PUSHPA SALUJA vs ITO WARD 45(4) NEW DELHI

Judgment text excerpt

$~14 * IN THE HIGH COURT OF DELHI AT NEW DELHI % Date of Decision: 15.04.2025 + ITA 281/2024 & CM No. 28758/2024 PUSHPA SALUJA .....Appellant Through: Mr Kanishk Rana, Advocate. Versus ITO, WARD 45(4), NEW DELHI .....Respondent Through: Mr Puneet Rai, SSC, Mr Ashvini Kumar and Mr Rishabh Nangia, SCs and Mr Nikhil Jain, Advocate. CORAM: HON'BLE MR. JUSTICE VIBHU BAKHRU HON'BLE MR. JUSTICE TEJAS KARIA VIBHU BAKHRU, J. 1. The Assessee has filed the present appeal under Section 260A of the Income Tax Act, 1961 [Act] impugning an order dated 21.09.2023 [impugned order] passed by the learned Income Tax Appellate Tribunal [ITAT] in ITA No.1491/Del/2022 captioned Pushpa Saluja v. Income Tax Officer in respect of assessment year [AY] 2014-15. The Assessee has projected the following questions for consideration of this court: “(i) Whether the Ld. ITAT erred in upholding the wrongful application of Section 68 of the Income Tax Act, 1961 on alleged bogus purchases? (ii) Whether the Ld. ITAT erred in upholding addition of entire amount of the alleged bogus purchases to the income of the Appellant, instead of only gross profit margin embedded in the purchases? ITA 281/2024 Page 1 of 6 Signature Not Verified Digitally Signed By:TARUN RANA Signing Date:24.04.2025 13:03:18 (iii) Whether the Impugned Order passed by the Ld. ITAT is perverse?” 2. The Assessee had filed her return of income for AY 2014-15 on 03.11.2014 declaring an income of ₹15,75,420/-. The Assessee’s return was selected for scrutiny and the AO issued notices under Section 143(2) of the Act as well as under Section 142(1) of the Act. The assessment proceedings culminated in an assessment order dated 28.12.2016 whereby the AO assessed the Assessee’s total income at ₹71,29,800/-. The AO made an addition of ₹55,54,382/- con