BHANSALI UDYOG PRIVATE LIMITED, NEW DELHI,DELHI V. ITO, WARD 4(1), DELHI, NEW DELHI

ITA 1464/DEL/2025

AI Insights

The case involves Bhansali Udyog Pvt. Ltd., which appealed against the disallowance of purchases amounting to Rs.53,48,116 from M/s. RCI Industries and Technologies Ltd., treated as bogus under section 69C of the Income-tax Act, 1961. The initial disallowance was set at 12.5% by the CIT(A)/NFAC, amounting to Rs.6,68,515. The Tribunal, after considering various judicial precedents and the arguments from both parties, decided to reduce the disallowance to 10% of the alleged bogus purchases. The Tribunal noted that the assessee's business of manufacturing electrical wires and cables could involve sourcing from unregistered dealers, which was not entirely ruled out.

• Counselvise Citation: [2026] 140 COUNSELVISE.COM (IT) 827767 (ITAT-DELHI)
• Duration Of Justice: 9 month(s) 29 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 08-01-2026
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: E
• Assessment Year: 2018-2019
• Appeal Filed On: 10-03-2025
• Other Referred Cases: Ravjibhai Becharbhai Dhamelia vs. ACIT, PCIT Vs. Hitesh Mody (HUF), PCIT Vs. Forum Sales (P) Ltd., PCIT Vs. Kanak Impex (India) Ltd, DCIT Vs. Kohinoor Foods Ltd., DCIT Vs. Tirupati Matsup (P.) Ltd.
• Laws Referred To: Income-tax Act, 1961
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: ANKUSH KALRA
• Assessee Lawyers: ANKUR GULATI
• Keywords: Bogus purchase; Bogus
• Section: 147; 69C

Judgement Text

" IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘E’ NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER ITA No.1464/Del/2025 Assessment Year: 2018-19 Bhansali Udyog Pvt. Ltd., A-42, Phase-1, Mayapur, New Delhi Vs. Income Tax Officer, Ward-4(1), Delhi PAN: AABCB0090K (Appellant) (Respondent) ORDER PER SATBEER SINGH GODARA, JM This assessee’s appeal for assessment year 2018-19, 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/250/2024-25/1072279511 (1), dated 17.01.2025 involving proceedings under section 147 r.w.s. 144 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’). Heard both the parties. Case file perused. 2. It emerges during the course of hearing that the assessee presses for its sole substantive ground on merits challenging both Assessee by Sh. Ankur Gulati, CA Department by Ms. Ankush Kalra, Sr. DR Date of hearing 08.01.2026 Date of pronouncement 08.01.2026 Printed from counselvise.com ITA No.1464/Del/2025 2 | P a g e the learned lower authorities’ action treating its purchases amounting to Rs.53,48,116/- sourced from M/s. RCI Industries and Technologies Ltd., as bogus one under section 69C of the Act, in the assessment order dated 11.03.2023. The CIT(A)/NFAC has restricted the disallowance to 12.5% of purchases coming to Rs.6,68,515/-. 3. That being the case, both the parties vehemently reiterate their respective stands against and in support of the impugned bogus purchases disallowance. We wish to make it clear that there is no dispute in principle that the assessee is engaged in the business of manufacturing of electrical wires and cables all along wherein possibility of assessee sourcing its purchases from unregistered dealers per se could not be altogether ruled out as well. And that his corresponding sales have nowhere been questioned in both the lower proceedings. Various recent judicial precedents (2025) 173 taxmann.com 592 (Guj.) Ravjibhai Becharbhai Dhamelia vs. ACIT; (2024) 160 taxmann.com 110 (Bom) PCIT Vs. Hitesh Mody (HUF), (2024) 160 taxmann.com 93 (Del) PCIT Vs. Forum Sales (P) Ltd.; (2025) 172 taxmann.com 283 (Bom) PCIT Vs. Kanak Impex (India) Ltd; (2025) 178 taxmann.com Printed from counselvise.com ITA No.1464/Del/2025 3 | P a g e 424 (Del. – Trib.) DCIT Vs. Kohinoor Foods Ltd.; and (2025) 177 taxmann.com 836 (Delhi-trib.) DCIT Vs. Tirupati Matsup (P.) Ltd. have recently decided the instant issue of bogus purchases with divergent views as well. 4. Faced with these peculiar facts, it is thus deemed appropriate in the larger interest of justice that a lumpsum disallowance @ 10% of the assessee’s alleged bogus purchases restricted to Rs.6,68,515/- by the CIT(A), would be just and proper with a rider that the same shall not be treated as a precedent. The assessee’s book entries are hereby rejected to the very extent. Necessary computation shall follow as per law. No other ground or argument has been pressed. 5. This assessee’s appeal is partly allowed in above terms. Order pronounced in the open court on 8th January, 2026 Sd/- Sd/- (S. RIFAUR RAHMAN) (SATBEER SINGH GODARA) ACCOUNTANT MEMBER JUDICIAL MEMBER Dated: 12th January, 2026. RK/- Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(A) 5. DR Asst. Registrar, ITAT, New Delhi Printed from counselvise.com "