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 367,154 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

V.V. Ttitanium Pigments Pvt. Ltd., Tirunelveli vs. ACIT, CC-2, Madurai

Appeals stand dismissed

ITA 1301/CHNY/2024[2015-16]Status: DisposedITAT Chennai09 Oct 2024AY 2015-16

Bench: Hon’Ble Shri Mahavir Singh, Vp & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपील सं./ Ita No.1301/Chny/2024 (िनधा+रण वष+ / Assessment Year: 2015-16) & 2. आयकरअपील सं./ Ita No.1302/Chny/2024 (िनधा+रण वष+ / Assessment Year: 2016-17) & 3. आयकरअपील सं./ Ita No.1303/Chny/2024 (िनधा+रण वष+ / Assessment Year: 2017-18) & 4. आयकरअपील सं./ Ita No.1304/Chny/2024 (िनधा+रण वष+ / Assessment Year: 2018-19) & 5. आयकरअपील सं./ Ita No.1305/Chny/2024 (िनधा+रण वष+ / Assessment Year: 2019-20) M/S V.V. Titanium Pigments Pvt.Ltd Acit बनाम/ Mahadevankulam, Keeraikaranthattu Central Circle-2 Vs. Tisayanvillai, Tirunelveli-627 657. Madurai. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aadcv-7723-P (अपीलाथ"/Appellant) : (" थ" / Respondent) & 6. आयकरअपील सं./ Ita No.1316/Chny/2024 (िनधा+रण वष+ / Assessment Year: 2015-16) & 7. आयकरअपील सं./ Ita No.1312/Chny/2024 (िनधा+रण वष+ / Assessment Year: 2016-17) & 8. आयकरअपील सं./ Ita No.1313/Chny/2024

For Appellant: Shri R. Venkata Raman (CA) - Ld. ARFor Respondent: Shri Nilay Baram Som (CIT) -Ld. DR
Section 143(3)Section 153ASection 153DSection 37

…आयकर अपीलीय अिधकरण “ए” "ायपीठ चे"ई म"। IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, CHENNAI माननीय "ी महावीर िसंह, उपा ! एवं माननीय "ी मनोज कुमार अ%वाल ,लेखा सद( के सम!। BEFORE HON’BLE SHRI MAHAVIR SINGH, VP AND HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM 1. आयकरअपील सं./ ITA No.1301/Chny/2024 (िनधा+रण वष+ / Assessment Year: 2015-16) & 2. आयकरअपील सं./ ITA No.1302/Chny/2024 (िनधा+रण वष+ / Assessment Year: 2016-17) & 3. आयकरअपील सं./ ITA No.1303/Chny/2024 (िनधा+रण वष+ / Assessment Year: 2017-18) & 4. आयकरअपील सं./ ITA No.1304/Chny/2024 (िनधा+रण वष+ / Assessment Year: 2018-19) & 5. आयकरअपील सं./ ITA No.1305/Chny/2024…

Deputy Commissioner of Income Tax, Central Circle-4, Jaipur vs. Sunder Das Sonkiya, Jaipur

In the result, both appeals of the revenue are dismissed

ITA 454/JPR/2024[2013-14]Status: DisposedITAT Jaipur09 Oct 2024AY 2013-14

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. S. R. Sharma, CA &For Respondent: Sh. Anup Singh, Addl.CIT
Section 143(1)Section 143(2)Section 143(3)Section 148

…the inference can only be that it is an unproved purchase. In such a case, the approach of the Tribunal that a reasonable disallowance for possible inflation could be warranted, has to be upheld.” Recently the Gujrat High Court in Judgement reported at (2013) 356 ITR 451 CIT Vs. Simit P. Seth held as under: - “In the present case, the Commissioner of Income-tax (Appeals) believed that when as a trader in steel the assessee sold certain quantity of steel, he would have purchased the same quantity from some source. When the total sale is accepted by the Assessing Officer, he could not have questioned the very basis…

Deputy Commissioner of Income Tax, Central Circle-4, Jaipur vs. Sunder Das Sonkiya, Jaipur

In the result, both appeals of the revenue are dismissed

ITA 453/JPR/2024[2012-13]Status: DisposedITAT Jaipur09 Oct 2024AY 2012-13

Bench: Moving Towards The Facts Of The Case We Would Like To Mention That The Revenue Has Assailed The Appeal In Ita No.453/Jp/2024 On The Following Grounds; “(I) Whether On The Facts & In The Circumstances Of The Case, The Ld. Cit(A) Is Justified In Deleting The Addition Of Rs.43,33,606/- Without Appreciating The Fact That Assessee Has Shown Bogus Purchase Of Rs 1,73,34,424/- During The Year From A Bogus Concern. 3

Section 132Section 143(1)Section 143(2)Section 148

…the inference can only be that it is an unproved purchase. In such a case, the approach of the Tribunal that a reasonable disallowance for possible inflation could be warranted, has to be upheld.” Recently the Gujrat High Court in Judgement reported at (2013) 356 ITR 451 CIT Vs. Simit P. Seth held as under: - “In the present case, the Commissioner of Income-tax (Appeals) believed that when as a trader in steel the assessee sold certain quantity of steel, he would have purchased the same quantity from some source. When the total sale is accepted by the Assessing Officer, he could not have questioned the very basis…

Manohar Manak Alloys Private Limited, C.P Tank Road, Mumbai vs. DCIT, Circle 4(2)(2), Mumbai, Aayakar Bhavan

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

ITA 260/MUM/2024[2009-10]Status: DisposedITAT Mumbai10 Sept 2024AY 2009-10

Bench: Ms. Padmavathy S & Shri Sandeep Singh Karhail

For Appellant: Shri Rajkumar SinghFor Respondent: Shri Surendra Meena, Sr. DR
Section 133(6)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 250

…d as bogus by the Sales Tax Authorities. Accordingly, by applying the peak credit theory, the AO made an addition of Rs.1,36,47,218. 7. The learned CIT(A), vide impugned order, following the decision of the Hon’ble Gujarat High Court in CIT v/s Smith P Sheth, 356 ITR 451, upheld the addition on account of bogus purchases to the extent of 12.5% of the impugned purchases being the gross profit margin embedded in such purchases. Accordingly, the learned CIT(A) upheld the addition amounting to Rs.25,86,547, being 12.5% of Rs.2,86,92,372. Being aggrieved, the assessee is in appeal before us. 8. We have considered the…

ITO, Ward-2(1), Thane vs. Shri Mehul Shantilal Bhavsar, Thane

In the result, the appeal filed by the revenue is dismissed

ITA 778/MUM/2020[2010-11]Status: DisposedITAT Mumbai05 Sept 2024AY 2010-11

Bench: Shri Br Baskaran&, Shri Pavan Kumar Gadaleito, Ward-2(1) Shri Mehul Shantilal Room No. 25, B-Wing, Bhavsar, Vs. 6Th Floor, Ashar It Park, Prop-M/S Shanti Road No. 16Z, Industries, Room No. 5, Wagle Indl. Estate, Mathura Dham Building, Thane-400604. Cabin Road,Bhayander(E), Maharashtra Thane-401105. Maharashtra. Pan/Gir No. Aibpb2782K (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Appellant By Smt.Mahita Nair. Sr. Dr Respondent By None

Section 133(6)Section 143(2)

…the facts and considered the Hon’ble High Court decision and took a view. Further, We find the Jurisdictional Honble High Court in the case of Pooja Paper Trading Co. Vs. ITO, (104 taxmann.com 95) and Honble Gujarat High court in CIT Vs. Simit P Sheth (2013) (356 ITR 451)has considered the profit element embedded in the transaction. 6. We find that the Ld.CIT(A) took a reasonable view that the only profit percentage has to be added and estimated @ 12.5% of bogus purchases. The Ld.DR could not controvert the observations of the Ld. CIT(A) with any new cogent evidence and material but relied only on the A.O order.…

Income Tax Officer, Mumbai vs. Govindbhai Tribhuvandas Patel, Mumbai

In the result, the appeal filed by the Assessee is partly allowed, whereas the appeal filed by the Revenue Department stands dismissed

ITA 4827/MUM/2023[2011-12]Status: DisposedITAT Mumbai26 Aug 2024AY 2011-12

Bench: Shri Narender Kumar Choudhry & Shri Amarjit Singhassessment Year: 2011-12

For Appellant: Shri Viraj Mehta, A.RFor Respondent: Dr. Kishor Dhule, CIT-DR
Section 133(6)Section 147Section 148Section 250Section 69C

…pening of the assessment u/s 148 of the Act, however by following the judgment of the Jurisdictional High Court in the case of PCIT vs. SV Jiwani (2022) 145 taxmann.com (Bombay) and the Hon’ble Gujarat High Court judgment in the case of CIT vs. Simit P. Sheth 356 ITR 451 (Guj.) restricted the addition to the tune of 12.5% of the alleged bogus purchases of Rs.10,16,50,735/- instead of 100% addition made by the AO. 5. The Revenue Department, being aggrieved, mainly on the reduction of addition to 12.5%, is in appeal before us, whereas the Assessee by filing separate appeal has challenged the addition restricted to…

Govindbhai Tribhuvandas Patel, Mumbai vs. ITO 19(1)(3), Mumbai

In the result, the appeal filed by the Assessee is partly allowed, whereas the appeal filed by the Revenue Department stands dismissed

ITA 4322/MUM/2023[2011-12]Status: DisposedITAT Mumbai26 Aug 2024AY 2011-12

Bench: Shri Narender Kumar Choudhry & Shri Amarjit Singhassessment Year: 2011-12

For Appellant: Shri Viraj Mehta, A.RFor Respondent: Dr. Kishor Dhule, CIT-DR
Section 133(6)Section 147Section 148Section 250Section 69C

…pening of the assessment u/s 148 of the Act, however by following the judgment of the Jurisdictional High Court in the case of PCIT vs. SV Jiwani (2022) 145 taxmann.com (Bombay) and the Hon’ble Gujarat High Court judgment in the case of CIT vs. Simit P. Sheth 356 ITR 451 (Guj.) restricted the addition to the tune of 12.5% of the alleged bogus purchases of Rs.10,16,50,735/- instead of 100% addition made by the AO. 5. The Revenue Department, being aggrieved, mainly on the reduction of addition to 12.5%, is in appeal before us, whereas the Assessee by filing separate appeal has challenged the addition restricted to…

Income Tax Officer, Mumbai vs. Sameer Mahesh Sachde, Mumbai

In the result, the appeal filed by the Revenue is dismissed and the Cross

ITA 2630/MUM/2024[2011-12]Status: DisposedITAT Mumbai02 Aug 2024AY 2011-12

Bench: Shri B.R. Baskaran & Shri Anikesh Banerjee

For Appellant: Shri Pravin ChavanFor Respondent: Shri Vimal Punmiya
Section 148

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “J (SMC)”, MUMBAI BEFORE SHRI B.R. BASKARAN, ACCOUNTANT MEMBER AND SHRI ANIKESH BANERJEE, JUDICIAL MEMBER ITA NO. 2630/MUM/2024 & CO NO. 143/MUM/2024 : A.Y : 2011-12 Income Tax Officer, Vs. Sameer Mahesh Sachde Mumbai. (Appellant) Room no. 84/85, 3rd floor, 69, B. Kutchi Lohana Niwas, Mumbai 400 010. PAN: AHZPS4210J (Respondent/Cross Objector) Appellant by : Shri Pravin Chavan Respondent by : Shri Vimal Punmiya Date of Hearing : 30/07/2024 Date of Pronouncement : 02/08/2024 ORDER PER B.R. BASKARAN, ACCOUNTANT MEMBER : The appeal filed by the Revenue and the Cross…

Dinesh Tarachand Mehta, Mumbai vs. CIT (A)-30, Mumbai

In the result, both the appeals of the assessee are partly allowed

ITA 4591/MUM/2023[2011-12]Status: DisposedITAT Mumbai24 Jul 2024AY 2011-12

Bench: Shri Narender Kumar Choudhry & Smt. Renu Jauhri

For Appellant: Mr. Nikhil JoshiFor Respondent: Shri Nagnath Pasale
Section 143(1)Section 147Section 148Section 250

…age 3 of 5 ITA Nos. 4590, 4591/Mum/2023 A.Ys.2010-11 & 2011-12 DINESH TARACHAND MEHTA b. The Ld. CIT(A) has upheld the order of the AO based on various decisions, specifically that of the Hon’ble Gujarat High Court in the case of CIT v/s Simit P. Shet (2013) 356 ITR 451. 7. We have considered the rival submissions and perused various judicial pronouncements cited by the Ld. AR as well as Ld. DR. The only issue for consideration is whether the element of profit estimated by the AO @12.5% in such bogus purchases is reasonable or not. 8. The assessee is engaged in trading in Ferrous and Non-ferrous Metals. Since, t…

Dinesh Tarakchand Mehta, Mumbai vs. CIT(A)-30, Mumbai

In the result, both the appeals of the assessee are partly allowed

ITA 4590/MUM/2023[2010-11]Status: DisposedITAT Mumbai24 Jul 2024AY 2010-11

Bench: Shri Narender Kumar Choudhry & Smt. Renu Jauhri

For Appellant: Mr. Nikhil JoshiFor Respondent: Shri Nagnath Pasale
Section 143(1)Section 147Section 148Section 250

…age 3 of 5 ITA Nos. 4590, 4591/Mum/2023 A.Ys.2010-11 & 2011-12 DINESH TARACHAND MEHTA b. The Ld. CIT(A) has upheld the order of the AO based on various decisions, specifically that of the Hon’ble Gujarat High Court in the case of CIT v/s Simit P. Shet (2013) 356 ITR 451. 7. We have considered the rival submissions and perused various judicial pronouncements cited by the Ld. AR as well as Ld. DR. The only issue for consideration is whether the element of profit estimated by the AO @12.5% in such bogus purchases is reasonable or not. 8. The assessee is engaged in trading in Ferrous and Non-ferrous Metals. Since, t…

M/S. Mukka Proteins Limited (Formerly Know As Mukka Sea Food Industries Ltd., Mangalore vs. Deputy Commissioner of Income Tax, Central Circle-1, Mangaluru

In the result, appeals of the assessee in ITA Nos

ITA 431/BANG/2024[2013-14]Status: DisposedITAT Bangalore03 Jul 2024AY 2013-14

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Sri Narendra Sharma, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 132Section 132(4)Section 153ASection 153DSection 234A

…trader and the Tribunal having retained twelve and half per cent of the purchase towards its possible profit, there was no reason to interfere in the order of the Tribunal.” 5.16 In the case of CIT Vs. Simit P. Sheth the Gujarat High Court reported in (2013) 356 ITR 451 (Guj) wherein the Hon’ble Gujarat High Court has held as under: “The assessee was engaged in the business of trading in steel on wholesale basis. During the course of the reassessment proceedings for the year 2006-07, the Assessing Officer noticed that some of the suppliers of steel to the assessee had made their statements on oath to the effect…

M/S. Gordhansingh S Rajpurohit, Navi Mumbai vs. The Income Tax Officer, Ward-5, Panvel

In the result, the appeal of the assessee is treated as allowed for statistical purposes

ITA 512/PUN/2024[2009-10]Status: DisposedITAT Pune01 Jul 2024AY 2009-10

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: N O N EFor Respondent: Shri Ramnath P. Murkunde
Section 133(6)Section 143(3)Section 145Section 68

…lated. Moreover the impugned addition of Rs.3,08,99,339/- would result in net profit of 68% which is not possible in any trading business. Therefore, following the principle laid down in the decision of Hon'ble Gujarat High Court, in the case of Simit P Seth (356 ITR 451), I accordingly direct the AO to restrict the addition to Rs.46,34,900/- (15% of Rs.3,08,99,339/-) instead of Rs.3,08,99,339/- made by him. The appellant gets relief of Rs.2,62,64,439/-.” 4.3 The Ld. CIT(A) however confirmed the addition of Rs.92,81,370/- on account of unexplained sundry creditors vide para 6 of his order for want of confirmatio…

ITO-19(3)(1), Mumbai vs. Shankarlal Bhimraj Bhansali, Mumbai

In the result, appeal is dismissed

ITA 807/MUM/2024[2010-11]Status: DisposedITAT Mumbai25 Jun 2024AY 2010-11

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI RATNESH NANDAN SAHAY (Accountant Member)

For Appellant: NoneFor Respondent: Shri P.D. Chougule, SR. D.R
Section 250

…IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH “E”, MUMBAI BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER AND SHRI RATNESH NANDAN SAHAY, ACCOUNTANT MEMBER Assessment Year: 2010-11 ITO – 19(3)(1) Shankarlal Bhimraj 405, Piramal Chambers, Bhansali Lalbaug, 38 Mukadam Building, Vs. 2nd Carpenter Street, Mumbai – 400012. Shop No. 3, Mumbai – 400004 PAN: AAAPB6637J (Appellant) (Respondent) Present for: Assessee by : None Revenue by : Shri P.D. Chougule, SR. D.R. Date of Hearing : 29 . 05 . 2024 Date of Pronouncement : 25 . 06 . 2024 O R D E R Per: Ratnesh Nandan Sahay, Accountant Member: 1. This appeal has been filed a…

Alfiya Ayazali Sayyad, Nagpur vs. Income Tax Officer, Ward-2(2), Nagpur

In the result, appeal filed by the assessee is allowed

ITA 206/NAG/2022[2010-11]Status: DisposedITAT Nagpur24 Jun 2024AY 2010-11

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

For Appellant: Shri Abhay AgrawalFor Respondent: Shri Surjit Kumar Saha
Section 271(1)(c)Section 274

…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.206/Nag./2022 (Assessment Year : 2010–11) Alfiya Ayazali Sayyad Flat no.5, Luxury Apartment ……………. Appellant Bajeriya, Nagpur 440 018 PAN – AOPJS9199H v/s Income Tax Officer ……………. Respondent Ward–2(2), Nagpur Assessee by : Shri Abhay Agrawal Revenue by : Shri Surjit Kumar Saha Date of Hearing – 24/06/2024 Date of Order – 24/06/2024 O R D E R PER V. DURGA RAO, J.M. The present appeal has been filed by the assessee challenging the impugned order dated 30/07/2021, pas…

Construction Technique, Mumbai vs. ACIT, Circle-20(1), Mumbai

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

ITA 747/MUM/2024[2010-11]Status: DisposedITAT Mumbai21 Jun 2024AY 2010-11

Bench: Shri Amarjit Singh & Shri Rahul Chaudhary

For Appellant: Aditya RamchandranFor Respondent: H.M. Bhatt
Section 133(6)Section 147Section 148Section 69C

…assessee restricted the addition to the extent of profit element embedded in such bogus purchases. The ld. CIT(A) restricted the addition to the extent of 18.25% after considering the decision of the Hon'ble Gujarat High Court in CIT v/s Simit P. Sheth (2013) 356 ITR 451 (Guj). In our view, the ld. CIT(A) disallowed the bogus purchases on reasonable basis. We have further noted that the decision arrived by ld. CIT(A) is in conformity with the order of Hon'ble Gujarat High Court in CIT v/s Simit P. Sheth (supra), which we affirm. No other contrary decision has been brought to our notice by the Ld. DR for the reven…

Harisons Steel Limited, Wada Thane vs. Dy CIT 12(2)(2), Mumbai

In the result, the appeal of the assessee vide ITA No

ITA 3957/MUM/2023[2013-14]Status: DisposedITAT Mumbai10 Jun 2024AY 2013-14

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhail

For Appellant: Mani JainFor Respondent: Biswanath Das
Section 143(3)Section 147Section 148

…se where the entire cash has been siphoned off by debiting the bogus purchases. This is a case where at the most, the purchases/expenses might have been inflated. Therefore, relying upon the decision of Hon'ble Gujarat High Court, in the case of Simit P Seth (356 ITR 451) and considering the facts in the appellant's case, I direct the AO to restrict the addition to Rs.16,30,54,466/- [i.e.12.5% of Rs. 130,44,35,730/- e the purchases against which bogus cenvat credit benefit is availed by the appellant), against addition made by the AO of Rs. 19,56,65,360/-, thereby reducing the said addition by an amount of Rs. 3,…

Harisons Steel Ltd, Wada Thane vs. DCIT 12(2)(2), Mumbai

In the result, the appeal of the assessee vide ITA No

ITA 3943/MUM/2023[AY 2011-12]Status: DisposedITAT Mumbai10 Jun 2024

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhail

For Appellant: Mani JainFor Respondent: Biswanath Das
Section 143(3)Section 147Section 148

…se where the entire cash has been siphoned off by debiting the bogus purchases. This is a case where at the most, the purchases/expenses might have been inflated. Therefore, relying upon the decision of Hon'ble Gujarat High Court, in the case of Simit P Seth (356 ITR 451) and considering the facts in the appellant's case, I direct the AO to restrict the addition to Rs.16,30,54,466/- [i.e.12.5% of Rs. 130,44,35,730/- e the purchases against which bogus cenvat credit benefit is availed by the appellant), against addition made by the AO of Rs. 19,56,65,360/-, thereby reducing the said addition by an amount of Rs. 3,…

Parmanand & Sons Food Product Pvt. Ltd, Delhi vs. DCIT, Central Circle-20

In the result, the appeals are disposed of as follows:

ITA 981/DEL/2022[2018-19]Status: DisposedITAT Delhi30 May 2024AY 2018-19

Bench: Dr. B.R.R. Kumar & Sh. Yogesh Kumar Usita No. 711, 712 & 713/Del/2022 A.Y. 2016-17, 2017-18 & 2018-19 Kwality Techmech Pvt. Ltd. Vs. Dcit/Acit, B-20, Lawrence Road Cc-20, Industrial Area , Delhi Keshav Puram, North West Delhi, Delhi-110035 Pan : Aaeck1176E Appellant Respondent

Section 69B

…rds its possible profit, there was no reason to interfere in the order of the Tribunal.” ITA No.71/Del/2022 & Ors. Kwality Techmech Pvt. Ltd. & other connected matters 28 In the case of CIT Vs. Simit P. Sheth the Gujarat High (vii) Court reported in (2013) 356 ITR 451 (Guj) wherein the Hon’ble Gujarat High Court has held as under: “The assessee was engaged in the business of trading in steel on wholesale basis. During the course of the reassessment proceedings for the year 2006-07, the Assessing Officer noticed that some of the suppliers of steel to the assessee had made their statements on oath to the effec…

Parmanand & Sons Food Product Pvt. Ltd, Delhi vs. DCIT, Central Circle-20

In the result, the appeals are disposed of as follows:

ITA 980/DEL/2022[2017-18]Status: DisposedITAT Delhi30 May 2024AY 2017-18

Bench: Dr. B.R.R. Kumar & Sh. Yogesh Kumar Usita No. 711, 712 & 713/Del/2022 A.Y. 2016-17, 2017-18 & 2018-19 Kwality Techmech Pvt. Ltd. Vs. Dcit/Acit, B-20, Lawrence Road Cc-20, Industrial Area , Delhi Keshav Puram, North West Delhi, Delhi-110035 Pan : Aaeck1176E Appellant Respondent

Section 69B

…rds its possible profit, there was no reason to interfere in the order of the Tribunal.” ITA No.71/Del/2022 & Ors. Kwality Techmech Pvt. Ltd. & other connected matters 28 In the case of CIT Vs. Simit P. Sheth the Gujarat High (vii) Court reported in (2013) 356 ITR 451 (Guj) wherein the Hon’ble Gujarat High Court has held as under: “The assessee was engaged in the business of trading in steel on wholesale basis. During the course of the reassessment proceedings for the year 2006-07, the Assessing Officer noticed that some of the suppliers of steel to the assessee had made their statements on oath to the effec…

DCIT, Central Circle-20, New Delhi vs. Devesh Mittal, Delhi

In the result, the appeals are disposed of as follows:

ITA 944/DEL/2022[2017--18]Status: DisposedITAT Delhi30 May 2024

Bench: Dr. B.R.R. Kumar & Sh. Yogesh Kumar Usita No. 711, 712 & 713/Del/2022 A.Y. 2016-17, 2017-18 & 2018-19 Kwality Techmech Pvt. Ltd. Vs. Dcit/Acit, B-20, Lawrence Road Cc-20, Industrial Area , Delhi Keshav Puram, North West Delhi, Delhi-110035 Pan : Aaeck1176E Appellant Respondent

Section 69B

…rds its possible profit, there was no reason to interfere in the order of the Tribunal.” ITA No.71/Del/2022 & Ors. Kwality Techmech Pvt. Ltd. & other connected matters 28 In the case of CIT Vs. Simit P. Sheth the Gujarat High (vii) Court reported in (2013) 356 ITR 451 (Guj) wherein the Hon’ble Gujarat High Court has held as under: “The assessee was engaged in the business of trading in steel on wholesale basis. During the course of the reassessment proceedings for the year 2006-07, the Assessing Officer noticed that some of the suppliers of steel to the assessee had made their statements on oath to the effec…