Question 1

What are the key legal issues in ITO vs. Ramlal Manekchand HUF?

Accepted Answer

1. Whether the Ld. CIT(A) was justified in deleting the addition made of Rs.16,13,74,905/- u/s.69C of the Act without appreciating the fact that the assessee could not prove the creditworthiness, identity, and genuineness of the suppliers with whom it has carried out the transactions? 2. Whether the Ld. CIT(A) was justified in deleting the addition made of Rs.89,41,858/- on account of non-genuine purchases without appreciating the fact that the assessee could not prove genuineness of these parties with whom It has carried out the transactions?

Question 2

What are the facts of ITO vs. Ramlal Manekchand HUF?

Accepted Answer

The assessee, Ramlal Manekchand HUF, had filed an income return for the Assessment Year 2021-22 declaring income of Rs.18,91,730/-. The case was selected for scrutiny due to substantial purchases from suppliers who were either non-filers or had filed non-business Income-tax returns. The assessee is engaged in trading gold bullions, silver bullions, and jewellery. The Assessing Officer made additions in the assessment based on verification reports from the Designated Verification Units (DVU). Two suppliers were found to be working as labourers and in furniture-related work, and their business activities were not commensurate with the purchases. Another three suppliers were not traceable. Additions were made under Section 69C and for non-genuine purchases. The assessee appealed to the First Appellate Authority, which was decided in their favour by the Ld. CIT(A). The Revenue appealed to the Income Tax Appellate Tribunal.

ITO vs. Ramlal Manekchand HUF

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