IN THE INCOME-TAX APPELLATE TRIBUNAL, MUMBAI “J (SMC)” BENCH, MUMBAI BEFORE SMT BEENA PILLAI, JUDICIAL MEMBER AND SHRI BIJAYANANDA PRUSETH, ACCOUNTANT MEMBER ITO 19(3)(1), Room no 405, vs. Tagaram Ganesiiram Prajapati, 4Th floor, Piramal 51/11, Dhabi Building, Dr. MG Mahimtura Chambers, Parel, Mumbai- Marg, 3rd Kumbharwada opp. Durgadevi

400012. Garden, Mumbai-400004.

PAN/GIR No: AAKPPSIOID (Appellant) (Respondent)

Assessee by Ms. Pooja H. Chhawacharia Revenue by Shri Aditya Rai (SR DR)

Date of Hearing 24.03.2026 Date of Pronouncement 25.03.2026 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 (Appeals), ADDL/JCIT (A)-3, Bengaluru [in short, ‘CIT(A)’], dated

26.11.2025 for the assessment year (AY) 2009-10.

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

“1. Whether on the facts and in the circumstances of the case and in law, the Learned CIT(A) was justified in restricting the bogus purchases at the rate of 12:5 percent as against the 100 percent addition on account of bogus purchases of Rs. 1,57,08,424/- obtained from four enti