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Judgment
PER SATBEER SINGH GODARA, JM
This Revenue’s appeal for assessment year 2014-15, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s DIN and order no. ITBA/NFAC/S/250/2025-26/1081075349(1), dated 29.10.2025 involving proceedings under section 147 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).
Heard both the parties. Case file perused.
2 For the reasons stated in the Revenue’s condonation averments, delay of 34 days in filing of the instant appeal is condoned in light of Collector, Land & Acquisition vs. Mst. Katiji & Others (1987) 167 ITR 471 (SC).
It transpires during the course of hearing at the outset that the Revenue has raised its twin substantive grounds seeking to revive unexplained bogus purchases addition of Rs.4,86,23,127/-and bogus credit entries of Rs.80 lakhs; added in the assessee’s hands in assessment order dated 30.03.2022 as deleted in the lower appellate discussion.
That being the case, learned counsel takes us to pages 57 to 59 in the paper-book first of all that the Assessing Officer had framed his section 143(3) regular assessment in the assessee’s case on 15.11.2016. And that he thereafter initiated the impugned reopening in its case based on some alleged investigation wing’s report that it had received credit entries from one Sh. Hitesh Jain. Learned counsel’s case accordingly is that the assessee at the best had declared its purchases amounting to Rs.16,02,031/- sourced from M/s. Gayatri Maa Enterprises whereas the Assessing Officer added the remaining sum of Rs.4,70,21,096/- pertaining to M/s. Ridhi Sidhi Impex and Rs.80 Lakhs in case of M/s. Mittersain Rajesh Kumar; respectively. Mr. Ankit Kumar’s case therefore is that neither there is any purchase claim nor credit entries involving the foregoing twin entities. And also that the assessee had duly explained the genuineness of purchase amounting to Rs.16.02 lakhs in the first round as well all along which has gone unrebutted from the Revenue side.
We thus find no merit in the Revenue’s instant twin substantive grounds which are hereby rejected in very terms.
Learned counsel further seeks to buttress the point that the Assessing Officer’s reopening reasons herein have nowhere discussed the assessee’s clear-cut failure in not disclosing all the relevant particulars “fully” and “truly” as well which renders the same non-est in the eyes of law. We are of the considered view that given the fact that we have already upheld the learned CIT(A)’s detailed discussion deleting the alleged bogus purchases and credit additions, the instant legal issue raised at the assessee’s behest is treated as academic at this stage.
This Revenue’s appeal is dismissed in above terms.