ITA No.383/Del/2025 & CO No.281/Del/2025 Payal Garg (AY: 2021-22)

Parties Involved

Facts Summary

The assessee, Payal Garg, runs a proprietorship concern named 'M/s. Satya International' engaged in trading wire and wire mesh. The Assessing Officer disallowed purchases aggregating to Rs. 4,51,90,010/- from six suppliers, treating them as bogus and added the same under Section 69C read with Section 115BDE of the Income Tax Act, 1961. However, the First Appellate Authority found the purchases genuine and deleted the addition. The revenue appealed this decision, and the assessee filed cross-objections.…

Legal Issues

• 1. Whether the additions could have been made under Section 69C of the Act.
• 2. Whether the focus of Section 69C is on the source of expenditure or the authenticity of the expenditure.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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