CIT v. Metachem Industries

245 ITR 160High Court2000#741 most cited

What is CIT v. Metachem Industries authority for?

An assessee introducing cash credit or capital is not required to prove the ultimate source of funds of the creditor or investor once the identity, creditworthiness, and genuineness of the transaction with the immediate creditor/investor are established. The assessee's burden is discharged upon providing a satisfactory explanation and producing the person who deposited the amount.

137

judgments rely on this decision, according to BharatTax’s citation analysis of 366,418 Indian tax judgments — from 2016 to 2026.

Also referred to as

CIT v. Metachem Industries · 245 ITR 160 · Section 68 · onus of proof cash credit · source of source · capital introduction · genuineness of transaction · creditworthiness of creditor

Also reported as

116 Taxmann 572

Sections most often in play

Section 68Section 143(3)Section 250Section 145(3)Section 147Section 133(6)Section 144Section 148

Issues it is cited on

onus of proofsource of sourcebogus share capitaladdition under section 68creditworthiness of the creditorshare application moneyaddition u/s 68section 269sssection 269genuineness of the transactionrejection of books of accountloose papers

Judgments citing CIT v. Metachem Industries

Deputy Commissioner of Income Tax, Central Circel-1(2, Nagpur vs. M/S. Vibrant Global Capital Ltd., Mumbai

In the result, appeal filed by the Revenue is dismissed

ITA 229/NAG/2022[2014-15]Status: DisposedITAT Nagpur25 Oct 2024AY 2014-15

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Kishore P. DewaniFor Respondent: Shri Sandipkumar Salunke
Section 143(3)Section 14ASection 68

…IN THE INCOME TAX APPELLATE TRIBUNAL NAGPUR BENCH, NAGPUR BEFORE SHRI V. DURGA RAO, JUDICIAL MEMBER AND SHRI K.M. ROY, ACCOUNTANT, MEMBER ITA no.229/Nag./2022 (Assessment Year : 2014–15) Dy. Commissioner of Income Tax ……………. Appellant Central Circle–1(2), Nagpur v/s M/s. Vibrant Global Capital Ltd. Unit no.202, Tower–A ……………. Respondent Peninsula Business Park Senapati Bapat Marg, Lower Parel Mumbai 400 013 PAN – aaacv5656j Assessee by : Shri Kishore P. Dewani Revenue by : Shri Sandipkumar Salunke Date of Hearing – 24/10/2024 Date of Order – 25/10/2024 O R D E R PER K.M. ROY, A.M. This appeal has been filed…

Dalas Biotech Limited, Bhiwadi vs. The Assistant Commissioner of Income-Tax, Alwar

In the result, the appeal of the assessee is allowed with no orders as to cost

ITA 147/JPR/2024[2010-11]Status: DisposedITAT Jaipur30 Sept 2024AY 2010-11

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Rohit Tiwari, Adv (Physical)For Respondent: Shri Anup Singh, Addl. CIT-DR
Section 131Section 143(3)Section 40Section 68

…of law arises appeal of the department dismissed." Apart from the above mentioned judgments of Hon'ble Jurisdictional High Court of Gujarat, Ahmedabad, the appellant's case has been found covered by the following judgments: - i. CIT v/s. Meta Chem Industries 245 ITR 160 (MP) ii. Nemichand Kolhani v/s CIT 264 ITR 254 (Gauhati) iii. iSona Electric Co. v/s. CIT 152 ITR 507 (Delhi) iv. Tam Tam Pedda Guruna Reddy v/s. JCIT 291 ITR 44 (Kar.) In the case of M/s. Capaxo Logistics Pvt Ltd. ‘’14. We have heard the rival contentions of both the parties and perused the materials available on record. Admittedly the assessee…

DCIT, Circle-2, Pune vs. Vastushodh Realty, Pune

Appeal is dismissed in above terms

ITA 254/PUN/2024[2018-19]Status: DisposedITAT Pune12 Sept 2024AY 2018-19

Bench: Shri R.K. Panda & Shri S.S. Godaraआयकर अपील आयकर अपील संसंसंसं. / Ita No.254/Pun/2024 आयकर आयकर अपील अपील िनधा"रण वष" / Assessment Year: 2018-19

For Appellant: NoneFor Respondent: Shri Arvind Desai
Section 250Section 68

…ed 15.02.2023 3. Keshwarwani Sheetalaya v. CIT [(2020) 315 CTR 815 (All)] 4. PCIT v. Vaishnodevi Refoils & Solvex [(2018) 253 Taxman 135 (Guj)] 5. Prayag Tendu Leaves Processing Co. v. CIT [(2018) 400 ITR 120 (Jharkhand)] 6. CIT v. Metachem Industries [(2000) 245 ITR 160 (MP)] 4. We thus conclude that although the assessee has not come in appeal against the CIT(A)/NFAC’s findings partly upholding the impugned addition; the Revenue’s instant sole substantive ground deserves to be rejected with a rider that such an addition has to be made only in the concerned partner’s hands than that of a partnership-firm. O…

DCIT, Circle-43(1), Civic Centre vs. Hart Travels and Real Estate Solutions LLP, Delhi

In the result, the appeal of the Revenue in ITA No

ITA 3543/DEL/2023[2018-19]Status: DisposedITAT Delhi11 Sept 2024AY 2018-19

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri S.K. Gupta, CAFor Respondent: Shri Choudhary, N.C. Roy, JCIT
Section 115BSection 143(2)Section 271A

…the hands of the partner, he should have considered it in his individual hands and not in the hands of the firm. 13. We also find that this view is supported by the decision of the Hon'ble Madhya Pradesh High Court in the case of CIT Vs. Metachem Industries 245 ITR 160. We notice that the Tribunal while coming to the conclusion in the case of Ambika Enterprises [supra], has cited the decisions relied upon by the ld. counsel for the assessee as above. 14. In that view of the matter, we find no infirmity in the order of the ld. CIT(A). Accordingly, we dismiss the appeal of Revenue. 15. In the result, the appeal…

Ebro India Pvt.Ltd., Delhi vs. ACIT Circle-7(1), Delhi

In the result, the ground no 4 raised by the assessee is allowed

ITA 1291/DEL/2022[2018-19]Status: HeardITAT Delhi09 Sept 2024AY 2018-19

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Accountant Member)

For Appellant: Shri Rohit Jain, AdvocateFor Respondent: Shri Rajesh Kumar, CIT DR
Section 143(3)Section 144BSection 144CSection 68

…ng Co. Limited: 49 ITR 723 (Bom.)  CIT v. Gagandeep Infrastructure (P.) Ltd. – [2017] 80 taxmann.com 272 (Bombay)  CIT v. Vacmet Packaging India (P) Ltd.: 367 ITR 217 (All.)  CIT v. Arunanada Textiles P. Ltd: 333 ITR 116 (Kar)  CIT v. Metachem Industries: 245 ITR 160 (MP)  DCIT v. Rohini Builders: 256 ITR 360 (Guj)  CIT v. Shree Rama Multi Tech Ltd.: 215 Taxman 157 (Guj.)(Mag.)  Nemichand Kothari V. CIT: 264 ITR 254 (Gauhati)  CIT v. Talbros Engineering Ltd.: 386 ITR 454 (P&H)  CIT v. Pranav Foundations Ltd.: T. C. (A.) NO. 262 OF 2014 (Mad.) 66. The ratio decidendi emanating from the aforesaid decisions…

Assistant Commissioner of Income Tax, Central Circle-1(1), Nagpur vs. M/S. Radha Radhav Developer, Nagpur

In the result, all the six appeals preferred by the department are dismissed

ITA 49/NAG/2021[2013-14]Status: DisposedITAT Nagpur29 Jul 2024AY 2013-14

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

Section 142ASection 145

…cumstances by itself would not lead to the conclusion that the amount belonged to the assessee. In the absence of any other evidence to the contrary, disbelieving the evidence as such would not be proper. 8.13 In the case of CIT Vs. Metachem Industries (2000) 245 ITR 160 (MP) the Hon'ble HC has held as under: "Once it is established that the amount has been invested by a particular person, be he a partner or an individual, then the responsibility of the assessee-firm is over. The assessee- firm cannot ask that person who makes investment whether the money invested is properly taxed or not. The assessee is only to…

Assistant Commissioner of Income Tax, Central Circle-1(1), Nagpur vs. M/S. Radha Madhav Developer, Nagpur

In the result, all the six appeals preferred by the department are dismissed

ITA 48/NAG/2021[2012-13]Status: DisposedITAT Nagpur29 Jul 2024AY 2012-13

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

Section 142ASection 145

…cumstances by itself would not lead to the conclusion that the amount belonged to the assessee. In the absence of any other evidence to the contrary, disbelieving the evidence as such would not be proper. 8.13 In the case of CIT Vs. Metachem Industries (2000) 245 ITR 160 (MP) the Hon'ble HC has held as under: "Once it is established that the amount has been invested by a particular person, be he a partner or an individual, then the responsibility of the assessee-firm is over. The assessee- firm cannot ask that person who makes investment whether the money invested is properly taxed or not. The assessee is only to…

Assistant Commissioner of Income Tax, Central Circle-1(1), Nagpur vs. M/S. Radha Madhav Developer, Nagpur

In the result, all the six appeals preferred by the department are dismissed

ITA 47/NAG/2021[2011-12]Status: DisposedITAT Nagpur29 Jul 2024AY 2011-12

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

Section 142ASection 145

…cumstances by itself would not lead to the conclusion that the amount belonged to the assessee. In the absence of any other evidence to the contrary, disbelieving the evidence as such would not be proper. 8.13 In the case of CIT Vs. Metachem Industries (2000) 245 ITR 160 (MP) the Hon'ble HC has held as under: "Once it is established that the amount has been invested by a particular person, be he a partner or an individual, then the responsibility of the assessee-firm is over. The assessee- firm cannot ask that person who makes investment whether the money invested is properly taxed or not. The assessee is only to…

Assistant Commissioner of Income Tax, Central Circle-1(1), Nagpur vs. M/S. Suflam Infra Project Ltd, Nagpur

In the result, the departmental appeal is dismissed

ITA 46/NAG/2021[2014-15]Status: DisposedITAT Nagpur29 Jul 2024AY 2014-15

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Kapil Hirani, Adv &For Respondent: Shri Kailash C. Kanojiya, CTI DR
Section 143(3)Section 263Section 68

…s circumstances by itself would not lead to the conclusion that the amount belonged to the assessee. In the absence of any other evidence to the contrary, disbelieving the evidence as such would not be proper. In the case of CIT Vs. Metachem Industries (2000) 245 ITR 160 (MP) the Hon'ble HC has held as under: "Once it is established that the amount has been invested by a particular person, be he a partner or an individual, then the responsibility of the assessee-firm is over. The assessee-firm cannot ask that person who makes investment whether the money invested is properly taxed or not. The assessee is only to…

Assistant Commissioner of Income Tax, Central Circle-1(1), Nagpur vs. M/S. Radha Madhav Developer, Nagpur

In the result, all the six appeals preferred by the department are dismissed

ITA 140/NAG/2021[2018-19]Status: DisposedITAT Nagpur29 Jul 2024AY 2018-19

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

Section 142ASection 145

…cumstances by itself would not lead to the conclusion that the amount belonged to the assessee. In the absence of any other evidence to the contrary, disbelieving the evidence as such would not be proper. 8.13 In the case of CIT Vs. Metachem Industries (2000) 245 ITR 160 (MP) the Hon'ble HC has held as under: "Once it is established that the amount has been invested by a particular person, be he a partner or an individual, then the responsibility of the assessee-firm is over. The assessee- firm cannot ask that person who makes investment whether the money invested is properly taxed or not. The assessee is only to…

Asstt.Commissioner of Income Tax Central Circle-1(1), Nagpur vs. M/S Radha Madhav Developer, Nagpur

In the result, all the six appeals preferred by the department are dismissed

ITA 27/NAG/2020[2015-16]Status: DisposedITAT Nagpur29 Jul 2024AY 2015-16

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

Section 142ASection 145

…cumstances by itself would not lead to the conclusion that the amount belonged to the assessee. In the absence of any other evidence to the contrary, disbelieving the evidence as such would not be proper. 8.13 In the case of CIT Vs. Metachem Industries (2000) 245 ITR 160 (MP) the Hon'ble HC has held as under: "Once it is established that the amount has been invested by a particular person, be he a partner or an individual, then the responsibility of the assessee-firm is over. The assessee- firm cannot ask that person who makes investment whether the money invested is properly taxed or not. The assessee is only to…

Asstt.Commissioner of Income Tax Central Circle-1(1), Nagpur vs. M/S Radha Madhav Developer, Nagpur

In the result, all the six appeals preferred by the department are dismissed

ITA 26/NAG/2020[2014-15]Status: DisposedITAT Nagpur29 Jul 2024AY 2014-15

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

Section 142ASection 145

…cumstances by itself would not lead to the conclusion that the amount belonged to the assessee. In the absence of any other evidence to the contrary, disbelieving the evidence as such would not be proper. 8.13 In the case of CIT Vs. Metachem Industries (2000) 245 ITR 160 (MP) the Hon'ble HC has held as under: "Once it is established that the amount has been invested by a particular person, be he a partner or an individual, then the responsibility of the assessee-firm is over. The assessee- firm cannot ask that person who makes investment whether the money invested is properly taxed or not. The assessee is only to…

Sufalam Infra Projects Ltd, Nagpur vs. Pr. CIT (Central ), Nagpur

In the result, the departmental appeal is dismissed

ITA 97/NAG/2019[2014-15]Status: DisposedITAT Nagpur29 Jul 2024AY 2014-15

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Kapil Hirani, Adv &For Respondent: Shri Kailash C. Kanojiya, CTI DR
Section 143(3)Section 263Section 68

…s circumstances by itself would not lead to the conclusion that the amount belonged to the assessee. In the absence of any other evidence to the contrary, disbelieving the evidence as such would not be proper. In the case of CIT Vs. Metachem Industries (2000) 245 ITR 160 (MP) the Hon'ble HC has held as under: "Once it is established that the amount has been invested by a particular person, be he a partner or an individual, then the responsibility of the assessee-firm is over. The assessee-firm cannot ask that person who makes investment whether the money invested is properly taxed or not. The assessee is only to…

M/S. Avinash Chalana & Co., Bhopal vs. PCIT-1, Bhopal

The appeal of the assessee is allowed

ITA 204/IND/2023[2018-19]Status: DisposedITAT Indore25 Jul 2024AY 2018-19

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 142(1)Section 143Section 143(3)Section 263

…saat sires ater, sek saris, sek IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI VIJAY PAL RAO, JUDICIAL MEMBER AND SHRI B.M. BIYANI, ACCOUNTANT MEMBER ITA No.204/Ind/2023 (Assessment Year: 2018-19) M/s. Avinash Chalana and Pr. CIT Company Bhopal G-2/119-A, Milestone 100 Complex, Trilanga Roa, Vs. Gulmohar Colony Bhopal (Appellant / Assessee) (Respondent/ Revenue) PAN: AALFA7929P Assessee by Shri Sumit Nema Sr. Adv. And Gagan Tiwari, Adv. Revenue by Shri Ram Kumar Yadav, CIT-DR Date of Hearing 16.05.2024 Date of Pronouncement | 25.07.2024 ORDER Per Vijay Pal Rao, JM : This appeal by ass…

Ensure Builders and Developers, Bengaluru vs. Income Tax Officer, Ward-1(2)(1), Bangalore

In the result, appeal of the assessee is allowed

ITA 1093/BANG/2024[2014-15]Status: DisposedITAT Bangalore18 Jul 2024AY 2014-15

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2014-15

For Appellant: Sri Atul Madhavan, A.RFor Respondent: Sri Subramanian S., D.R
Section 143(3)Section 144BSection 147

…d that the assessee had explained the fund flow and was not routing transactions between various companies. The assessee was the ultimate beneficiary of the funds introduced as share capital. 3.10 Madhya Pradesh High Court – CIT Vs. Metachem Industries (200) 245 ITR 160 (MP) It was held that, according to Section 68, the burden was on the assessee to satisfactorily explain the credit entry in the books of account in the previous year and in a case where satisfactory explanation had been given by establishing that the amount had been invested by a particular person, be he a partner or any individual, then the bur…

Rewin Ceramics Pvt Ltd, New Delhi vs. ITO Ward - 21(3), New Delhi

In the result, the appeal filed by the assessee is partly allowed

ITA 4580/DEL/2019[2010-11]Status: DisposedITAT Delhi18 Jul 2024AY 2010-11

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI SUDHIR PAREEK (Judicial Member)

Section 133(6)Section 142(1)Section 143(1)Section 143(2)Section 148Section 68

…Commissioner of Income-tax (Patna HC) reported in 103 ITR 344. 3. CIT vs Diamond Prducts Ltd. (Delhi HC) reported in 177 Taxman.331. 4. CIT vs Dwarkadhish Investment P. Ltd. (Delhi HC) reported in 330 ITR 298. 5. CIT vs Matachem Industries (MP HC) reported in 245 ITR 160 6. CIT vs. Ram Narain Goel (P&H HC) reported in 224 ITR 180 7. DCIT vs Rohini Builders (Guj HC) reported in 256 ITR 360 PROPOSITION 7: Once the initial onus is discharged by the assessee, than the Revenue has to peruse the matter by enforcing the attendance of the creditor/lender and in absence of the same, addition under section 68 is unsustaina…

I.T.O. Ward -1, Amravati vs. Shri Sanjay Nanasaheb Bharsakale, Amravati

In the result, the appeal of the department is rejected

ITA 81/NAG/2018[2011-2012]Status: DisposedITAT Nagpur16 Jul 2024AY 2011-2012

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Manoj Moriyani, AdvocateFor Respondent: Shri Abhay Y.Marathe, Sr.Dr
Section 131Section 143(1)Section 143(3)Section 148Section 250Section 269TSection 44ASection 68

…IN THE INCOME TAX APPELLATE TRIBUNAL NAGPUR BENCH, NAGPUR BEFORE SHRI V. DURGA RAO, JUDICIAL MEMBER AND SHRI K.M. ROY, ACCOUNTANT, MEMBER ITA No. 81/Nag./2018 (Assessment Year : 2011-12) Income Tax Officer, ……………. Appellant Ward -1, Amravati v/s Shri Sanjay Nanasaheb Bharsakale 1, Shivaji Nagar, Banosa, ……………. Respondent Daryapur, Dist. Amravati. PAN – AHRPB8625J Assessee by : Shri Manoj Moriyani, Advocate Revenue by : Shri Abhay Y.Marathe, Sr.Dr. Date of Hearing – 09/07/2024 Date of Order – 16/07/2024 O R D E R PER K.M.ROY, A.M. The present appeal has been preferred by the department challenging the impugned…

The Income Tax Officer, Ward-3, Gandhinagar vs. Shri Ramesh Gobarji Thakor, Ahmedabad

In the result, the appeal of the Revenue is dismissed

ITA 59/AHD/2020[2010-11]Status: DisposedITAT Ahmedabad11 Jul 2024AY 2010-11

Bench: Smt.Annapurna Gupta & Ms. Suchitra Raghunath Kambleassessment Year : 2010-11 Income-Tax Officer Vs. Shri Ramesh Gobarji Thakor Ward-3 Sector 11 Gandhinagar. Gandhinagar. Pan : Aespt 3446 H (Applicant) (Responent) Assessee By : Shri S.N. Soparkar, Sr.Advocate & Shri Parin Shah, Ars. Revenue By : Shri Kamlesh Makwana, Cit-Dr सुनवाई क" तारीख/Date Of Hearing : 16/04/2024 घोषणा क" तारीख /Date Of Pronouncement: 11/07/2024 आदेश आदेश/O R D E R आदेश आदेश

For Appellant: Shri S.N. Soparkar, Sr.Advocate and Shri Parin Shah, ARsFor Respondent: Shri Kamlesh Makwana, CIT-DR
Section 147Section 250Section 68

…rises- appeal of the department dismissed. " d. Apart from the above mentioned judgments of Hon'ble Jurisdictional High Court of Gujarat, the appellant's case has been found to be covered by the following judgments as well:- i) CIT V/s. Meta Chem Industries 245 ITR 160(MP) ii) Nemichand Kolhani v/s CIT 264 ITR 254 (Gauhati) iii) Sona Electirc Co V/s CIT 152 ITR 507(Delhi) iv) Tarn Tarn Pedda Guruna Reddy V/s JCIT 291 ITR 44 (Kar.) Finding:- On appraisal of these fresh evidences along with the submissions made by the appellant including the copy of the appellate order of the ClT(A)-5, Ahmedabad passed in the c…

Ashwini Kumar Taneja, New Delhi vs. ITO Ward - 46(3), New Delhi

Appeal is allowed

ITA 7391/DEL/2019[2016-17]Status: DisposedITAT Delhi27 May 2024AY 2016-17

Bench: Sh. G.S.Pannu, Hon’Ble & Sh. Anubhav Sharmash. Ashwini Kumar Taneja Vs. Ito, Ward-46(3), 586, Gandhi Cloth Market New Delhi Chandni Chowk, Delhi-110006 C/O M/S Rra Taxindia, D-28, South Extension, Part-I, New Delhi-110049 Pan : Adbpt3461A (Appellant) (Respondent)

Section 143(1)Section 143(3)Section 68

…19 CTR 571 • Aravali Trading Co. vs. I.T.O. 220 CTR 622 (H.C. of Raj) • CIT vs. Shri Raj Kumar Agarwal: Income Tax Appeal no. 179 of 2008 dt. 17.11.2009 (Allahabad High Court). • Mangilal Agarwal (Late) vs. ACIT 300 ITR 372 (Raj) • CIT vs. Metachem Industries 245 ITR 160 (MP) 4.1 It was submitted that once assessee points out the depositor from whom he has received money and depositor earns the advancement of money the source of source cannot be explore for which reliance was placed on judgment: • Tolaram Daga vs. Commissioner of Income Tax 59 ITR 632 (Assam) • CIT vs. Shri Ram Narain Goel 224 ITR 180 (Pun. & Ha…

Aabhushan, Dhamnod, Madhya Pradesh vs. ITO Dhar, Dhar

In the result, appeal of the assessee is allowed

ITA 344/IND/2023[AY 2017-18]Status: DisposedITAT Indore09 May 2024

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniaabhushan Dhamnod Ito, Dhar 1St Floor, Ganpati Market Ab Road Dhamnod Vs. Mp (Appellant / Assessee) (Respondent/ Revenue) Pan: Abgfa0812K Assessee By Shri Pranay Goyal & Shri S.N. Goyal, Ars Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 10.04.2024 Date Of Pronouncement 09.05.2024 O R D E R

Section 115BSection 142(1)Section 143(2)Section 68

…आयकर अपील"य अ"धकरण, इंदौर "यायपीठ, इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI VIJAY PAL RAO, JUDICIAL MEMBER AND SHRI B.M. BIYANI, ACCOUNTANT MEMBER Aabhushan Dhamnod ITO, Dhar 1st Floor, Ganpati Market AB Road Dhamnod Vs. MP (Appellant / Assessee) (Respondent/ Revenue) PAN: ABGFA0812K Assessee by Shri Pranay Goyal & Shri S.N. Goyal, ARs Revenue by Shri Ashish Porwal, Sr. DR Date of Hearing 10.04.2024 Date of Pronouncement 09.05.2024 O R D E R Per Vijay Pal Rao, JM : This appeal by assessee is directed against the order dated 16.08.2023 of the Commissioner of Income Tax (Appeal)…