LAKHTARWALA JEWELLERS PRIVATE LIMITED,AHMEDABAD vs. DCIT CIRCLE 2(1)(1), AHMEDABAD

PER ANNAPURNA GUPTA, AM:

The present appeal has been filed by the Assessee against the order of the National Faceless Appeal Centre (NFAC), Delhi (hereinafter referred to as “CIT(A)”) dated 20.11.2025 passed under Section 250 of the Income Tax Act, 1961 (hereinafter referred to as the “Act”).

ITA No.2459/Ahd/2025 Lakhtarwala Jewellers Prívate Limited - 2 –

ITA No.2459/Ahd/2025 Lakhtarwala Jewellers Prívate Limited - 3 – 3. Briefly stated, pursuant to a search action carried out in the case of Operation Jewel Star and its various associated concerns and persons, u/s 132 of the Act on 11.07.2023, J.P. Group, being one of the biggest consortiums of jewellers in Rajkot was also covered under this operation and which revealed that the Group was involved in making unaccounted sales to various entities including the assessee. The assessee was noted to have made unaccounted purchases of Rs.39,49,343/- from the J.P. Group. This was revealed in post-search investigation, wherein it was found that the J.P. Group was using various softwares, and while it was using one particular set of softwares like Tally or Miracle where all the accounted transactions were recorded, in the other set of softwares namely JSoft, all accounted sales and unaccounted transactions were recorded. A comprehensive exercise was carried out establishing the aforesaid fact. A complete excel list for the impugned Year, AY 2019-20, extracted from the JSoft software, revealed that the assessee, M/s Lakhtarwala Jewellers Private Limited had made bogus purchase from M/s J.P. Exports aggregating in all of Rs.39,49,343/-. 4. Based on the above information, the case of the assessee, was reopened by issuing notice u/s 148 of the Act, and after considering the replies filed by the assessee, assessment was framed making addition on account of the unaccounted purchases of the assessee as revealed from the search action conducted on the J.P. Group amounting to Rs.39,49,343/-.Further addition on

ITA No.2459/Ahd/2025 Lakhtarwala Jewellers Prívate Limited - 4 – account of disallowance of depreciation claim of Trademark amounting to Rs.1,63,47,656/- was also made. 5. The assessee filed an appeal against the assessment order before the Ld. CIT(A), who confirmed the order of the AO, aggrieved, by which, the assessee has come up in appeal before us. 6. Taking up first the issue of addition made to the income of the assessee on account of unaccounted purchases, the contention of the ld. Counsel for the assessee before us was that the assessee had demonstrated to the Authorities below that the alleged unaccounted purchases were all duly accounted for the in the books of accounts of the assessee. That the Revenue did not controvert this fact but the only infirmity noted by them was that while these purchases in the JSoft Accounting Software of the J.P. Group were recorded in the first half of the accounting year, the assessee had recorded these transactions in its books of accounts in the latter half of the accounting year. He pointed out that no other discrepancy was noted by the Revenue Authorities, and he therefore, contended that, having sufficiently established that the allegation of the assessee having entered into any unaccounted transaction of purchase with the J.P. Group was factually incorrect, there was no reason at all for making any addition to the income of the assessee, on account of the unaccounted purchases made from the J.P. Group to the tune of Rs.39,49,343/-. In this regard, he first drew our attention to the alleged list of unaccounted transactions undertaken by the assessee from M/s J.P. Exports as listed at para 4.4 of the order as under:-

ITA No.2459/Ahd/2025 Lakhtarwala Jewellers Prívate Limited - 5 – 4.4 On perusal of the complete excel list for the F.Y. 2019-20 extracted from JSoft, it is found that Lakhtarwala Jewellers Private Limited -PAN: AACCL9522F has made bogus purchase from M/s. J.P. Exports on the following dates as under:

At the outset we state that we are not involve in alleged bogus purchase to the tune of Rs. 39,49,343/-. The invoice details provided in the table below reconcile with the net weight in grams as stated in the notice. We have enclosed a copy of the Excel sheet containing the reconciliation of the net weight in grams as recorded in the invoice with the figures reflected in the notice. [Page No. 5] Following table shows the entries stand reconciled with invoices.

ITA No.2459/Ahd/2025 Lakhtarwala Jewellers Prívate Limited - 6 – As mentioned earlier, there is total purchase transaction of Rs. 63,70,388/- with J P Exports.

Below table contains the summary of net weight reconciliation with annexure provided in the notice:

Please note that we have accounted purchases of 1622.290 grams in our books.

From the above, it is evident that out of 705.74 grams as mentioned in the notice, net weight of 664.07 grams stands reconciled. The weight of Rs. 664.07 grams is purchased for value of Rs. 25,99,426/-. It is pertinent to note that the rate considered at Rs. 3522 is vague and without any supporting evidence.

It seems from the notice that AO has taken average rate per gram. From the invoices enclosed, it will be found that there is purchase of 22 et Gold Ornaments and the rates are accordingly mentioned in it. Under such a scenario, any average rate mentioned cannot be relied upon.

It seems that JP Exports has recorded the sale order in JSoft, which merely reflects when the order was placed, rather than the actual sale date when the transaction was executed. Furthermore, there is a discrepancy between the date mentioned on the purchase invoice and the date stated in the notice, which leading to inconsistencies in the records.

We have maintained all the necessary documents to substantiate the legitimacy of the transactions. The following documents are enclosed for Your Honour reference:

I. Purchase Invoice: We have enclosed the copies of GST invoices of all purchase made with JP Exports. Purchase invoices duly signed by authorised person of JP Exports, same has been reflected in invoices attached herewith. [Page No. 6 to 21]

II. Bank Statement: Payment for the purchases has been made through banking channels, and the same is reflected in our bank statement. We have enclosed the copy of bank statement with highlighting the transaction. [Page No. 22 to 26]

ITA No.2459/Ahd/2025 Lakhtarwala Jewellers Prívate Limited - 7 –

III. Ledger Account: We have enclosed the copy of JP Exports ledger account from our books of account, duly confirmed by the JP Exports. [Page No. 27 to 29]

IV. GST Compliance: GSTR-2B is an auto-generated Input Tax Credit statement issued by the GST portal every month. It provides details of inward supplies (purchases) as reported by the supplier in their GSTR-1 return. We have enclosed the copy of GSTR 2B. [Page No. 30]

Matching with Supplier's GSTR-1:  If a purchase is genuine, the supplier must have reported the sale in their GSTR-1.  If the transaction appears in GSTR-2B, it confirms that the supplier has declared the sale and paid GST.  All purchases made from JP Exports are duly reflected in our GSTR- 2B, which confirms that JP Exports has reported these sales in their GSTR-1.  This proves that the transaction is not fictitious or bogus.

V. Stock Register: The purchased goods have been duly recorded in the stock register. A copy of stock register was furnished vide reply dated 19/03/202.

All purchases are duly reflected in the GST invoices issued by JP Exports and have been thoroughly verified against the supporting documents mentioned above.

The transaction is bona fide and fully compliant, with complete documentation available for verification. Therefore, the claim of a bogus purchase is incorrect, and we kindly request Your Honour to consider our submission and not take any adverse action.

The notice states that Shri Ishan Sanjaybhai Rajpara and Shri Maulik Jitendrabhai Joshi have given statements under Section 131(1A) of the Income Tax Act, 1961. We kindly request Your Honour to provide copies of full statement recorded under Section 131(1A) of the Act, rather than just the extracted portion mentioned in the notice.

On perusal of the extracted portion of the statement, it is evident that nowhere our name appears. From the extracted portion of the statement, it can be inferred that we have got no relevance with the statement recorded.

ITA No.2459/Ahd/2025 Lakhtarwala Jewellers Prívate Limited - 8 –

We respectfully submit that Your Honour has relied upon the statements of employees to allege unaccounted purchases. In the interest of natural justice, we request an opportunity to cross-examine to assess the authenticity, accuracy, and relevance of statements recorded. Since these statements form the foundation of the proposed addition, denying the assessee this right would constitute a violation of the principles of natural justice. It is pertinent to note that employers' statements cannot be relied upon for making any addition. This will enable us to thoroughly cross-verify all details for our clarity. 8. He further, pointed out, that the assessee had clarified that what was recorded in the books of J.P. Exports was probably the sales order, which merely reflected when the order was placed, rather than the actual sale date when the transaction was executed. He further pointed out, that the assessee had maintained all documents, evidencing the said transaction being purchase invoices, copy of GST invoices, Bank Statement, GST Compliance:- GSTR-2B is an auto-generated Input Tax Credit statement issued by the GST Portal every month, providing details of inward supplies as reported by the supplier in their GSTR-1 return, stock register, that all purchases were duly reflected in the GST Invoices issued by J.P. Exports. He drew our attention to para 5.2 of AOs order, pointing out, that except for noting the fact that the alleged unaccounted sale transaction of the assessee with J.P. Exports were recorded in different months in the books of the assessee as opposed to the months in which they were recorded in the books of J.P. Exports, no infirmity was pointed out by the AO in the impugned transaction.

ITA No.2459/Ahd/2025 Lakhtarwala Jewellers Prívate Limited - 9 – 5.2 The reply filed by the assessee is considered but the same is not tenable in view of the following observations:

 The assessee has admitted to having made sale/purchase transaction with JP Exports during the AY under consideration.

 It is observed that the assessee has attempted to reconcile the data found / extracted from the seized data of J.P. Exports and has matched the quantities recorded in such analyzed data. Still, the dates on which such purchases are claimed to be recorded by the assessee do not match with the dates found recorded in the seized/analyzed data. Thus, the reconciliation is not reliable and indicates to manipulation in the books to cover it up.  The reconciliation provided makes it clear that the purchases recorded in the books of the assessee are in the months of Nov-19 to Mar-20, whereas the sales recorded in the books / seized data pertain to the period May-19 to Nov-19. This observation lead to draw an inference about the manipulation in books.

 The assessee's contention that the seized/analyzed data appears to be the order placement, whereas the assessee records purchases in the books, when transaction is completed does not bears any fruits as it cannot happen that all the orders are palced in first part of the FY under consideration on different dates and without even completion of single order placed before month of Nov-19, the assessee has placed repeated purchase orders to JP Exports on different dates for various specific quantities. And, surprisingly all the orders were completed by JP Exports only during and after Nov-19 and that too the the rates prevailing on dates of generation of bills. The gold prices fluctuates on daily basis, as such this contention of the assessee does not appears true.

 The assessee heavily relied upon the documentation made to prove the transactions as real and asserted upon the match of the bills recorded with the GST return filed. However, this is the main allegation for the manipulation as the sales recorded in the seized/analysed dats in name of the assessee

ITA No.2459/Ahd/2025 Lakhtarwala Jewellers Prívate Limited - 10 – during the period APR-19 to Nov-19 do not match with the GST return of JP Exports and thus gives an impression of unrecorded sales which as a counter transaction happens to be the unaccounted purchases for the assessee.

 The rates adopted while analysing the data by the then investigation officer is taken at same rate (probably the average rate) for all the bills as, the corresponding bills were not present and it represents the unrecorded sales in books of JP exports and correspondingly the unaccounted purchases in the books of the assessee.

 The quantities of the transaction under reference are recorded in the books of the assessee in later part of the year, whereas the exact same quantity (in majority cases) appears in the seized data in first part of the FY under consideration. This itself is sufficient to prove that the assessees books are defective and manipulated.

 Shri Maulik Jitendrabhai Joshi, an employee of JP Exports (responsible for making data entry in software J Soft) has confirmed in his statement that all the entries are entered in the JSoft software whereas only entries that are to be accounted are made in Tally/Miracle. This itself is testimony to the findings and fortifies the fact that the entries found in the seied/analyzed data are not billed and thus represent the unaccounted purchases for the Assessee for the AY under consideration. Relevant extract of the statement was already provided to the assessee via SCN issued and the same is reproduced elsewhere in the body of the order, and not reproduced herein again for the sake of brevity.

 The assessee's request for supply of the full statement of both persons recorded u/s. 131(1A) of the Act cannot be adhered to, as the same is confidential in nature and may contain other details not relevant to the assessee. The relevant extract of these statements has already been supplied to the assessee.

ITA No.2459/Ahd/2025 Lakhtarwala Jewellers Prívate Limited - 11 – 10. We have heard the rival contentions. Undoubtedly the issue for adjudication is the addition made to the income of the assessee on account of alleged unaccounted purchases made by the assessee from J.P. Exports amounting to Rs.39,49,343/-. We have gone through the findings of the AO as pointed out to us, by ld. Counsel for the assessee at para 5.2 of the order, and we have noted that the AO has literally admitted to the fact, that the alleged unaccounted entries were accounted in the books of the assessee. Having said so, we find that there is no case for holding the assessee to have made any unaccounted purchases at all from J.P. Exports in relation to the transactions identified by the Revenue. 11. Besides we have noted that, the only discrepancy noted by the Revenue is with regards to the period for the said transaction, while J.P. Exports data apparently revealed the transactions to have been conducted in the first half of the year, the assessee’s records revealed that the transaction recorded in the second half of the year. There were other discrepancy noted by the AO, but be that so, we find that it is not the case of the Revenue that the transactions recorded by the assessee in his books of accounts, were not those which were noted by the AO to be unaccounted transactions as per the data revealed during search action on the J.P. Group. 12. Therefore, as long as the fact remains that the alleged unaccounted transaction with J.P. Exports were sufficiently demonstrated to be duly accounted in the books of accounts of the

ITA No.2459/Ahd/2025 Lakhtarwala Jewellers Prívate Limited - 12 – assessee, there can be no case, we hold for treating the impugned transactions as unaccounted in the books of the assessee. The addition therefore, made in the hands of the assessee on account of unaccounted purchases to the tune of Rs.39,49,343/-, we hold has no legs to stand upon on the facts itself, and we accordingly delete the same. 13. In view of the above, grounds of appeal Nos.2 to 4 raised by the assessee, are allowed. 14. The next issue raised by the assessee before us, relates to the disallowance of depreciation claim on trademark amounting to Rs.1,63,47,656/-. The contention of the ld. Counsel for the assessee before us, was that, on merits the issue of depreciation of trademark was a legacy issue from AY 2016-17 being the first order of disallowance of depreciation which was pending before the Ld. CIT(A). His other contention before us, was that, if the assessee succeeded on the issue of bogus purchase, no addition could be made on the issue of depreciation of trademark in the re- assessment proceedings, since the main issue was not part of the basis for reopening. In this regard, he relied on the decision of the Hon’ble Delhi High Court in the case of Valmik Thapar Vs. Principal Commissioner of Income-tax [2025] reported in 173 taxmann.com 983 (Delhi). Copy of the order was placed before us, and our attention was drawn to para 26 to 37 as under:- ………… 26. The learned counsel appearing for the Assessee has confined the present appeal on the sole ground that the additions made were not sustainable as the additions made on the basis of the reasons recorded for reopening of the assessment had been deleted.

ITA No.2459/Ahd/2025 Lakhtarwala Jewellers Prívate Limited - 13 –

"Return declaring an income of Rs.2,91,02,041/- for A.Y. 2010-11 in this case was filed on 26.7.2010. A perusal of computation of total income annexed with a the return shows that during the year, the assessee has received an amount of Rs.14,20,00,000/- from sale of 50% share in House No.19, Kautilya Marg, New Delhi.

The assessee has declared Long Term Capital Gain of Rs.2,50,36,358/-, Out of Sale Proceeds, the assessee has made the following investments:-

(a) Investment in REC Capital Gain bonds on 24.02.2009 out of advance rcvd: Rs.50,00,000/-proceedings for two reasons. First, that the deduction under Section 54EC of the Act was in excess of Rs.50,00,000/- which according to the AO was not permissible. And second, that the Assessee had claimed deduction under Section 54 of the Act on account of investments made in two properties: Rs.3,77,65,215/- for purchasing a flat at Mumbai [new asset] and Rs.1,70,00,000/-for construction of the one half share of the subject property retained by the

(a) Investment in NHAI Bonds on 9.12.2009 out of Advance Rs.50,00,000/-

Section 54EC reads as under:-

(1) Where the capital gains arises from the transfer of a longterm capital Asset and

(2) Proviso to Sec. 54EC reads as under:-

[Provided that the investment made on or after the 1st day of April, 2007 in the long term specified asset by an assessee during any financial year does not exceed fifty Lakh rupees.]

In this case, the assessee has claimed deduction u/s 50EC for Rs.1 Crore. The assessee has invested an amount exceeding Rs.50,00,000/- in long term capital assets out of sale proceeds, proviso to Section 54EC is clearly applicable in this case. Thus the deduction u/s 54EC on LTCG amounting to Rs.50,00,000/- has been claimed in excess which required to be taxed. As assessee has made a wrong claim for deduction u/s 54EC and income (LTCG) of Rs.50 lacs chargeable to income-tax has escaped assessment.

ITA No.2459/Ahd/2025 Lakhtarwala Jewellers Prívate Limited - 14 – Apart from above, assessee has also claimed deduction u/s 54 amounting to Rs.3,77,65,215/-& Rs.1,70,00,000/- by making investment in two capital assets (new property) whereas deduction u/s 54 is allowable for only one property. In view of this, the assessee has claimed excess deduction u/s 54 which is liable to be withdrawn and taxed.

In view of this, I have reason to believe that income as mentioned above has escaped assessment and accordingly proceedings u/s 147 of the Income-tax Act, 1961 are initiated. Notice u/s 148 of the Income-tax Act, 1961 is being issued."

ITA No.2459/Ahd/2025 Lakhtarwala Jewellers Prívate Limited - 15 – the decision of the Madras High Court in CIT v. C. Jaichander [2015] 53 taxmann.com 466/229 Taxman 10/370 ITR 579 (Madras) concluded that the issue whether a deduction under Section 54EC of the Act could exceed the said amount, as claimed by the Assessee, was covered in the Assessee's favour. The Revenue's appeal against the CIT(A)'s order was, accordingly dismissed.

"17. Now, coming back to the interpretation which was given by the Bombay High Court to sections 147 and 148 in view of the precedent on the subject, the court held as under (pages 243 and 247 of 331 ITR):

"Interpreting the provision as it stands and without adding or deducting from the words used by Parliament, it is clear that upon the formation of a reason to believe under section 147 and following the issuance of a notice under section 148, the Assessing Officer has the power to assess or reassess the income which he has reason to believe had escaped assessment, and also any other income chargeable to tax. The words 'and also' cannot be ignored. The interpretation which the court places on the provision should not result in diluting the effect of these words or rendering any part of the language used by Parliament otiose. Parliament having used the words 'assess or reassess such income and also any other income chargeable to tax which has escaped assessment', the words 'and also' cannot be read as being in the alternative. On the contrary, the correct interpretation would be to regard those words as being conjunctive and cumulative. It is of some significance that Parliament has not used the word 'or'. The Legislature did not rest content by merely using the word 'and'. The words 'and' as well as 'also' have been used together and in conjunction......

ITA No.2459/Ahd/2025 Lakhtarwala Jewellers Prívate Limited - 16 – Evidently, therefore, what Parliament intends by use of the words 'and also' is that the Assessing Officer, upon the formation of a reason to believe under section 147 and the issuance of a notice chargeable to tax which has escaped assessment and which comes to his notice subsequently in the and also (if) any course of the proceedings under the section. The words 'such income refer to the income chargeable to tax which has escaped assessment and in respect of which the Assessing Officer has formed a reason to believe that it has escaped assessment. Hence, the language which has been used by Parliament is indicative of the position that the assessment or reassessment must be in respect of the income in respect of which he has formed a reason to believe that it has escaped assessment and also in respect of any other income which comes to his notice subsequently during the course of the proceedings as having escaped assessment. If the income, the escapement of which was the basis of the formation of the reason to believe is not assessed or reassessed, it would not be open to the Assessing Officer to independently assess only that income which comes to his notice subsequently in the course of the proceedings under the section as having escaped assessment. If upon the issuance of a notice under section 148(2), the Assessing Officer accepts the objections of the assessee and does not assess or reassess the income which was the basis of the notice, it would not be open to him to assess income under some other issue independently. Parliament when it enacted the provisions of section 147 with effect from April 1, 1989 clearly stipulated that the Assessing Officer has to assess or reassess the income which he had reason to believe had escaped assessment and also any other income chargeable to tax which came to his notice during the proceedings. In the absence of the assessment or reassessment the former, he cannot independently assess the latter....

Section 147 has this effect that the Assessing Officer has to assess or reassess the income ('such income') which escaped assessment and which was the basis of the formation of belief and if he does so, he can also assess or reassess any other income which has escaped assessment and which comes to his notice during the course of the proceedings. However, if after issuing a notice under section 148, he accepted the contention of the assessee and holds that the income which he has initially formed a reason to believe had escaped assessment, has as a matter of fact not escaped assessment, it is not open to him independently to assess some other income. If he intends to do so, a fresh notice under section 148 would be necessary, the legality of which would be tested in the event of a challenge by the assessee."

ITA No.2459/Ahd/2025 Lakhtarwala Jewellers Prívate Limited - 17 – 18. We are in complete agreement with the reasoning of the Division Bench of the Bombay High Court in the case of CIT v. Jet Airways (1) Limited [2010] 195 Taxman 117/331 ITR 236 (Bombay). We may also note that the heading of section 147 is "income escaping assessment" and that of section 148 "issue of notice where income escaped assessment". Sections 148 is supplementary and complimentary to section 147. Sub- section (2) of section 148 mandates reasons for issuance of notice by the Assessing Officer and sub-section (1) thereof mandates service of notice to the assessee before the Assessing Officer proceeds to assess, reassess or recompute the escaped income. Section 147 mandates recording of reasons to believe by the Assessing Officer that the income chargeable to tax has escaped assessment. All these conditions are required to be fulfilled to assess or reassess the escaped income chargeable to tax. As per Explanation 3 if during the course of these proceedings the Assessing Officer comes to conclusion that some items have escaped assessment, then notwithstanding that those items were not included in the reasons to believe as recorded for initiation of the proceedings and the notice, he would be competent to make assessment of those items. However, the Legislature could not be presumed to have intended to give blanket powers to the Assessing Officer that on assuming jurisdiction under section 147 regarding assessment or reassessment of the escaped income, he would keep on making roving inquiry and thereby including different items of income not connected or related with the reasons to believe, on the basis of which he assumed jurisdiction. For every new issue coming before the Assessing Officer during the course of proceedings of assessment or reassessment of escaped income, and which he intends to take into account, he would be required to issue a fresh notice under section 148."

"23. It becomes evident that the Court in Ranbaxy Laboratories Ltd., firstly took into consideration Section 147 of the Act, embodying the phrase "and also" prefixed to the expression "any other income chargeable to tax which has escaped assessment". It thus came to the conclusion that, while an assessment may be reopened based on certain grounds which may have led the AO to be of the opinion that income chargeable to tax had escaped assessment, once it is found thatthe reassessment power had been validly invoked, the power of the AO would not stand confined only to those aspects which may have been noticed in the original notice issued

ITA No.2459/Ahd/2025 Lakhtarwala Jewellers Prívate Limited - 18 – under Section 148 of the Act but would also extend to any other income which may be found to be exigible to tax.

"8. Learned counsel for the assessee submitted that the Assessing Officer had reopened the assessment by issuing notice under section 148 of the Act on the ground that the income from salary, perquisites and unexplained cash deposits in various accounts along with interest thereon had escaped assessment. The counsel urged that the Assessing Officer, however, while passing the reassessment order had sought to make addition of another amount without any addition having been made on the ground on the basis

ITA No.2459/Ahd/2025 Lakhtarwala Jewellers Prívate Limited - 19 – of which reassessment had been initiated. According to the learned counsel, no reassessment order could be passed by the Assessing Officer. Learned counsel for the assessee relied upon the following observations made by this court in CIT v. Atlas Cycle Industries 46 Taxman 315/180 ITR 319 (Punjab & Haryana): 1

"...we are of the view that the Tribunal was right in cancelling the reassessment as both the grounds on which reassessment notice was issued were not found to exist, and the moment such is the position, the Income- tax Officer does not get the jurisdiction to make a reassessment."

ITA No.2459/Ahd/2025 Lakhtarwala Jewellers Prívate Limited - 20 – 15. Ld. DR was unable to draw our attention to any contrary decision on the proposition of law pointed out by the ld. Counsel for the assessee referring to the decision of the Hon’ble Delhi High Court in the case of Valmik Thapar (Supra). 16. Considering the above, since we have deleted the addition made on account of unaccounted purchases, issue raised by the assessee in ground Nos.2 to 4 above at para 11 of order and admittedly, this was the solitary issue for which the case of the assessee was reopened, since the reasons for reopening do not survive, the assessee succeeds in its contention, that no addition on account of any other issue is sustainable in the case of the assessee, as held by the Hon’ble Delhi High Court in the case of Valmik Thapar (Supra). 17. In view of the above, ground of appeal Nos. 5 and 6 are allowed. 18. In effect, the appeal of the assessee is allowed. Order is pronounced under provision of Rule 34 of ITAT Rules, 1963 on 22.07.2026

Sd/- sd/- (SANJAY GARG) (ANNAPURNA GUPTA) JUDICIAL MEMBER ACCOUNTANT MEMBER Ahmedabad; Dated /07/2026 Mittali आदेश क� ��त�ल�प अ�े�षत/Copy of the Order forwarded to : 1. अपीलाथ� / The Appellant ��यथ� / The Respondent. 2. संबं�धत आयकर आयु�त / Concerned CIT 3. आयकर आयु�त(अपील) / The CIT(A)- 4. 5. �वभागीय ��त�न�ध, आयकर अपील�य अ�धकरण, अहमदाबाद / DR, ITAT, Ahmedabad 6. गाड� फाईल / Guard file.

ITA No.2459/Ahd/2025 Lakhtarwala Jewellers Prívate Limited - 21 – आदेशानुसार/ BY ORDER,

उप/सहायक पंजीकार (Dy./Asstt. Registrar) आयकर अपील�य अ�धकरण, अहमदाबाद / ITAT, Ahmedabad