CIT v. Simit P. Sheth

356 ITR 451High Court2013#27 most cited

What is CIT v. Simit P. Sheth authority for?

Additions for alleged bogus purchases should be restricted to the profit element, not the entire turnover. The profit element is often estimated at 12.5% of the purported bogus purchases.

1,465

judgments rely on this decision, according to BharatTax’s citation analysis of 367,368 Indian tax judgments — from 2016 to 2026.

Also referred to as

CIT v. Simit P. Sheth · section 69C · bogus purchases · undisclosed income · addition on profit element · gross profit · net profit · reassessment · assessment procedure

Also reported as

38 Taxmann 385

Sections most often in play

Section 143(3)Section 147Section 148Section 132Section 131Section 69CSection 133(6)Section 143(2)

Issues it is cited on

section 69csection 131section 133(6)reassessment proceedingsundisclosed incomesearch and seizuresection 69section 132section 13section 148businesssection 147

Judgments citing CIT v. Simit P. Sheth

ITO, 19(3)(4), Mumbai vs. Sunita Ankush Kurale, Mumbai

In the result, appeal filed by the revenue is dismissed

ITA 529/MUM/2019[2009-10]Status: DisposedITAT Mumbai14 Feb 2020AY 2009-10

Bench: Shri Saktijit Dey & Shri G. Manjunathaबनाम बनाम/ बनाम बनाम Ito 19(3)(4) Smt. Sunita Ankush Matru Mandir, Room Kurale, Vs. No. 210, Tardeo Road, Sai, Flat No. 4A, 2Nd Floor, Mumbai. Building No. 26, Durgadevi Pin – 400 007. Street Opp Durgadevi Temple, Kumbhawada. Mumbai. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Anwpk6615J (अपीलाथ" /Appellant) (""यथ" / Respondent) .. अपीलाथ" ओर से / Appellant Shri Sourabh Deshpande, Dr By : ""यथ" क" ओर None से/Respondent By : सुनवाई क" तारीख / / / / Date Of 03/02/2020 Hearing घोषणा क" तारीख /Date Of 14 /02/2020 Pronouncement आदेश / O R D E R Per Shri G. Manjunatha- Am: This Appeal Filed By The Revenue Is Directed Against Order Of The Ld. Cit (A)-30, Mumbai, Dated 03/10/2018 & It Pertains To The A.Y 2009-10. 529/Mum/2019. Sunita Ankush Kurale. 2. The Revenue Has Raised The Following Grounds Of Appeal:

Section 133(6)Section 143(1)Section 143(3)Section 147

…, no additions could be made on the basis of information received from third party. The Ld.CIT(A), after considering relevant submission of the assessee and also, by following the decision of Hon’ble Gujarat High Court, in the case of CIT vs. Simith P. Sheth (356 ITR 451) has scaled down addition made by the AO towards alleged bogus purchases to 12.50% gross profit on total purchases from those parties. 5. None appeared for the assessee. We have heard the Ld. DR, perused the material available on record and gone through orders of the authorities below. We find that the Ld. AO has made 100% addition on alleged bo…

Chirag J. Mehta, Mumbai vs. ACIT Circle- 19 (2), Mumbai

In the result, appeal filed by the assessee for AY 2009-10 is partly allowed

ITA 6520/MUM/2018[2009-10]Status: DisposedITAT Mumbai14 Feb 2020AY 2009-10

Bench: Shri C.N.Prasad & Shri G. Manjunatha

Section 133ASection 143(3)Section 147Section 148

…ment of imagination and further, only the profit element embedded on such purchases needs to be taxed. This legal proposition is supported by plethora of judicial precedents, including the decision of Hon’ble Gujarat High Court, in the case of Simit P. Sheth (356 ITR 451), where the Hon’ble High Court categorically held that in cases of alleged bogus purchases, only profit element embedded in those purchases needs to be taxed, but not total purchases, because the findings of the authorities below was that the assessee has purchased goods from grey market and to cover-up such purchases has obtained accommodation b…

Rosana Tools, Mumbai vs. ITO 22(3)(2), Mumbai

In the result both the appeals of the assessee are dismissed

ITA 724/MUM/2019[2011-12]Status: DisposedITAT Mumbai13 Feb 2020AY 2011-12

Bench: Shri R.C.Sharma

Section 133(6)Section 143(3)Section 69C

…la dealers. In the present case, the ratio of Vijay Protein, a manufacturing concern cannot be applied since the appellant is a business concern doing trading. In my opinion, the ratio of the judgment of Hon'ble Gujarat High Court in the case of Simit P. Seth 356 ITR 461 (Guj.) is applicable to the facts and circumstances of the appellant's case. Here, the Hon’ble Court has held that disallowance of 12.5% of the purchases from such hawala dealers will be justified based on the premise that the appellant have derived benefit to this extent based on his nature of business. In view of the above the disallowance of R…

Rosona Tools, Mumbai vs. ITO 22(3)(2), Mumbai

In the result both the appeals of the assessee are dismissed

ITA 723/MUM/2019[2009-10]Status: DisposedITAT Mumbai13 Feb 2020AY 2009-10

Bench: Shri R.C.Sharma

Section 133(6)Section 143(3)Section 69C

…la dealers. In the present case, the ratio of Vijay Protein, a manufacturing concern cannot be applied since the appellant is a business concern doing trading. In my opinion, the ratio of the judgment of Hon'ble Gujarat High Court in the case of Simit P. Seth 356 ITR 461 (Guj.) is applicable to the facts and circumstances of the appellant's case. Here, the Hon’ble Court has held that disallowance of 12.5% of the purchases from such hawala dealers will be justified based on the premise that the appellant have derived benefit to this extent based on his nature of business. In view of the above the disallowance of R…

ITO 24(1)(3), Mumbai vs. Bijal Prashant Kalbag, Mumbai

In the result, appeals filed by the Revenue for both

ITA 805/MUM/2019[2010-11]Status: DisposedITAT Mumbai12 Feb 2020AY 2010-11

Bench: Shri Saktijit Dey & Shri G. Manjunatha

For Appellant: Shri Sourabh DeshpandeFor Respondent: None
Section 133(6)Section 143(1)Section 143(3)Section 147

…no additions could be made on the basis of information received from third party. The Ld. CIT(A), after considering relevant submission of the assessee and also, by following the decision of Hon’ble Gujarath High Court, in the case of CIT Vs. Simith P. Sheth (356 ITR 451) scaled down addition made by the AO towards alleged bogus purchases to 12.50% gross profit on total purchases from those parties. 5. None appeared for the assessee. We have heard the Ld. DR, perused the material available on record and gone through orders of the authorities below. We find that the Ld. AO has made 18% addition on alleged bogus p…

ITO 24(1)(3), Mumbai vs. Bijal Prashant Kalbag, Mumbai

In the result, appeals filed by the Revenue for both

ITA 804/MUM/2019[2009-10]Status: DisposedITAT Mumbai12 Feb 2020AY 2009-10

Bench: Shri Saktijit Dey & Shri G. Manjunatha

For Appellant: Shri Sourabh DeshpandeFor Respondent: None
Section 133(6)Section 143(1)Section 143(3)Section 147

…no additions could be made on the basis of information received from third party. The Ld. CIT(A), after considering relevant submission of the assessee and also, by following the decision of Hon’ble Gujarath High Court, in the case of CIT Vs. Simith P. Sheth (356 ITR 451) scaled down addition made by the AO towards alleged bogus purchases to 12.50% gross profit on total purchases from those parties. 5. None appeared for the assessee. We have heard the Ld. DR, perused the material available on record and gone through orders of the authorities below. We find that the Ld. AO has made 18% addition on alleged bogus p…

ITO Ward 6(3)(3), Mumbai vs. M/S Jepi Chemo-Pack Pvt. Ltd., Mumbai

In the result, appeal filed by the revenue is dismissed

ITA 454/MUM/2019[2012-13]Status: DisposedITAT Mumbai12 Feb 2020AY 2012-13

Bench: Shri Saktijit Dey & Shri G. Manjunathaito, Ward-6(3)(3) Vs. Jepi Chemo-Pack Pvt.Ltd. Room No.524, 5Th Floor 120, Blue Rose Industrial M.K.Road Estate, Western Express New Marine Lines Highway, Borivali (East) Mumbai-400 020 Mumbai-400 066

Section 143(1)Section 143(3)Section 147

…, no additions could be made on the basis of information received from third party. The Ld.CIT(A), after considering relevant submission of the assessee and also, by following the decision of Hon’ble Gujarat High Court, in the case of CIT vs. Simith P. Sheth (356 ITR 451) scaled down addition made by the AO towards alleged bogus purchases to 12.50% gross profit on total purchases from those parties. The relevant findings of the Ld.CIT(A) are as under:- 4.2 1 have considered the assessment order and the submissions of the appellant including the case laws cited. The AO held in the assessment order that the appell…

Bhawarlal Kesharimal Jain, Mumbai vs. ITO, Ward-18(3)(1), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 1071/MUM/2019[2010-11]Status: DisposedITAT Mumbai12 Feb 2020AY 2010-11

Bench: Sri C N Prasad, Jm & Sri Rajesh Kumar, Am आयकर अपील सुं./ Ita No. 1071/Mum/2019 (यनर्ाारण वर्ा / Assessment Year 2010-11) आयकर अपील सुं./ Ita No. 1072/Mum/2019 (यनर्ाारण वर्ा / Assessment Year 2011-12) Shri Bhawarlal Kesharimal Jain The Income Tax Officer Shop No.5, R.K. Wadi Building, Ward-18(3)(1) बनाम/ 2Nd Parsiwada Lane, V.P. Road, Mumbai-400 021 Vs. Mumbai-400 004 (अपीलार्थी / Appellant) (प्रत्यर्थी/ Respondent) स्र्थायी लेखा सुं./Pan No. Aatpj1678G अपीलार्थी की ओर से / Appellant By : Shri M.S. Mathuria, Ar प्रत्यर्थी की ओर से / Respondent By : Shri R. Bhoopathi, Dr सुनवाई की तारीख / Date Of Hearing: 12.02.2020 घोर्णा की तारीख / Date Of Pronouncement: 12.02.2020

For Appellant: Shri M.S. Mathuria, ARFor Respondent: Shri R. Bhoopathi, DR
Section 133(6)Section 143(3)Section 147

…income of the assessee. Aggrieved, assessee preferred the appeal before CIT(A), who confirmed the disallowance of the bogus purchases by observing in para 4.11 by following the decision of Hon’ble Gujarat High court in the case of CIT vs. Smith P. Seth (2013) 356 ITR 451 (Guj) as under: - “4.11. Even if materials have been purchased, they are not purchased form 4 | P a g e ITA No. 1071 & 1072/Mum/2019 Shri Bhawarlal Kesharimal Jain these parties and may be in cash from un- disclosed parties. By purchasing from the grey market, the appellant would have benefitted by the savings of taxes. It is noted from Tax Au…

Samarthmal Sanghvi, Mumbai vs. ITO 19(3)(2), Mumbai

In the result, appeal of the assessee is dismissed

ITA 6574/MUM/2018[2009-10]Status: DisposedITAT Mumbai11 Feb 2020AY 2009-10

Bench: Shri R.C.Sharma & Shri Vikas Awasthysamarthmal D.Sangvi, C/O. Fitwel Industries, 10, Tulsi Bldg., 178/180, Khetwadi, Back Road, Mumbai 400 004 Pan:Aafps 4195P ...... Appellant

For Appellant: Shri Gautam SalechaFor Respondent: Shri Kumar Padmapani Bora
Section 147

…ssment proceedings has held that the assessee has obtained bogus purchase bills to the extent of Rs.72,36,259/- from various parties. The Assessing Officer following the decision of Hon’ble Gujarat High Court in the case of CIT vs. Simit P. Sheth, reported as 356 ITR 451 made disallowance of Rs.12.5% of such bogus purchase i.e. Rs.9,04,532/-. We find that that the addition made by 3 authorities below is just and reasonable and hence, warrants no interference. The impugned order is upheld and the appeal of the assessee is dismissed. 6. In the result, appeal of the assessee is dismissed. Order pronounced in the…

ITO 19 (2)(3), Mumbai vs. Mafaram J. Choudhary, Mumbai

The appeal stands dismissed

ITA 5716/MUM/2018[2012-13]Status: DisposedITAT Mumbai11 Feb 2020AY 2012-13

Bench: Hon’Ble Shri Amarjit Singh, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: NoneFor Respondent: Ms. Jyoti Lakshmi Nayak-Ld.DR
Section 133(6)Section 143(3)Section 148

…rious judicial pronouncements, estimated the addition of 12.5% against these purchases. Reliance was placed on ITA No.5715-16/Mum/2018 Mafaram J. Choudhary Assessment Years:2009-10 & 2012-13 the decision of Hon’ble Gujarat High Court in CIT V/s Simit P.Sheth (356 ITR 451) while making such addition. Aggrieved, the revenue is under further appeal before us. 4. Upon due consideration, we are of the opinion that there could be no sale without actual purchase of material particularly when the assessee was into trading activities. The sales turnover has not been disputed / disturbed by the revenue. The assessee was in…

ITO 19 (2)(3), Mumbai vs. Mafaram J. Choudhary, Mumbai

The appeal stands dismissed

ITA 5715/MUM/2018[2009-10]Status: DisposedITAT Mumbai11 Feb 2020AY 2009-10

Bench: Hon’Ble Shri Amarjit Singh, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: NoneFor Respondent: Ms. Jyoti Lakshmi Nayak-Ld.DR
Section 133(6)Section 143(3)Section 148

…rious judicial pronouncements, estimated the addition of 12.5% against these purchases. Reliance was placed on ITA No.5715-16/Mum/2018 Mafaram J. Choudhary Assessment Years:2009-10 & 2012-13 the decision of Hon’ble Gujarat High Court in CIT V/s Simit P.Sheth (356 ITR 451) while making such addition. Aggrieved, the revenue is under further appeal before us. 4. Upon due consideration, we are of the opinion that there could be no sale without actual purchase of material particularly when the assessee was into trading activities. The sales turnover has not been disputed / disturbed by the revenue. The assessee was in…

Hicon Construction, Mumbai vs. DCIT, Central Circle-5(1), Mumbai

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

ITA 637/MUM/2019[2007-08]Status: DisposedITAT Mumbai10 Feb 2020AY 2007-08

Bench: Shri Saktijit Dey & Shri G. Manjunathahicon Constructions Vs. Dcit,Central Circle-5(1) B-201, Leo Apartment Air India Building 24Th Road 19Th Floor Khar(W) Nariman Point Mumbai-400 052 Mumbai-400 021

Section 132Section 143(3)Section 144Section 147Section 69C

…and held that in case purchases claims to have made from alleged hawala dealers, only profit element embedded in those purchases needs to be taxed, but not total purchase from those parties. The Hon’ble Gujarat High Court, in the case of CIT vs Simith P.Sheth 356 ITR 451 had considered a similar issue and held that at the time of estimation of profit from alleged bogus purchases no uniform yardsticks could be adopted, but it depends upon facts of each case. The ITAT, Mumbai, in number of cases had considered an identical issue and depending 7 Hicon Construction upon facts of each case, directed the Ld.AO to est…

ITO-26(2)(5), Mumbai vs. Shri Ramesh C Gala, Mumbai

In the result, appeal filed by the revenue is dismissed

ITA 474/MUM/2019[2011-12]Status: DisposedITAT Mumbai10 Feb 2020AY 2011-12

Bench: Shri Saktijit Dey & Shri G. Manjunathaito-26(2)(5) Vs. Ramesh C Gala Room No.506, 5Th Floor Room No.9, 2Nd Floor C-11, Bandra Kurla Complex Bldng No.14, Bmc Building Bandra(E) Sion-Koliwada Mumbai-400 051 Sakinaka Mumbai-400 072 Pan/Gir No.Amfpg1277J (Appellant) .. Respondent)

Section 143(1)Section 143(3)Section 147Section 40A

…, no additions could be made on the basis of information received from third party. The Ld.CIT(A), after considering relevant submission of the assessee and also, by following the decision of Hon’ble Gujarat High Court, in the case of CIT vs. Simith P. Sheth (356 ITR 451) scaled down addition made by the AO towards alleged bogus purchases to 20% gross profit on total purchases from those parties. The relevant findings of the Ld.CIT(A) are as under:- “From the above chart it is seen that the gross and net profit ratios, being 19.69% and 4.80% respectively declared in the return filed for the assessment year under…

ITO 26(2)(5), Mumbai vs. Smt. Reshma J Khan, Mumbai

In the result, appeal filed by the revenue is dismissed

ITA 473/MUM/2019[2011-12]Status: DisposedITAT Mumbai10 Feb 2020AY 2011-12

Bench: Shri Saktijit Dey & Shri G. Manjunathaito-26(2)(5) Vs. Smt. Reshma J Khan Room No.506, 5Th Floor A/9, Sharif Market, C-11, Bkc Laxmi Narayan Mandir Bandra (E) Road, Sakinaka Mumbai-400 051 Andheri(E) Mumbai-400 072

Section 143(1)Section 143(3)Section 147Section 40A(3)

…, no additions could be made on the basis of information received from third party. The Ld.CIT(A), after considering relevant submission of the assessee and also, by following the decision of Hon’ble Gujarat High Court, in the case of CIT vs. Simith P. Sheth (356 ITR 451) scaled down addition made by the AO towards alleged bogus purchases to 10% gross profit on total purchases from those parties. The relevant findings of the Ld.CIT(A) are as under:- 7.4.1 However, as the AO hag not doubted purchases are to be allowed since there cannot be production and sales thereof without purchase of the materials. The given…

Shri.Prithviraj S. Bhansali, Mumbai vs. ITO-19(2)(5), Mumbai

In the result, appeal filed by the assessee for AY 2009-10 is dismissed

ITA 469/MUM/2019[2009-10]Status: DisposedITAT Mumbai10 Feb 2020AY 2009-10

Bench: Shri Saktijit Dey & Shri G. Manjunatha

Section 143(1)Section 145(3)Section 147

…, no additions could be made on the basis of information received from third party. The Ld.CIT(A), after considering relevant submission of the assessee and also, by following the decision of Hon’ble Gujarat High Court, in the case of CIT vs. Simith P. Sheth (356 ITR 451), upheld addition made by the AO towards 12.50% profit on alleged bogus purchases from those parties. The relevant findings of the Ld.CIT(A) are as under:- 9.8 Having gone through the case laws cited in support of the appellant in his submissions, it is seen that in none of those cases so much of investigation was done including those by another…

ITO, 20(1)(1), Mumbai vs. Aliakbar Haiderali Mukhi, Mumbai

In the result, appeal filed by the revenue is dismissed

ITA 1113/MUM/2019[2010-11]Status: DisposedITAT Mumbai10 Feb 2020AY 2010-11

Bench: Shri Shamim Yahya(A.M.) & Shri Pawan Singh (Jm) Ito-20(1)(1), Mumbai Vs Shri Aliakbar Haiderali Mukhi 22, Akharwa Galli Opp Anjuman Islam College Maulana Azad Road Mumbai 400 008 Pan : Agkpm4793N Appellant Respondednt

Section 133(6)Section 143(1)Section 147Section 148Section 40A(3)

…suspicious parties as parties were not available at their given addresses. The assessee has not maintained stock register nor was any proof of transportation of goods furnished. The AO, on the basis of decision of Hon’ble Gujarat High Court in Simit P Sheth 356 ITR 451 (Guj) concluded that assessee failed to establish genuineness of transaction, but assessee has shown sales which cannot be ignored and these facts lead to conclusion that assessee purchased the material in the grey market and sources of funds used for purchases from grey market had not been explained. On the basis of these observations, the AO…

ITO-32(1)(5), Mumbai vs. Shri. Harish Kantilal Jain, Mumbai

In the result, appeal filed by the revenue is dismissed

ITA 471/MUM/2019[2009-10]Status: DisposedITAT Mumbai07 Feb 2020AY 2009-10

Bench: Shri Saktijit Dey & Shri G. Manjunathaito-32(1)(5) Vs. Harish Kantilal Jain Room No.203, 2Nd Floor 404, Bhakti Apartment C-11, Bandra Kurla Complex Opp. Jain Temple Bandra(E) Jambli Galli Mumbai-400 051 Borivali (West) Mumbai-400 092

Section 143(1)Section 143(3)Section 147Section 69C

…, no additions could be made on the basis of information received from third party. The Ld.CIT(A), after considering relevant submission of the assessee and also, by following the decision of Hon’ble Gujarat High Court, in the case of CIT vs. Simith P. Sheth (356 ITR 451) scaled down addition made by the AO towards alleged bogus purchases to 12.50% gross profit on total purchases from those parties. The relevant findings of the Ld.CIT(A) are as under:- 4.1 I have considered the assessment order and the submissions of the appellant. The AO he'd that the appellant produced the details with regard to purcha.ses mad…

Income Tax Officer 33(1), Mumbai vs. Shri Chetan Arvind Shah, Mumbai

In the result, appeal filed by the revenue is dismissed

ITA 6523/MUM/2018[2010-11]Status: DisposedITAT Mumbai07 Feb 2020AY 2010-11

Bench: Shri Saktijit Dey & Shri G. Manjunathaito-33(1)(3) Vs. Chetan Arvind Shah C-12, 7Th Floor B/305, Veena Sur Co-Op. Room No.707 Hsg. Society Pratyakshkar Bhawan Mahavir Nagar Bkc, Bandra(E) Kandivali (W) Mumbai-400 051 Mumbai-400 067

Section 143(3)Section 147

…, no additions could be made on the basis of information received from third party. The Ld.CIT(A), after considering relevant submission of the assessee and also, by following the decision of Hon’ble Gujarat High Court, in the case of CIT vs. Simith P. Sheth (356 ITR 451) scaled down addition made by the AO towards alleged bogus purchases to 12.50% gross profit on total purchases from those parties. The relevant findings of the Ld.CIT(A) are as under:- 5.1 I have considered the assessment order and the submission of the appellant including the case laws cited. The AO observed in the assessment order in para 7.1…

ITO-26(2)(2), Mumbai vs. Shri. Matiullah Karmullah Khan, Mumbai

In the result, appeal of the revenue is dismissed

ITA 762/MUM/2019[2011-12]Status: DisposedITAT Mumbai06 Feb 2020AY 2011-12

Bench: Shri R.C.Sharmai.T.O.-26(2)(2), Vs. Shri Matiullah Karmullah Building No. C-11, 7Th Khan, Floor, Room No. 704, M/S Shams Sales Pratyakshakar Bhavan, Corporation, Room No. 2, Bandra Kurla Complex, Quddus Compound, Opp. Bandra (East), Mumbai- M.K. Brothers, Andheri Kurla 400051. Road, Jarimari Mumbai- 400072. Pan/Gir No.Aagpk 7147 J (Appellant) .. (Respondent)

Section 143(3)

…s partly allowed.” 5. It is clear from the order of the ld. CIT(A) that after considering the facts and circumstances of the case and the judicial pronouncements laid down to this effect by the Hon’ble Gujarat High Court in the case of CIT Vs Simit P Seth 356 ITR 451 & M/s Bholanath Polyfab Pvt. Ltd. (2013) 355 ITR 290 he had given further relief of profit already declared by the assessee out of addition of 12.5% so made by the A.O. The detailed findings so recorded by the ld. CIT(A) has not been controverted by the ld DR by bringing any positive 4 ITO Vs Shri Matiullah Karmullah Khan material on record, t…

DCIT Cirlce-2, Thane vs. Shir Pahadsingh L Rajput, Thane

In the result, appeal filed by the Revenue stands dismissed and cross-objections filed by the assessee stands dismissed as withdrawn

ITA 368/MUM/2019[2010-11]Status: DisposedITAT Mumbai05 Feb 2020AY 2010-11

Bench: Shri Rajesh Kumar, Am & Shri Amarjit Singh, Jm

Section 133(6)Section 143(1)Section 147

…IN THE INCOME TAX APPELLATE TRIBUNAL “C”, BENCH MUMBAI BEFORE SHRI RAJESH KUMAR, AM & SHRI AMARJIT SINGH, JM ITA Nos.368 & 369/Mum/2019 (Assessment Year. 2010-11) DCIT, Circle-2 Vs. Shri Pahadsingh L. Rajput Room No.27, 6th Floor, B- D-8, Sujata Shoping Centre Wing, Wagle Industrial Navghar Road, Bhayander (E), Estate, Thane(W)-400604. Thane-401104. Cross Objection Nos.08 & 09/Mum/2020 (Arising out of ITA Nos.368 & 369/Mum/2019) (Assessment Year.2010-11) Shri Pahadsingh L. Rajput Vs. DCIT, Circle-2 Room No.27, 6th Floor, B- D-8, Sujata Shoping Centre Navghar Road, Bhayander (E), Wing, Wagle Industrial Thane-40110…