In Bholenath Foods Limited v. Deputy Commissioner of Income Tax, the Delhi Bench of the Income Tax Appellate Tribunal examined the validity of an appellate order confirming addition of ₹1.35 crore on account of alleged bogus purchases and accommodation entries for Assessment Year 2012–13.

The assessment was reopened on the basis of information received from the Investigation Wing alleging that the assessee had made purchases from a proprietorship concern controlled by an accommodation entry provider. The Assessing Officer made additions under Section 68 relying primarily on a third-party statement. The CIT(A), National Faceless Appeal Centre, upheld the reassessment and confirmed the addition, observing that the assessee failed to furnish sufficient documentary evidence to establish the genuineness of purchases.

The Tribunal noted that while the CIT(A) listed various documents and evidences required to establish genuineness of purchases, the appellate authority dismissed the appeal without deciding the issues in accordance with the mandatory requirements of Section 250(6), which obligates the CIT(A) to pass a reasoned order stating points for determination, decisions thereon, and reasons for such decisions.

Holding that the impugned appellate order was passed in violation of statutory mandate and principles of natural justice, the ITAT set aside the order of the CIT(A) and restored the matter for fresh adjudication.
The Tribunal directed that adequate opportunity be granted to the assessee to furnish complete details and that the appeal be decided afresh by a speaking order in accordance with law.

Accordingly, the appeal was disposed of by way of remand.

Source Link- https://itat.gov.in/public/files/upload/1767785814-ackzsA-1-TO.pdf

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