, , आयकरअपीलीयअिधकरण इंदौर(cid:586)ायपीठ इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI B.M. BIYANI, ACCOUNTANT MEMBER AND SHRI PARESH M JOSHI, JUDICIAL MEMBER ITA No.245/Ind/2025 (Assessment Year : 2018-19)

Rajveer Leaf Springs बनाम/ DCIT/ACIT-4(1), Private Limited, Vs. INDORE D-405, Shubh City, Palda, Indore (PAN:AAHCR2870H)

(Assessee/Appellant) (Revenue/Respondent)

Assessee by S/Shri Harsh Chouske&KunalAgrawal,, ARs Revenue by ShriAshishPorwal, DR Date of Hearing 20.11.2025 Date of Pronouncement 28.11.2025 आदेश / O R D E R Per Paresh M Joshi, J.M:

This is an appeal filed by the assessee Under Section 253 of the Income Tax Act, 1961 (hereinafter referred to as the “Act” for sake of brevity) before this Tribunal. The assessee is aggrieved by the order bearing Number ITBA/NFAC/S/250/2024- 25/1073117032(1) dated 11.02.2025 passed by the Ld. CIT(A) u/s 250 of the Act which is hereinafter referred to as the “Impugned order”. The relevant Assessment Year is 2018-19and the corresponding previous year period is from 01.04.2017 to

31.03.2018.

2. FACTUAL MATRIX

2.1 That as and by way of an assessment order passedu/s 147r.w.s. 144B of the Act, the assessee’s total income exigible to tax was computedand assessed at Rs.4,65,54,174/-.The income as per the return of income filed was at Rs.2,90,304/-. The addition on account of bogus purchase u/s 69C was at Rs.4,62,63,870/-. Some of the observations of the Ld. A.O is reproduced by us as below:-

“4.1 In response to notice issued, the assessee stated that The DGCI had conducted a search at our business premises on 18/01/2019 and has taken away all the original copies of invoices along with print outs of books of accounts for the period 01/07/2017 to 18/01/2019. The matter is under process with DGCI and that no order has been passed till now. Further State GST has investigated and searched our place of business on 26/12/2019 and has taken away all the relevant documents along with original documents for the period 19/01/2019 to 26/12/2019. The matter isstill under process and no order has been passed till now. Hence it is humbly submitted that, we have provided all possible documents for the purpose of assessment and that we are not in a position to provide copies of sales and purchase invoices, transportation details, weightment slip, godown address where material picked or any other document for the proceedings as these documents are under the custody of the above mentioned agencies. We are attaching the scanned copy of statement/ Panchanama for your kind perusal

4.2 In order to confirm the genuineness of transactions, letters u/s 133(6) of the Income Tax Act, 1961 was issued to Sh.Jasmat Singh Prop of M/s R.A.Enterprises and Sh.VikasAnand Prop. Of Radha Rani Trader on 16.02.2023 wherein they were asked to furnish details of sales made to the assessee alongwith copies of sale bills, transportation details, weightment slip, godown address where material picked or any other documents by the assessee. However, only copy of ledger account has been furnished by Sh.Jasmat Singh and no supporting document or evidence was furnished. Moreover ledger submitted by M/s. R A Enterprises belongs to M/s. Royal Enterprises, 77, Sector-E, Sanwer Road, Indore having PAN AJBPK6093K not to M/s. Rajveer leaf. Besides, there has been no response from Sh. VikasAnand. It is pertinent to mention that no supporting documentary evidence.

4.3 Thus from above enquiry report as well as in view of non furnishing of requisite documents like sales and purchase invoices, transportation details, weightment slip, godown address where material picked or any other documents either by the assessee or by the concerned parties, an amount of purchase of Rs. 4,39,78,860/- and Rs. 22,85,010/- shown by the assessee with M/s RA Enterprises and M/s Radha Rani Traders respectively during the financial year 2017-18 are treated as bogus purchase”.

2.2 That the aforesaid assessment order bears No.ITBA/AST/S/147/2022-23/10