PCIT v. Sunil Devkishan Panwar (2026) 310 Taxman 607 (Guj)(HC)

S. 69C: Unexplained expenditure-Bogus purchases-Failure to give an opportunity of cross-examination-Sham transaction-Deletion of addition was affirmed.[S.147, 148, 260A]

Assessee filed his return of income, and scrutiny assessment under section 143(3) was completed.Based on information from the Investigation Wing, Mumbai regarding transactions with Keshav Impex, notice under section 148 was issued and reassessment proceedings were initiated.  Commissioner(Appeals) allowed the assessee’s appeal, holding that the Assessing Officer had failed to discharge the onus of disproving the transactions as sham and accepting the assessee’s contention that underlying material was not supplied and opportunity of cross-examination was denied.  Tribunal affirmed the order and dismissed the revenue’s appeal. Order of Tribunal affirmed.   (AY. 2012-13)

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