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2025 Supreme(Online)(ITAT) 7923

INCOME TAX APPELLATE TRIBUNAL (CHANDIGARH BENCH)
Krinwant Sahay, AM, Laliet Kumar, JM
Akbar Ali – Appellant
Versus
The ITO – Respondent


Advocates:
For the Appellants/Petitioners:Sh. Sudhir Sehgal, Advocate
For the Respondents: Sh. Vivek Vardhan, Addl. CIT, Sr.DR

Table of Content
1. allegations of bogus purchases lack supportive evidence. (Para 1 , 2 , 3)
2. reopening assessments must be based on concrete evidence. (Para 5)
3. suspicion cannot validate reopening assessments without evidence. (Para 6)
4. court quashed assessment on invalid reopening. (Para 7 , 8)

आदेश/Order

Per Krinwant Sahay, AM :

Appeal in this case has been filed by the assessee against the order dated 19.05.2025 passed by the Ld. CIT(A), National Faceless Appeal Centre (NFAC), Delhi

2. Grounds of appeal, as raised by the Assessee are reproduced as under:

1. That the Ld. Assessing Officer has erred in reopening the assessment u/s 147 and making an addition of Rs.43,17,081/- on account of alleged bogus purchases from M/s G.S. Industries, Mandi Gobindgarh.

2. That the confirmation of addition by the Ld. CIT(A) in respect of bogus purchases amounting to Rs. 43,17,081/- is against the facts and circumstances of the case.

3. That the reopening of the case u/s 148 merely on the basis of statement of third party 1.e. supplier is not justified, since there is no other material on record.

4. That the Ld. Assessing Officer/CIT(A) has failed to appreciate that no evidencery value can be attache

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