Mere discrepancy in classification of a transaction as ‘loan’ or ‘purchase advance’ does not justify an addition under Section 69A of the Income Tax Act, 1961, nor does it warrant revision under Section 263 of the Act.
25 June 2026 5:17 PM
The Ahmedabad bench of the Income Tax Appellate Tribunal (ITAT) ruled that the discrepancy between ‘Loan’ or ‘Purchase Advance’ not justifiable for addition under Section 69A of the Income Tax Act, 1961 or revision under Section 263 of the Income Tax Act, 1961.
The Assessing Officer (AO) received information that the assessee, Siddhartha Bronze Products Pvt. Ltd., had allegedly availed accommodation entries of Rs. 59,70,000 from M/s Kasturi Commodities Private Limited, prompting reopening of assessment under Section 147 of the Income Tax Act.
During the proceedings, the assessee claimed the amount was an advance for purchases which was later returned, while the said entity stated in response to notice under Section 133(6) that it had availed a short-term loan which was repaid.
Although the AO did not make an addition of the principal amount, he added 2% of the transaction as alleged commission income. The Principal Commissioner of Income Tax (PCIT), exercising revisionary powers under Section 263, observed inconsistencies in the explanations and held that the AO failed to make a full addition under Section 69A of the Act. Accordingly, the assessment order passed under Section 147 was set aside with a direction for fresh assessment in accordance with law.
The assessee explained that since the goods ordered (propeller) was not up to the mark, hence, the same were not purchased. M/s. Kasturi Commodities Pvt. Ltd., however, had replied that it had availed short term loan from the assessee, which was repaid.
The Tribunal of Sanjay Garg, Judicial Member and Narendra Prasad Sinha, Accountant Member noted that “Whether the assessee had given the amount as a short term loan or as advances for purchases, it makes no difference when there is no allegation that the said amount was advanced by the assessee from any undisclosed sources. It is also an admitted fact that the said amount was returned back by M/s. Kasturi Commodities Pvt. Ltd. to the assessee in a short span of time of 2-3 days, therefore, it is apparently not a case of any accommodation entry received by the assessee. We fail to understand as to how even the AO can conclude that the assessee might have earned some commission on the payment of this amount through a banking channel to M/s. Kasturi Commodities Pvt. Ltd. and especially when, the same was refunded, as such, to the assessee by the said party.”
It was held that the case did not involve accommodation entries or bogus purchases, as the assessee had not undertaken any purchase transactions and the amount in question was ultimately refunded. The exercise of revisionary jurisdiction under Section 263 of the Income Tax Act, 1961 by the Principal Commissioner of Income Tax (PCIT) was therefore found to be unjustified.
Accordingly, the revision order passed under Section 263 was held to be without jurisdiction and was quashed.
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Siddhartha Bronze Products Pvt. Ltd. vs DCIT
CITATION : 2026 TAXSCAN (ITAT) 905Case Number : I.T.A. No. 305/Ahd/2026Date of Judgement : 19 June 2026Coram : SANJAY GARG, JUDICIAL MEMBER & NARENDRA PRASAD SINHA, ACCOUNTANT MEMBERCounsel of Appellant : Aseem Thakkar, A.R.Counsel Of Respondent : R P Rastogi, CIT. DR
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ICAI to Declare CA Foundation May 2026 Results on July 3
The Foundation exam serves as the entry point to the Chartered Accountancy course, while the Intermediate level acts as a gateway to articleship training and the Final examination.
25 June 2026 6:26 PM
The Institute of Chartered Accountants of India (ICAI) has announced that the results of the Chartered Accountants Foundation Examination held in May 2026 will be declared by the afternoon of July 3, 2026.
Candidates will be able to access their results on the official ICAI website, caresults.icai.org. To view their scorecards, students must log in using their Registration Number and Roll Number, as specified by the Examination Department.
The Foundation Examination, conducted in May 2026, is a crucial entry‑level test for aspiring Chartered Accountants across the country. The declaration of results marks an important milestone for thousands of candidates who appeared for the exam. The announcement was issued by Anand Kumar Chaturvedi, Joint Secretary (Exams), underscoring ICAI’s continued commitment to transparency and timely communication in its examination process.
Recently, the Institute of Chartered Accountants (ICAI) announced the results of the Chartered Accountants Intermediate Examination held in May 2026 through a press release dated June 24, 2026.
Also, the Institute of Chartered Accountants of India ( ICAI ) has declared the CA final examination results. The examination was conducted in the month of May from the 2nd to the 12th this year. In Group I, a total of 54,606 candidates appeared for the exam, with 6,555 successfully clearing it. For Group II 8,725 out of the 42,573 candidates passed. Additionally, 3,345 out of the 23,776 candidates who attempted both groups successfully cleared them.
The CA Foundation Examination is the entry‑level test conducted by the Institute of Chartered Accountants of India (ICAI) for students aspiring to become Chartered Accountants. It serves as the first stage of the Chartered Accountancy course, designed to assess a candidate’s understanding of fundamental accounting, business, and legal concepts.
This exam evaluates proficiency across subjects such as Principles and Practice of Accounting, Business Laws and Business Correspondence, Business Mathematics and Logical Reasoning, and Business Economics.
After the CA Foundation Examination, candidates who qualify become eligible to register for the CA Intermediate level, which is the second stage of the Chartered Accountancy course conducted by the Institute of Chartered Accountants of India (ICAI).
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