ITAT Delhi Cuts Bogus Purchase Addition to 15% & Upholds 153C Jurisdiction  

JPS Buildtech Pvt Ltd Vs DCIT (ITAT Delhi)

Tribunal dealt with four cross-appeals arising from search-linked assessments u/s 153C in the case of JPS Buildtech Pvt Ltd following seizure of incriminating tally data from Sanjay Jain—an admitted accommodation entry operator. The jurisdictional objection was rejected as seized ledgers & tally records clearly pertained to Assessee & established nexus with undisclosed transactions, satisfying the requirement of valid satisfaction u/s 153C.

On merits, AO treated entire purchases from entities linked to Sanjay Jain as bogus

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