Kandoi Metal Powders Manufacturing Co. Pvt. Ltd. vs. DCIT

Parties Involved

Facts Summary

The assessee, Kandoi Metal Powders Manufacturing Co. Pvt. Ltd., is engaged in the business of manufacturing copper wire and other copper-related products. The case pertains to the reassessment of the assessee's income for the assessment year 2012-13. The original assessment was completed under section 143(3)/153C of the Income Tax Act, 1961. The case was reopened under section 147 of the Act due to the suspicion of bogus purchases. The Assessing Officer (AO) found that the assessee had engaged in bogus purchases amounting to Rs. 21,05,94,215/-. The assessee filed an appeal against the order of the Commissioner of Income Tax (Appeals)-4, Jaipur, dated 29/03/2022. The appeal was decided by the Bench on 15.09.2022, taking into consideration the judgment of the Rajasthan High Court in the case of CIT(Central), Jaipur vs. M/s Clarity Gold (P.) Ltd. The assessee challenged the order of the Commissioner of Income Tax (Appeals)-4, Jaipur, dated 29/03/2022, which sustained the addition of Rs. 1,14,76,726/- on account of gross profit and Rs. 6,88,603/- on account of alleged commission payment. The assessee argued that the addition should not be sustained as the purchases were genuine and the AO treated genuine purchases as non-genuine. The Bench considered the arguments and submissions of both parties and decided the appeal on 01/10/2024.…

Legal Issues

• 1. Whether the addition of Rs. 1,14,76,726/- on account of gross profit is sustainable?
• 2. Whether the addition of Rs. 6,88,603/- on account of alleged commission payment is sustainable?

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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