue before the Tribunal was whether purchases amounting to ₹15,08,950 allegedly made from a GST hawala/accommodation entry provider could be treated as bogus and added entirely under section 69C despite the assessee producing invoices, bank payment proofs, GST details and corresponding sales records.
Facts: The assessee was engaged in the business of supply of hardware goods to Gram Panchayats under the proprietorship concern “New Bengal Hardware”. The case was reopened under sections 147/148A on the basis of Investigation Wing information that M/s Rajbhar Trade Commercial was merely a paper concern engaged in issuing fake GST invoices without actual supply of goods. The assessee had shown purchases of ₹15,08,950 from the said concern during AY 2018-19. During reassessment proceedings, the assessee furnished copies of purchase invoices, RTGS payment proof, bank statements and confirmation from the supplier and contended that the corresponding sales had been accepted by the department.
AO Findings: The Assessing Officer held that the purchases were bogus because the supplier was found non-existent during field enquiry, notices under section 133(6) remained unserved, the supplier had no infrastructure or financial capacity to conduct genuine business, vehicle numbers mentioned in invoices were found de-registered/non-operational and no delivery challans, weighment slips or transport evidence proving physical movement of goods were produced. Accordingly, the entire purchase amount of ₹15,08,950 was added under section 69C as unexplained expenditure.
CIT(A) Findings: The CIT(A) upheld the reassessment proceedings as valid and confirmed the entire addition. It was held that information received from the Investigation Wing constituted tangible material for reopening and that mere invoices and banking transactions were insufficient to establish genuineness when the supplier itself was proved to be a bogus accommodation entry provider. The CIT(A) further held that the assessee failed to produce independent evidence regarding actual delivery or utilization of goods in government contract work and therefore section 69C squarely applied. Reliance was placed upon N.K. Proteins Ltd. v. DCIT, CIT v. Precision Finance Pvt. Ltd. and Sumati Dayal v. CIT.
ITAT Findings: The ITAT Kolkata dismissed the appeal and confirmed the entire addition. The Tribunal held that recent Bombay High Court decisions have clarified that once purchases are proved to be bogus accommodation entries, appellate authorities cannot merely estimate profit percentage and grant implied deduction of unexplained expenditure. The Tribunal relied upon Pr. CIT v. Kanak Impex (India) Ltd., Pr. CIT v. Drisha Impex Pvt. Ltd. and PCIT v. Mrs. Premlata Tekriwal to hold that where purchases are not proved genuine, entire bogus purchase amount is liable to be added under section 69C and not merely the profit element.
Gist of Cases Relied Upon: In Pr. IT v. Kanak Impex (India) Ltd. [ITA No. 286 of 2022, order dated 03.03.2025], the Bombay High Court held that once purchases are found bogus and unexplained under section 69C, appellate authorities cannot restrict additions merely to GP percentage because doing so would indirectly allow deduction of unexplained expenditure prohibited by statute. In Pr. CIT v. Drisha Impex Pvt. Ltd. [ITA No. 1558 of 2024, order dated 07.04.2025], the High Court held that after recording a finding that purchases were bogus, the Tribunal could not sustain addition of only 3% profit element. Reliance was also placed upon PCIT v. Mrs. Premlata Tekriwal [ITA No. 161 of 2022, judgment dated 27.07.2022], wherein it was held that once expenditure is proved bogus/unexplained, the entire amount is liable to be added. Further reliance was placed upon N.K. Proteins Ltd. v. DCIT [SLP(C) No. 769 of 2017, order dated 16.01.2017], affirming full addition in accommodation entry purchase cases, and Sumati Dayal v. CIT [(1995) 214 ITR 801], emphasizing the test of human probabilities over mere documentary evidence.
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FULL TEXT OF THE ORDER OF ITAT KOLKATA
This appeal filed by the assessee is against the order of the Commissioner of Income Tax (Appeals)-NFAC, Delhi [hereinafter referred to as Ld. ‘CIT(A)’] passed u/s 250 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) for AY 2018-19 dated 04.11.2025.
2. The assessee is in appeal before the Tribunal raising the following grounds of appeal:
“1. That on the facts and in the circumstances of the case the Ld. CIT(A), NFAC is wrong, unjust and has erred in law in confirming the addition made by the Ld.AO, NFAC merely on surmises and suspicion, without recording justifiable dissatisfaction with the appellant’s explanations regarding the genuineness of purchases.
2. That the authorities below failed to appreciate that the assessee had furnished comprehensive evidencial details of suppliers (name, address, PAN, GST details, invoices, bank payments, confirmation of statement of Accounts, Trade Licence of supplier etc.) in support of genuineness of purchases.
3. That the learned CIT(A), NFAC in confirming the addition on account of purported bogus purchases for non compliance of GSTR by suppliers which could have a bearing on the ITC claimed by the Assessee but the entire purchase cannot be consideded (considered) as bogus purchase when comprehensive details of purchases supported with evidence was provided to the authorities.
4. That the learned CIT(A), NFAC erred in confirming the addition on account of bogus purchases, ignoring that the corresponding sales were accepted and payments were made through banking channels, which is contrary to settled judicial precedents.
5. That the disallowance of the entire purchase amount is not justified, and a reasonable Gross Profit (GP) rate should be applied on the sales corresponding to the disputed purchases, in Vine with the commercial realities and judicial decisions
6. That, the appellant craves leave to amend, alter, modify, substitute, add to, abridge and/or rescind any or all of the above grounds”
3. Brief facts of the case are that the assessee is an individual and carrying on the business of supply mainly hardware goods to Gram Panchayant under the name and style ‘New Bengal Hardware’ of Guskara Bus Stand, Purba Burdwan-713128. The assessee had prepared its books of account for the financial year ended on 31st March 2018 and the said books of account were audited u/s 44AB of the Act. Thereafter, the assessee filed his return of income for AY 2018-19 declaring total income of ₹11,92,700/- on 10.10.2018 which was processed u/s 143(1) of the Act on 10.02.2019. The Assessing Officer (hereinafter referred to as Ld. ‘AO’) issued notice u/s 148A(b) of the Act to the assessee on the basis of the information received from DDIT(Inv.)-2(1), Kolkata and DDIT(Inv.)-1(4), Kolkata that Mr. Sumit Rajbhar, proprietor of M/s. Rajbhar Trade Commercial was engaged in generation of fake GST invoices to facilitate irregular input tax credits to other business entities and while doing this he also availed and utilized irregular input tax credit by others. The supplier had filed his return of income for the AY 2018-19 disclosing turnover of ₹60,68,62,642/- and had declared gross total income of ₹3,73,127/- with no fixed assets. The Department had construed that the said party was a paper entity with no financial worth and was used for providing accommodation entries in the guise of invoice issuance; therefore, transactions made by the entity were treated as sham transactions and all the sales made by the entity were held to be bogus sales and all the sales proceeds in the hand of the recipients were actually bogus purchases. The assessee was one of the beneficiaries having made bogus purchases from M/s. Rajbhar Trade Commercial during the FY 2017-18 relevant to the AY 2018-19 for an amount of ₹15,08,950/- and the amount had escaped assessment for AY 2018-19 being inadmissible expenses. The assessee appeared before the Ld. AO, made submissions and produced relevant documents but he did not submit the same through e filing portal. The Ld. AO passed an order u/s 148(a) of the Act and also issued notice u/s 148 of the Act. The assessee filled the return of income u/s 148 of the Act on 11.11.2022 declaring taxable income of ₹12,70,870/-. The case was selected for scrutiny u/s 147 of the Act. The Ld. AO/NFAC issued notice u/s 142(1) of the Act and the assessee submitted all the documents viz. copy of purchase bills, payment certificates issued by the banks, bank statements and confirmation letter as received from the said creditor. The Ld. AO treated the alleged purchases as bogus and disallowed and added to the total income of the assessee for the year under consideration. Aggrieved with the assessment order, the assessee filed an appeal before the Ld. CIT(A) who, vide order dated 04.11.2025, dismissed the appeal of the assessee as per his findings as under:
“6. Ground wise Findings and Decision of the appellate authority Ground No. 1 – Validity of Reassessment Proceedings The appellant contends that the AO initiated proceedings merely based on information from the Investigation Wing without independent application of mind or tangible material linking escapement of income to the appellant.
Finding:
Perusal of the records shows that the information from the Investigation Wing was specific and credible, indicating that the appellant was a direct beneficiary of accommodation entries in the form of bogus purchases from M/s Rajbhar Trade Commercial during the relevant year.
The AO recorded reasons citing such tangible material, obtained satisfaction, and issued notice u/s 148A(b), giving the assessee an opportunity to respond. Subsequent approval u/s 151 was duly obtained. The satisfaction recorded is neither mechanical nor general in nature, rather, it contains a live nexus between the information and formation of belief of escapement. Judicial precedents (Raymond Woollen Mills Ltd. v. ITO, 236 ITR 34 (SC), ACIT v. Rajesh Jhaveri Stock Brokers Pvt. Ltd., 291 ITR 500 (SC)) have held that sufficiency of material is not to be examined at this stage, only the existence of tangible material and bona fide belief is relevant.
Accordingly, the reassessment proceedings are found valid and sustainable. Ground No. 1 is dismissed.
Ground Nos. 2 & 3-Addition of 15,08,950/- towards Bogus Purchases The main issue for consideration is whether purchases shown by the assessee from M/s Rajbhar Trade Commercial amounting to 15,08,950/- are genuine or bogus.
(i) Appellant’s Submission The assessee argued that:
(i) Purchases were supported by bills, bank payments (RTGS), and confirmations.
(ii) Goods were used in government contract works,
(iii) Merely because the supplier is not found at the address after six years does not render the transaction non-genuine.
(iv) Sales corresponding to purchases were accepted.
(v) Relied on several judicial pronouncements (e.g., Vaman International Pvt. Ltd. Mohammad Haji Adam & Co., etc.) contending that entire purchase should not be disallowed.
(ii) Findings and Discussion
(i) The AO made detailed verification which revealed:
(ii) Non-existence of supplier: Field enquiry report from the Investigation Wing categorically stated that M/s Rajbhar Trade Commercial was not operating at the stated address. The concern had no fixed assets, infrastructure, or stock, and was used as a paper entity to issue GST invoices.
(iii) Non-response to statutory notices: Notices issued u/s 133(6) remained unserved. No confirmation or evidence directly from the supplier was produced.
Transport details unverifiable: The vehicles mentioned in invoices were found either de-registered or non-operational during the relevant period, proving that actual movement of goods could not be established.
No evidence of actual delivery: Apart from self-generated invoices and bank payments, no delivery challans, weighment slips, or transport receipts were produced to substantiate physical receipt of goods.
It is settled law that mere payment by cheque or existence of invoice is not sufficient to prove genuineness of a transaction unless the supplier’s identity, capacity, and genuineness of transaction are established. (Refer. CIT v. Precision Finance Pvt. Ltd. 208 ITR 465 (Cal), N.K. Proteins Ltd. v. DCIT 292 CTR 354 (SC)).
The appellant’s reliance on Vaman International Pvt. Ltd. and Mohammad Haji Adam & Co. is distinguishable. In those cases, the purchases were partly proved through stock reconciliation and sales linkage, whereas in the present case, the supplier has been conclusively found to be a non-existent accommodation entry provider. No independent corroborative evidence of actual delivery or consumption has been demonstrated.
The plea that goods were utilized in government contracts remains unsubstantiated, as no work order-wise material consumption register or certificate from the Panchayat authorities linking these specific purchases was furnished.
In view of the above, the purchases remain unverified and unverifiable. The AO’s action in treating the same as bogus and disallowing u/s 69C is justified.
Further, once the purchases are proved to be bogus, the corresponding expenditure is deemed to be unexplained under section 69C. The deeming fiction squarely applies since the assessee failed to satisfactorily explain the source and genuineness of the expenditure.
(iii) Judicial Position
The Hon’ble Supreme Court in N.K. Proteins Ltd. v. DCIT (2017) held that once it is established that the assessee obtained accommodation entries and not actual goods, the entire amount of such bogus purchases is liable to be added. Similarly, CIT v. La Medica 250 ITR 575 (Del) and Sumati Dayal v. CIT 214 ITR 801 (SC) emphasize that surrounding circumstances and human probabilities must be considered rather than mere documents.
Hence, in view of overwhelming evidence that the supplier was a non-genuine entity, and the appellant failed to discharge the onus of proving genuineness of purchase, the entire addition of 15,08,950/- u/s 69C is upheld.
Ground Nos. 2 & 3 are dismissed.
Ground No. 4 – Interest Income Discrepancy
The AO noticed a difference of 78,170/- between interest income declared in the original and revised returns. The appellant has not provided any cogent explanation for such variation either during assessment or appellate
proceedings. Therefore, the AO’s action is found correct.
Ground No. 4 is dismissed.
7. Penalty Proceedings
The AO has initiated penalty proceedings u/s 270A for under-reporting and misreporting of income. The issue of penalty is independent and will be decided separately. No interference is called for at this stage.
8. Conclusion
After considering all facts, arguments, and judicial precedents, it is held that:
i) The reassessment proceedings u/s 147 were validly initiated.
ii) The purchases of 15,08,950/- from M/s Rajbhar Trade Commercial are bogus and fall within the ambit of unexplained expenditure u/s 69C.
iii) The AO’s addition is, therefore, confirmed in full.
iv) The addition of 78,170/- towards interest income discrepancy is also upheld.
9. Result
The appeal is dismissed in toto. The assessment order u/s 147 r.w.s. 143(3) dated 10.03.2023 is confirmed.”
4. Aggrieved with the order of the Ld. CIT(A), the assessee has filed the appeal before the Tribunal.
5. Rival contentions were heard and the submissions made have been examined. It was contended by the Ld. AR that the assessee had shown gross profit rate of 6.87% and net profit rate of 4.58%. the Ld. AR was agreeable to extra profit of 6% on the alleged bogus purchases over and above that shown in the return of income. The Ld. DR relied upon the order of the Ld. CIT(A) and requested that the same may be upheld in view of the decisions relied upon by the Ld. CIT(A).
6. We have considered the facts of the case, the submissions made and the documents filed and have also gone through the assessment order as well as the appeal order. The Ld. AO verified the purchases by issuing notice u/s 133(6) of the Act. The Ld. CIT(A) upheld the addition.
7. Hon’ble Bombay High Court in the case of Principal Commissioner of Income-tax vs. Drisha Impex (P.) Ltd. [2025] 173 taxmann.com 571 (Bombay)[07-04-2025] has held that once the Tribunal has concluded that the purchases were bogus, therefore, it was not justified in estimating, after giving such a finding, to confirm the disallowance of only 3% of the bogus purchases. The SLP against the same was also dismissed by the Hon’ble Apex Court.
8. Further, Hon’ble Bombay High Court in support of Principal Commissioner of Income-tax vs. Kanak Impex (India) Ltd. [2025] 172 taxmann.com 283 (Bombay)/[2025] 474 ITR 175 (Bombay)[03-03-2025] have held as under:
■ The short issue which requires adjudication in this appeal is whether additions made by the Assessing Officer on account of the failure of the assessee to prove the genuineness of the purchases can be said to be valid. [Para 13]
■ In the instant case, admittedly, the assessee did not appear before the Assessing Officer during the reassessment proceedings to prove the deduction claimed for purchases. There is no justification for non-appearance before the Assessing Officer to establish the purchases. The plea of the assessee that they were not served with the notices has been negatived by the Appellate Authority and the same has not been challenged. Therefore, the assessee in the present case has failed to prove the purchases of which the claim for deduction was made before the Assessing Officer. [Para 17]
■ The Commissioner (Appeals) has also given a finding against the assessee, stating that the assessee failed to prove the genuineness and source of the purchases and confirmed its involvement in the modus operandi. It is viewed that the Commissioner (Appeals) was not justified after giving such a finding that the additions should be restricted only to 12.5 per cent of such purchases and not entire purchases. The issue before the Commissioner (Appeals) was not whether the profit disclosed by the assessee was low so as to justify the estimation of the profit of 12.5 per cent. The issue before Commissioner (Appeals) was whether the purchases had been proved and the Commissioner (Appeals), having observed against the assessee on this issue, ought to have confirmed the additions of the entire purchases. It is viewed that the Commissioner (Appeals) misdirected himself by estimating a profit of 12.5 per cent. [Para 18]
■ It was nobody’s case that both the sales and purchases are unaccounted. If that be so and the purchases have been recorded in books of account by accommodation entry, then same gets automatically reflected in the books of account. In the instant case, since the purchases are recorded by accommodation entry in the books of account and sales have not been disputed, the Commissioner (Appeals) was not justified in estimating the profit, when the basis of addition was not low profit. [Para 19]
■ The Tribunal also misdirected itself by approaching the issue with the erroneous belief that it was estimating profit. In fact, the issue before the Tribunal was whether the Commissioner (Appeals) was justified in not confirming entire purchase additions. Therefore, to that extent, the Tribunal too misdirected itself by approaching the issue solely based on estimating profit. [Para 20]
■ It is viewed that both the Appellate Authorities ought to have appreciated that the issue before them was whether the assessee had proved the purchases of which the claim for deduction was made. The assessee, having failed to discharge its onus on this issue before all three authorities, it is viewed that the additions made in the assessment order by the Assessing Officer was justified. [Para 21]
■ If the approach of the Appellate Authorities of estimating the profit on such purchases is to be accepted, then, in effect, the consequence would be that even if assessee has failed to prove its claim of deduction of purchases, still by estimating profit, impliedly deduction of purchases is given. For example, if the purchases by accommodation entries are Rs.100 and a profit of 10 per cent is estimated, then to the extent of Rs.90 deduction on account of purchases is deemed to have been given by the Appellate Authorities. This approach would not be correct since it is nobody’s case that the assessee has made sales out of books by purchasing the goods out of books. [Para 22]
■ If the approach of the Appellate Authorities is accepted, then the provision of section 69C, which is an enabling provision, would become redundant. Section 69C provides that where an assessee has incurred any expenditure and offers no explanation about the source of expenditure or the explanation offered is not in the opinion of the Assessing Officer satisfactory, then the amount of expenditure may be deemed to be the income of the assessee and such unexplained expenditure which is deemed to be the income of the assessee shall not be allowed as a deduction under any head of income. It is viewed that if the approach of the Commissioner (Appeals) and the Tribunal is accepted, then it would amount to endorsing outright conduct of illegality, contrary to the express provisions of section 69C, which the Appellate Authorities have entirely ignored. In the above example, by estimating 10 per cent and thereby impliedly giving a deduction of Rs.90, in the teeth of the provisions of section 69C, which expressly bars the allowability of unexplained expenditure. [Para 23]
■ The assessee relied upon the details of sundry debtors and sundry creditors filed during the original assessment proceedings under Section 143(3) to contend that the details of purchases have been furnished. These details were furnished in the course of the original assessment proceedings under section 143(3) and not during the re-assessment proceedings. This fact has been admitted by the respondent-assessee. After the original assessment order under Section 143(3), the revenue, on the basis of the information received from the DGIT (Inv.)/Sales Tax Department, reopened the case on the ground that the purchases made by the respondent-assessee are from hawala operator. Therefore, the details of sundry debtors and creditors filed in the original assessment proceedings do not absolve the respondent-assessee from proving the source of the purchases in the course of the re-assessment proceedings. On the contrary, on account of reasons for which case was reopened, the onus was more to prove purchases which respondent-assessee has totally failed. [Para 28]
■ The re-assessment proceedings were initiated for this very reason that the purchases which were accepted in the original assessment proceedings are non-genuine after the passing of the assessment order. The respondent-assessee chose not to attend the re-assessment proceedings even though the notices were sent to the respondent-assessee by post, email and affixture. The CIT(A) has given a finding that the address of the petitioner mentioned in the assessment order and in Form No.35, which is an appeal filed by the respondent-assessee, is same and the respondent-assessee intentionally did not accept notice sent by post. The CIT(A) has also given a finding that notices sent by email have not bounced back and there is no rebuttal to the affixture of notice on the office of the respondent-assessee. [Para 29]
■ The assessee having consciously and intentionally decided not to join the investigation, cannot now contend that the revenue should have given them all the details before making the addition. Such a conduct of the assessee cannot be accepted. It was incumbent upon the assessee to have joined the reassessment proceedings, discharge the initial onus of proving the purchases and seek details, if any. Having not joined the reassessment proceedings, the contentions raised by the assessee on this issue are to be rejected.[Para 30]
■ The submission of assessee that if this addition made by the AO is sustained, then profit rate would be exorbitant and therefore addition should be deleted is to be rejected. The fallacy of this argument is that the AO has not made the addition because of low profit. The addition was made because the assessee failed to prove genuineness of purchases because of allegation of purchases by accommodation entries as explained above. If contention of assessee is accepted, then every addition would have to be deleted if related to business deduction. Such a submission is to be rejected outright. [Para 31]
■ The Commissioner (Appeals) has given a clear finding of fact that the assessee was involved in getting bogus bills. This finding has not been challenged by the assessee before the Tribunal, and only submission made before the Tribunal was on the estimation of gross profit. [Para 34]
■ The question of law admitted in this appeal states explicitly that neither of the Appellate Authorities has considered the provisions of section 69C. [Para 36]
■ The assessee has not made any submissions on the provisions of section 69C, although the same were explicitly framed in the admission order and relied upon by the revenue in the course of the hearing. Therefore, the only conclusion that can be arrived at is that the assessee does not dispute the applicability of the provisions of section 69C to its facts. [Para 37]
■ It is viewed that in the instant case, the assessee has offered no explanation of the source of the expenditure incurred on account of purchases and, therefore, the Assessing Officer was justified in making an addition of the said amount and the Appellate Authorities were not justified in estimating the profit rate and thereby impliedly grant deduction of such unexplained expenditure which is contrary to the express provision of section 69C. [Para 38]
■ In the instant case, the assessee has not appeared in the reassessment proceedings to discharge its onus on proving purchase transactions under consideration. Before the Commissioner (Appeals) for the first time, scanty details of sundry debtors, creditors and stocks were given. The Commissioner (Appeals) gave a finding of the assessee’s involvement in bogus transaction. Therefore, the finding of the Assessing Officer on the genuineness of the purchases was confirmed by the Commissioner (Appeals). Before the Tribunal, the assessee has not canvassed any submission on the genuineness of the purchases but only pleaded for an estimation of a certain percentage of such bogus purchases to be added. Therefore, before all three authorities, the assessee has not proved the genuineness of the purchases, which inter alia include the source of making the payment for such purchases. In the light of these factual findings by three authorities, today before the High Court, the assessee’s submissions that they have discharged the onus cast upon them to prove the genuineness of the purchases, including the source cannot be accepted. [Para 39]
■ In view of the above, the appeal of the revenue is allowed by answering the question in favour of the revenue and against the assessee.
Consequently, the order of the Assessing Officer is restored, and the order passed by Commissioner (Appeals) and the Tribunal is reversed. However, it is made clear that the aggregate addition after considering the Commissioner (Appeals) and the Tribunal’s order should not exceed Rs.20.07 crores. [Para 40]”
9. Similar view has also been expressed by the Hon’ble jurisdictional High Court in the case of Principal Commissioner of Income-tax v. Mrs. Premlata Tekriwal [2022] 143 com 173 (Calcutta) where it has been upheld that since it was established that expenditure was unexplained/bogus, entire amount of bogus expenditure was to be added to the income of assessee and the PCIT was fully justified in exercising revision jurisdiction under section 263 of the Act. Thus, in view of the judicial pronouncements and the facts of the case, we find no reason to interfere with the finding of the Ld. CIT(A) who has confirmed the entire purchase as unexplained expenditure u/s 69C of the Act which was treated as bogus by the Ld. AO, which view is also supported by the decisions of the Hon’ble Bombay High Court in the case of Kanak Impex (India) Ltd. (supra), Drisha Impex (P.) Ltd. (supra) as well as the Hon’ble Jurisdictional High Court in the case of Mrs. Premlata Tekriwal (supra). Hence, the grounds of appeal filed by the assessee are hereby dismissed.
10. In the result, the appeal filed by the assessee is dismissed. Order pronounced in the open Court on 5th May, 2026.
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