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DCIT, Circle-I, Bathinda. (Appellant) Vs. Aggarwal Construction Company (Respondent) and Aggarwal Construction Company (Appellant) Vs. DCIT, Circle-I, Bathinda. (Respondent)

Case No: I.T.A. No.352/Asr/2023 and ITA No. 366/Asr/2023
Court: Income Tax Appellate Tribunal, Amritsar Bench
Date: 9/19/2024

Parties Involved

appellantDCIT, Circle-I, Bathinda.
respondentAggarwal Construction Company
appellantAggarwal Construction Company
respondentDCIT, Circle-I, Bathinda.

Facts Summary

The assessee, Aggarwal Construction Company, is a partnership firm engaged in the business of development of colonies, trading of construction materials, and construction work. The company filed its income return under section 139(1) of the Income Tax Act, 61, declaring a returned income of Rs.71,99,271/-. The Assessing Officer issued a notice under section 148 of the Act, alleging that the assessee had made bogus purchases amounting to Rs. 10,29,40,198/- during the year under consideration. The assessee responded with detailed submissions and documentary evidence, including bank statements, purchase bills, and VAT returns, to demonstrate that the purchases were genuine and had been used for construction of the Talwandi Sabo Thermal Power Plant. The CIT(A) sustained the addition of Rs. 4,29,39,587/- (25% of the alleged bogus purchases), which both the department and the assessee appealed against.

Decision in favour of

Partly Assessee / Partly Revenue

Legal Issues

  • 1. Whether the CIT(A) erred in limiting the addition to 25% of bogus purchases as against 100%?
  • 2. Whether the reassessment notice issued under section 148 was valid?

Judgment Outcome

Decided in favour of Partly Assessee / Partly Revenue.

Precedents Relied Upon

2 precedents cited in this judgement.

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