China Construction Sausum (I) Pvt. Ltd. Vs DCIT (ITAT Delhi)
Summary: The Income Tax Appellate Tribunal, Delhi Bench “E”, considered appeals filed by M/s China Construction Sausum (I) Pvt. Ltd. for Assessment Years 2020-21 and 2021-22 against orders of the Commissioner of Income Tax (Appeals)-27, New Delhi. The appeals arose from assessments framed under section 143(3) read with section 153A of the Income Tax Act, 1961. Since identical issues were involved, both appeals were heard together and disposed of by a common order.
The assessee was engaged in civil and industrial construction contracts and had executed projects including the OPPO Mobile Manufacturing Centre Phase-II Project, Haier North India Industrial Park Project, Chenfeng Technology factory EPC Project and “The Icon” project. For Financial Years 2019-20 and 2020-21, its operational revenue was stated at Rs 509.40 crores and Rs 685.69 crores respectively. The books of account had been audited and accepted by the Revenue.
Following a survey and thereafter a search and seizure operation, the Revenue alleged that the assessee had made suspicious or bogus purchases and booked bogus expenses through accommodation entries. In Assessment Year 2020-21, the principal disputed additions concerned purchases from Dethat Trading Pvt. Ltd. of Rs 95,76,70,592, purchases from Bhagwati Enterprises of Rs 1,01,53,673, and purchases from Shaurya Enterprises, Hwbat Trading Pvt. Ltd. and Amplec Power Solutions aggregating to Rs 58,19,555.
