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Judgment
ORDER
This assessee’s appeal for assessment year 2019-20, 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/250/2025-26/1082923198(1), dated 24.11.2025 involving proceedings under section 147 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).
Heard both the parties. Case file perused.
It is noticed at the outset that the assessee is aggrieved against both the learned lower authorities’ assessment and lower appellate findings disallowing its purchase of Rs.16.70 lakhs as bogus ones under section 37 of the Act.
It is in this factual backdrop that the tribunal’s attention is invited to the assessee’s P & L Account pertaining to the relevant financial year wherein it had declared stock-in-trade purchases at “nil”. This clinching factual position has gone unrebutted from the Revenue side. The tribunal is of the considered view in this factual backdrop that once the assessee has not even claimed any purchases in the books of account, the same could not have been disallowed under section 37 of the Act. Deleted accordingly.
This assessee’s appeal is allowed.