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Judgment
This assessee’s appeal for Assessment Year 2020-21, arises against the C IT(A)/NFAC, Delhi’s DIN & order No. ITBA/NFAC/S/250/2025-26/1084512798(1), date d 07.01.2026 in proceed ings u/s 147 of the Income Tax Act, 1961 (in short “the Act”).
Heard both the p arties. Case file perused.
It transpires dur ing the course of hearing that the learned lower author ities had first initiated Sectio n 148 proceedings against the assessee for the purpose of disallowing his purchases amounting to Rs.24 .6 2 lakhs invo lving M/s Johnson Watch Group and M/s Kapoor Watch Group and others whereas t h the assessme nt dated 26 March 2025 ended up in a further disallowance of Rs.11 ,35,500/- representing alleged bogus purchases in case of M/s Ravi G iri, etc. That be ing the case, the Revenue co uld hardly dispute that the asse ssee no where claims to have sought purchases deduction of Rs.24.62 lakhs from the foregoing tw in e ntities M/s Johnson Watch Group and M/s Kapoor Watch Gro up and others.
So far as the alle ged purchases involving Mr. Ravi Giri are concerned, it is reiter ated the same do not form part o f the Assessing Officer’s reopening reasons. Faced with this situation, this tribunal neither finds any merit in the impugned reopening going by ATS Infrastructure Ltd. Vs. ACIT (2024) 166 taxman.com 61 (Delhi), Ranbaxy Laboratory CIT (2011) 335 ITR 136 (Del), CIT Vs. Jet Airways (I) Ltd. (2011) 331 ITR 236 (Bom.)nor on merits since both the learned lower authoritie s have simp ly proceeded on mere conjectures and surmises than substantiating the disallowance herein of bogus purchases in the assessee’s hands. Dele ted according ly.
The assessee’s appeal is allowed.