How many judgments cite CIT v. Simit P. Sheth?

1,465 judgments on BharatTax cite CIT v. Simit P. Sheth (356 ITR 451), spanning 2016 to 2026.

Which sections of the Income Tax Act does CIT v. Simit P. Sheth come up under?

It is most often cited in judgments turning on Section 143(3), Section 147, Section 148, Section 132, Section 131, Section 69C.

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 366,470 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 147 Section 148 Section 132 Section 131 Section 69C Section 133(6)Section 143(2)

Issues it is cited on

section 69c section 131 section 133(6)reassessment proceedings undisclosed income search and seizure section 69 section 132 section 13 section 148 business section 147

Judgments citing CIT v. Simit P. Sheth

ACIT, CC-30, New Delhi vs. Winner Constructions Private Limited, Delhi

ITA 631/DEL/2025[2018-19]Status: DisposedITAT Delhi12 Aug 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 153A

…it is evident that Judicial precedents have consistently held that when purchases are suspected to be bogus but linked to business activities, only the profit element embedded in the transactions should be taxed. In the case of CIT vs. Simit P. Sheth (2013) (356 ITR 451 (Guj)), Held that only the profit element in suspected bogus purchases should be added to income, with a GP addition of 12.5%. Further, in the case of CIT vs. Nikunj Eximp Enterprises Pvt. Ltd. (2015) [372 ITR 619 (Bom)], stated that when sales are not questioned, disallowing the entire purchase amount is inappropriate, and taxing a reasonable GP…

ACIT, CC-30, New Delhi vs. Winner Constructions Private Limited, New Delhi

ITA 624/DEL/2025[2020-21]Status: DisposedITAT Delhi12 Aug 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 153A

Santosh Laujari Gupta, Mumbai vs. Assessing Officer - 33(3)(3), Kautilya Bhavan

In the result, the appeal of the assessee is partly allowed

ITA 2971/MUM/2025[2011-2012]Status: DisposedITAT Mumbai30 Jul 2025AY 2011-2012

Bench: Shri Pawan Singh(Physical Hearing) Santosh Laujari Gupta Ito, Ward-33(3)(3), Mumbai A-801, Raj Heights, M G Road, Near Vs Vora Colony, Kandivali West, Mumbai-400067. [Pan No. Adupg8487C] Appellant / Assessee Respondent / Revenue

Section 143(1)Section 143(2)Section 143(3)Section 145(3)Section 147Section 148Section 234ASection 254(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH, MUMBAI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER (Physical hearing) Santosh Laujari Gupta ITO, Ward-33(3)(3), Mumbai A-801, Raj Heights, M G Road, Near Vs Vora Colony, Kandivali West, Mumbai-400067. [PAN No. ADUPG8487C] Appellant / Assessee Respondent / Revenue Assessee by Sh. Vimal Punmiya, CA Revenue by Smt. R.M. Brindha, Addl. JCIT/ Sr DR Date of hearing 30.06.2025 Date of pronouncement 30.07.2025 Order under section 254(1) of Income Tax Act PER PAWAN SINGH, JUDICIAL MEMBER; 1. This appeal by assessee is directed against the order of National Faceless App…

Assisstant Commissioner of Income Tax, Cir, 20(1), Mumbai vs. Anil Monshi Shah, Mumbai

In the result, ground of

ITA 2094/MUM/2025[2009-10]Status: DisposedITAT Mumbai24 Jul 2025AY 2009-10

Bench: Shri Pawan Singh& Shri Ms. Padmavathy S(Physical Hearing) Acit, Circle – 20(1), Mumbai Anil Monshi Shah 3Rd Floor, Piramal Chambers, Vs 103, Sukh Castle, Bhandarkar Road, Lalbaug, Parel, Matunga East, Mumbai – 400019. Mumbai – 400012. [Pan: Aacps9726P] Appellant / Revenue Respondent / Assessee

Section 148Section 254(1)

…ion carried out by investigation wing Mumbai 03.10.2013. 6. We find that the AO ultimately made addition @ 12.5% of the purchases from Nazar Impex Private Ltd. The AO while making addition followed the decision of Gujarat High Court in CIT vs Simit P. Sheth 356 ITR 451 and Bholanath Poly Fab Private Ltd. reported in 355 ITR 290. The AO restricted the addition to the extent of profit element on such disputed purchases. Before ld. CIT(A), the assessee again furnished complete set of documents to substantiate the purchases and further contended that the purchases shown from Nazar Impex cannot be doubted. The sa…

Rajesh Gokulchand Agrawal, Mumbai vs. Income Tax Officer, WD-41(3)(3), Mumbai

In the result, the grounds of appeal

ITA 2257/MUM/2025[2018-19]Status: DisposedITAT Mumbai23 Jul 2025AY 2018-19

Bench: Shri Pawan Singh & Shri Prabhash Shankar(Physical Hearing) Rajesh Gokulchand Agrawal Ito, Ward-41(3)(3), G.M. Enterprises, 24,Old Hanuman Vs Kautilyabhavan, Bandrakurla Lane, Kalbadevi Road, Complex, Bandra (East), Mumbai – 400002. Mumbai-400051. [Pan No. Aawpa9648Q] Appellant / Assessee Respondent / Revenue

Section 133(6)Section 145(3)Section 147Section 148Section 148ASection 151ASection 254(1)Section 69C

…ght. Notice issued to the seller parties under section 133(6) remained not complied. The ld. CIT(A) confirmed the action of assessing officer by referring decision of Supreme Court in N.K. Proteins (2017-TIOL-23- SC-IT) and Gujarat High Court Smit P. Sheth 356 ITR 461. Further, aggrieved the assessee has filed present appeal before Tribunal. 5. We have heard the submission of learned Authorised Representative (ld. AR) of the assessee and the learned Senior Departmental Representative (ld. Sr. DR) for the revenue. The ld. AR of the assessee submits that he has raised grounds against the validity of reopeni…

Ramjibhai Kesaraji Patel, Vadodara vs. The ITO, Ward-1(2)(2), Vadodara

In the result, the appeal of the Assessee is partly allowed

ITA 827/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad17 Jul 2025AY 2018-19

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

For Appellant: Shri Prashant Upadhyay, ARFor Respondent: Shri Kamal Deep Singh, Sr DR

Section 147Section 250Section 251Section 69C

…portion that may represent unexplained or unverifiable expenditure, is liable to be brought to tax, so as to prevent the leakage of revenue. In support of these submissions, the Ld. AR relied upon the following judgments: - i. CIT vs. Simit P. Sheth [(2013) 356 ITR 451 (Guj.)] – Only profit embedded in purchases is taxable; upheld Tribunal’s 12.5% estimation. ii. Pr. CIT vs. Surya Impex [(2023) 451 ITR 395 (Guj.)] – When AO himself applied 3%-5% on similar parties, Tribunal rightly restricted addition to 6%. Ramjibhai Kesaraji Patel Vs. ITO Asst. Year : 2018-19 - 4– iii. Pr. CIT vs. Jigisha Satishkumar Mehta […

Rudra Global Infra Products Ltd., Bhavnagar vs. The ACIT, Circle-1, Bhavnagar

In the result, the appeal of the assessee is partly allowed

ITA 2069/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad17 Jul 2025AY 2018-19

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Tushar Hemani, Sr. Advocate & ShriFor Respondent: Shri Alpesh Parmar, CIT DR

Section 115BSection 133(6)Section 147Section 148Section 234ASection 270ASection 69C

…d that addition should be restricted only to the profit element embedded in the value of disputed purchases. 10. In the case of Commissioner of Income-tax vs. Simit P. Sheth [2013] 38 taxmann.com 385 (Gujarat) / [2013] 219 Taxman 85 (Gujarat) (Mag.) / [2013] 356 ITR 451 (Gujarat), the assessee was engaged in business of trading in steel on wholesale basis. The Assessing Officer having found that some of Rudra Global Infra Products Ltd. vs. ACIT Asst.Year –2018-19 - 7– alleged suppliers of steel to assessee had not supplied steel to the assessee but the assessee had only provided sale bills. Accordingly, the Asse…

Income Tax Officer, Delhi vs. Akash Deep Sethi, Delhi

In the result, the appeal filed by the Revenue is dismissed and at the same time, the cross objections filed by the assessee are also dismissed

ITA 4973/DEL/2024[2021-22]Status: DisposedITAT Delhi16 Jul 2025AY 2021-22

Bench: Shri Challa Nagendra Prasad & Shri S. Rifaur Rahmanincome Tax Officer, Vs. Akash Deep Sethi, Delhi. B-236, Derawal Nagar, Model Town, Delhi – 110 009. (Pan : Abyps8933P) Co No.26/Del/2025 (In Ita No.4973/Del/2024) (Assessment Year: 2021-22) Akash Deep Sethi, Vs. Income Tax Officer, B-236, Derawal Nagar, Delhi. Model Town, Delhi – 110 009. (Pan : Abyps8933P) (Appellant) (Respondent) Assessee By : Shri Ved Jain, Advocate Shri Aman Garg, Ca Ms. Kirti, Ca Revenue By : Shri Ajay Kumar Arora, Sr. Dr Date Of Hearing : 27.05.2025 Date Of Order : 16.07.2025 O R D E R Per S.Rifaur Rahman: 1. This Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income-Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi

For Appellant: Shri Ved Jain, AdvocateFor Respondent: Shri Ajay Kumar Arora, Sr. DR

Section 133(6)Section 139Section 142(1)Section 143(2)Section 143(3)Section 44A

…d that in this case the AO himself did not make addition of entire bogus purchases but restricted himself to a percentage thereof. The Hon'ble Gujarat High Court followed its own decision in CIT v. Simit P. Sheth [2013] 38 taxmann.com 385/219 Taxman 85 {Mag.)/356 ITR 451, where purchases were not found to be bogus but were made from parties other than those mentioned in books of account, it was held that not entire purchase price but only profit element embedded in such purchases could be added to income of assessee. 5.13 Thus ground 2 to 8 of the appellant are rejected but his gross profit is worked out at 2.46%…

Madhav Desai, Mumbai vs. Assessing Officer, Piramal Chambers

In the result, the appeal of the assessee stands partly allowed

ITA 4871/MUM/2024[2011-2012]Status: DisposedITAT Mumbai27 May 2025AY 2011-2012

Bench: Hon’Ble Shri Sandeep Gosainmadhav Desai Vs. Ito, Ward – 28(2)(1) Ground Floor, Room No. 1 Piramal Chambers, 39/41, Prankuti Bldg Parel, Mumbai. 4Th Kumbharwada, Mumbai Pan/Gir No. Ajjpd5013E (Applicant) (Respondent)

Section 147Section 250Section 41(1)

…tion, it was found that the assessee had indulged in making bogus purchases amounting to Rs.26,94,526/- from four parties. Therefore, after providing opportunity of hearing to the assessee and relying upon the judgement in the case of CIT(A) Vs. Smith P Sheth 356 ITR 451, (Gujarat ) made additions @ 12.5% of the total purchases to the total income of the assessee. 3 Madhav Desai., Mumbai 7. Although Ld. CIT(A) sought remand report, but upheld the additions and the operative portion of the order of Ld.CIT(A) is reproduced here in below: In this case, the AO was seen having possession of information and evidenc…

Income Tax Officer, Noida vs. Clean Crop India Private Limited, Noida

Appeal is dismissed

ITA 3236/DEL/2024[2022-23]Status: DisposedITAT Delhi21 May 2025AY 2022-23

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2022-23 Income Tax Officer, Vs. Clean Crop India Pvt. Ltd., Noida Flat No. 211, Bha Millennium Towers, Plot B- 9/17, Sector-62, Noida, Gautam Buddha Nagar, Uttar Pradesh Pan: Aaicc0064D (Appellant) (Respondent)

Section 133(6)Section 143(3)

…entire quantity of stock was sold by the assessee and hence only the profit margin embedded in such purchases would be subjected to tax and not entire purchases. The Hon'ble Gujarat High Court in the case of Commissioner of Income Tax vs. Simit P. Seth (2013) 356 ITR 451 upheld the order of the Tribunal directing an addition to the extent of 12.5% of bogus purchases. 4.6.8 On perusal of trading and profit and loss account it is seen that the assessee has shown purchases of Rs.28,75,36,893/- and sale of Rs.29,12,54,297/-. In view of the above mentioned facts and considering the above said judgments, 12.50% of non…

Income Tax Officer 1911, Piramal vs. Badamidevi Tejraj Mutha, Mumbai

In the result the appeal filed by the revenue is dismissed

ITA 5432/MUM/2024[2010-11]Status: DisposedITAT Mumbai20 May 2025AY 2010-11

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Smt. Renu Jauhriito – 19(1)(1) Vs. Badamidevi 501, 5Th Floor, Piramal Tejrajmutha Chambers, Lalbaug 67, Dr.Mg. Mohimtura Mumbai – 400012. Marg, 3Rd Kumbharwadalane, Mumbai – 400004. Pan/Gir No. Akipk1935E (Applicant) (Respondent)

Section 133(6)Section 250

…the additions under the identical circumstances @ 12.5% of the purchases made by the assessee from non genuine / tainted parties to rope in element of diluted income while relying upon the decision of Hon’ble Supreme Court in the case of Smt. P. Sheth [2013] 356 ITR 451. 10. Now, when once the department itself has restricted the additions @ 12.5% of the bogus purchase while passing the order of assessment for the same year u/s 143(3) r.w.s 9 Badamidevi Tejraj Mutha, Mumbai 147 of the Act therefore department cannot be allowed to approbate and reprobate in the same breath. Apart from the above, the Coordinate…

Astt. Commissioner of Income Tax, Circle-4, Ludhiana, Aayakar Bhawan vs. Waryam Steel Casting Private Limited, Kanganwal Road

In the result, appeal of the assessee is allowed and the Cross appeal of the Revenue is dismissed

ITA 757/CHANDI/2024[2019-20]Status: DisposedITAT Chandigarh14 May 2025AY 2019-20

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Ashwani Kumar, C.A and Ms. Muskan Garg, C.AFor Respondent: Shri Ved Parkash Kalia, Sr. DR

Section 115JSection 148Section 250

…आयकर अपीलीय अिधकरण,च"ीगढ़ "ायपीठ “बी” , च"ीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL, CHANDIGARH BENCH “B”, CHANDIGARH HEARING THROUGH: PHYSICAL MODE "ी राजपाल यादव, उपा"" एवं "ी कृणव" सहाय, लेखा सद" BEFORE: SHRI. RAJPAL YADAV, VP &SHRI. KRINWANT SAHAY, AM आयकरअपीलसं./ ITA No. 715 /Chd/ 2024 िनधा"रणवष" / Assessment Year : 2019-20 M/s Waryam Steel Castings Private बनाम The DCIT Limited, Circle-4, Ludhiana Kanganwal Road, Jugiana, Ludhiana, Punjab-141010 "ायीलेखासं./PAN NO: AAACW1494P अपीलाथ"/Appellant ""थ"/Respondent आयकरअपीलसं./ ITA No. 757/Chd/ 2024 िनधा"रणवष" / Assessment Year : 2019-20 The ACIT बनाम M/s Waryam S…

Waryam Steel Castings Private Limited, Ludhiana vs. Deputy Commissioner of Income Tax, Circle-4, Ludhiana

In the result, appeal of the assessee is allowed and the Cross appeal of the Revenue is dismissed

ITA 715/CHANDI/2024[2019-20]Status: DisposedITAT Chandigarh14 May 2025AY 2019-20

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Ashwani Kumar, C.A and Ms. Muskan Garg, C.AFor Respondent: Shri Ved Parkash Kalia, Sr. DR

Section 115JSection 148Section 250

DCIT-C-6(2), Mumbai vs. Samira Habitats India Limited, Mumbai

In the result, the cross-objection by the assessee for the assessment year 2012-13 is dismissed

ITA 5714/MUM/2024[2012-13]Status: DisposedITAT Mumbai09 May 2025AY 2012-13

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhailita No.5714/Mum/2024 Assessment Year : 2011-12 Assessment Year : 2012-13 Assessment Year : 2009-10

For Appellant: Shri Rakesh JoshiFor Respondent: Dr. Kishor Dhule, CIT-DR

Section 132(4)Section 250

…her appeal, the learned CIT(A) estimated 12.5% of the bogus purchases as an addition to be made instead of confirming the entire bogus purchases, placing reliance upon the decision of the Hon’ble Gujarat High Court in CIT v/s Simit P Sheth, reported in [2013] 356 ITR 451 (Guj.). The Tribunal, in further appeal, by placing reliance upon the decision of the Hon’ble Jurisdictional High Court in Mohd. Haji Adam, reported in [2019] 103 Taxmann.com 459 (Bom.), dismissed the appeal filed by the Revenue and directed the AO to restrict the addition to the extent of bringing the gross profit rate of disputed purchases to t…

DCIT Circle-3(2)(1), Mumbai vs. Sunjewels Private Limited, Andheri East, Mumbai

In the result, the appeal filed by the assessee and revenue are partly allowed for statistical purpose

ITA 5244/MUM/2024[2014-15]Status: DisposedITAT Mumbai09 May 2025AY 2014-15

Bench: Shri. Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm Sunjewels Private Limited Dy. Commissioner Of Income Tax 116, Sdf-Iv, Seepz, Andheri East, – 3(2)(1), Mumbai Room No. 608, 6Th Floor, Aaykar Mumbai – 400096. Vs. Bhavan, M. K. Road, New Marine Lines, Mumbai – 400020. Pan/Gir No. Aabce3519L (Appellant) : (Respondent) Dy. Commissioner Of Income Tax – Sunjewels Private Limited 3(2)(1), Mumbai 116, Sdf-Iv, Seepz, Andheri East, Room No. 608, 6Th Floor, Aaykar Mumbai – 400096. Vs. Bhavan, M. K. Road, New Marine Lines, Mumbai – 400020. Pan/Gir No. Aabce3519L (Appellant) : (Respondent)

For Appellant: Shri. Ravikanth PathakFor Respondent: Shri. Prashant Barote, Sr. DR

Section 115JSection 143(2)Section 143(3)Section 250Section 72ASection 72A(2)(b)Section 80G

…IN THE INCOME TAX APPELLATE TRIBUNAL “F” BENCH, MUMBAI BEFORE SHRI. OM PRAKASH KANT, AM AND MS. KAVITHA RAJAGOPAL, JM Sunjewels Private Limited Dy. Commissioner of Income Tax 116, SDF-IV, SEEPZ, Andheri East, – 3(2)(1), Mumbai Room No. 608, 6th Floor, Aaykar Mumbai – 400096. Vs. Bhavan, M. K. Road, New Marine Lines, Mumbai – 400020. PAN/GIR No. AABCE3519L (Appellant) : (Respondent) Dy. Commissioner of Income Tax – Sunjewels Private Limited 3(2)(1), Mumbai 116, SDF-IV, SEEPZ, Andheri East, Room No. 608, 6th Floor, Aaykar Mumbai – 400096. Vs. Bhavan, M. K. Road, New Marine Lines, Mumbai – 400020. PAN/GIR No. AABCE3…

Sunjewels Private Limited, Mumbai vs. Dy. Commissioner of Income Tax - 3(2)(1), Mumbai

In the result, the appeal filed by the assessee and revenue are partly allowed for statistical purpose

ITA 4720/MUM/2024[2014-15]Status: DisposedITAT Mumbai09 May 2025AY 2014-15

For Appellant: Shri. Ravikanth PathakFor Respondent: Shri. Prashant Barote, Sr. DR

Section 115JSection 143(2)Section 143(3)Section 250Section 72ASection 72A(2)(b)Section 80G

Quality Heightcon Private Limited, Mumbai vs. Dy. Commissioner of Income Tax, Circle -14(1)(2), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 1489/MUM/2025[2010-2011]Status: DisposedITAT Mumbai07 May 2025AY 2010-2011

Bench: Shri Saktijit Dey, Hon'Ble & Shri Narendra Kumar Billaiya, Hon'Ble

For Appellant: Shri Gyaneshwar Kataram, A/RFor Respondent: Shri Ashok Kumar Ambastha, Sr. D/R

Section 143(1)Section 148Section 154

…d held that "8. The ITAT in is impugned order had relied upon the judgments of Gujarat High Court in the case of Vijay Proteins Ltd. v. CIT [2015] 58 taxmann.com 44 and also in the case of CIT v. Smith P. Sheth [2023]. 38 taxmann.com 385/2019 Taxman 85 (Mag.)/356 ITR 451 and held that no uniform yardstick can be applied the estimating gross profit on bogus purchases which is depending upon the facts of different cases. The ITAT held that the Co-ordinate Beach in number of cases has taken a consistent view and directed AO to estimate gross profit of 12.5% on alleged bogus purchases and therefore, in the case at ha…

Pushpa Saluja vs. ITO Ward 45(4) New Delhi

ITA/281/2024HC Delhi15 Apr 2025

Bench: HON'BLE MR. JUSTICE VIBHU BAKHRU,HON'BLE MR. JUSTICE TEJAS KARIA

Section 131Section 142(1)Section 143(2)Section 260ASection 68

…ing from the said purchases but it was impermissible to make addition of the entire expenditure on account of purchases. The Assessee also relied on the decision of the Gujarat High Court in the case of Commissioner of Income Tax v. Simit P. Sheth: (2013) 356 ITR 451. 8. Additionally, the Assessee also relied on the decision of the Bombay High Court in CIT v. Nikunj Eximp Enterprises Pvt. Ltd.: (2015) 372 ITR 619 (Bom) in support of her contention that an addition could not be made merely because the supplier had not appeared before the AO. 9. The learned counsel appearing for the Assessee contende…

Income Tax Officer 1(2), Raipur, Income Tax Department vs. Mukesh Kedia, H.No. Sixty Four

In the result, cross objection filed by the assessee is allowed and the revenue’s appeal is dismissed

ITA 400/RPR/2024[2012-13]Status: DisposedITAT Raipur19 Mar 2025AY 2012-13

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.400/Rpr/2024 Co No.15/Rpr/2024 "नधा"रण वष" /Assessment Year : 2012-13 The Income Tax Officer-1(2), Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. Mukesh Kedia, House No.64, Gulmohar Park, Laxman Nagar, Raipur (C.G.) Pan : Apzpk0464Q ……""यथ" / Respondent

For Appellant: Shri Sunil Kumar Agrawal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 124(1)Section 127Section 127(1)Section 147Section 148Section 2Section 69C

…reating the same as unexplained expenditure. 4. The Ld. Sr. DR also submitted that on appeal before the first appellate authority, the Ld.CIT(Appeals)/NFAC had relied on the judgments of the Hon’ble High Court of Gujrat in the case of CIT Vs. Simit P. Sheth, 356 ITR 451 (Guj) and that of the Hon’ble High Court of Bombay in the case of Pr. CIT Vs. JK Surface Coatings (P) Ltd. order dated 28.10.2021 wherein it was held that only profit element embedded in 4 ITO-1(2), Raipur Vs. Mukesh Kedia CO No.15/RPR/2024 alleged bogus purchases has to be brought within ambit of taxation and sustained addition of Rs.77,593/- a…

DCIT 3(2)(1), Mumbai vs. Sunjewels Pvt. Ltd, Mumbai

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

ITA 5027/MUM/2024[2017]Status: DisposedITAT Mumbai28 Feb 2025

Bench: Shri Narender Kumar Choudhry, Jm & Smt Renu Jauhri, Am आयकर अपील सं./Ita No.4062/Mum/2024 (िनधा"रण वष" / Assessment Year :2017-18)

For Appellant: Shri Ravikant PathakFor Respondent: Shri Swapnil Sawant, Sr. DR

Section 142(1)Section 143(3)Section 250

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI “G” BENCH, MUMBAI BEFORE SHRI NARENDER KUMAR CHOUDHRY, JM AND SMT RENU JAUHRI, AM आयकर अपील सं./ITA No.4062/MUM/2024 (िनधा"रण वष" / Assessment Year :2017-18) Sunjewels Pvt. Ltd. Vs. 11(2)(2), Mumbai Room No 421, 4th Floor, 116, SDF-IV, SEEPZ, Andheri (E), Mumbai, Aayakar Bhavan, Maharishi Maharashtra-400096 Karve Road, Mumbai, Maharashtra-400020 "थायी लेखा सं./PAN No. : AABCE3519L (अपीलाथ" /Appellant) (""थ" / Respondent) .. आयकर अपील सं./ITA No.5027/MUM/2024 (िनधा"रण वष" / Assessment Year :2017-18) DCIT 3(2)(1) Vs. Sunjewels Pvt. Ltd. Room No. 608, 6th Floor, 116,…