IN THE INCOME-TAX APPELLATE TRIBUNAL, SURAT BENCH, SURAT BEFORE MS SUCHITRA RAGHUNATH KAMBLE, JUDICIAL MEMBER AND SHRI BIJAYANANDA PRUSETH, ACCOUNTANT MEMBER ITO, vs. Krishna Syn Fab Private Limited Ward - 1(1)(3), D-210, International Trade Center, Surat Majura Gate, Surat - 395001 èथायीलेखासं /.जीआइआरसं /.PAN/GIR No: AADCK6406A (Appellant) (Respondent)

Appellant by Shri Mukesh Jain, CIT-DR with Shri Kevin Langaliya, CA Respondent by Shri Rasesh Shah, CA Date of Hearing 18/11/2025 Date of Pronouncement 16/12/2025 आदेश (cid:877) O R D E R PER BIJYANANDA PRUSETH, AM:

This appeal filed by the revenue emanates from the order passed under section 250 of the Income-tax Act, 1961 (in short, ‘Act’) by the Commissioner of Income-Tax, National Faceless Appeal Centre [in short, ‘CIT(A), NFAC’], Delhi, dated

03/09/2024 for the Assessment Year 2014-15.

2. The grounds of appeal raised by the revenue are as under:

“1. On the basis of the facts and circumstances of the case and in law, the ld. CIT(A) has erred in allowing the appeal of the assessee and deleting the addition made by the AO of Rs.5,15,40,770/- on account of making addition of export benefits of the assessee and rejecting the claim of trading activities of the assessee even though the assessee company has failed to prove the genuineness of the purchases during the assessment proceedings.

2. On the basis of the facts and circumstances of the case and in law, the Id. CIT(A) has not appreciated that during the course of assessment proceedings on being provided ample opportunity of being heard the assessee could not prove the genuineness of the purchases and in absence of the same the AO has rightly rejected the claim of the trading activities of the assessee and taxed the export benefits claimed.

3. It is therefore prayed that the order of ld. CIT(A) may kindly be set aside that of the Assessing Officer be restored.

4. The appellant craves leave to add, alter, amend and/or withdraw any ground of appeal either before or during the course of hearing of the appeal.”

3. Since all the above grounds raised by the revenue pertain to a common issue, being the correctness of the action of the CIT(A) in deleting the addition made by the Assessing Officer (in short, ‘AO’) on account of unverifiable purchases and consequential impact on the trading results, they are being adjudicated together through a consolidated reasoning in the interest of clarity and to avoid repetition.

4. The facts of the case in brief are that the assessee filed its return declaring income of Rs.14,73,640/-. The case was selected for scrutiny. The assessee reported turnover of Rs.1,05,31,18,743/- from trading, import and export activities. The assessee also earned other income of Rs.5,15,40,774/- including duty drawback, exchange rate difference, focus product scheme, interest etc. To verify the correctness of purchase transactions, the AO issued notices u/s 133(6) to several suppliers. Most notices were returned unserved with postal remarks such as “Left, Not Known, Shifted, Insufficient Address”. The AO, thereafter, issued summons u/s 131 of the Act to certain suppliers such as M/s Khetrapal Corporation, M/s Shejal Enterprise, M/s Oasis Trading Co., M/s Mohit Trading Co. and M/s Shree Sai Traders.

These also returned unserved. Field enquiries revealed that the said entities did not exist at the declared addresses. The assessee was confronted about the above fact and was required to produce suppliers and supporting documentary evidence. The Director of the assessee appeared u/s 131 of the Act and assured production of documentary evidence and parties; however, no supporting documentary proof or any of the suppliers were ever produced despite multiple opportunities.

5. The AO also examined the invoices and noted serious inconsistencies. The bills did not contain GST/VAT or statutory identifiers. Signatures across different parties appeared in identical handwriting and format, suggesting a common origin. Invoices for iron and ste