Sanjay Oil Cake Industries v. CIT (10 DTR 153)

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. S S PULSES MANUFACTURING PVT LTD, DELHI

In the result, the appeal is partly allowed

ITA 2384/DEL/2024[2012]Status: DisposedITAT Delhi09 Dec 2025

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: NoneFor Respondent: Shri Manish Gupta, Sr. DR

Section 143(3)Section 147Section 148Section 69C

…along with the conduct of the assessee has led to the inescapable conclusion that the assessee had taken accommodation entries and alleged purchases were not genuine. 5.2 The Hon’ble Gujarat High Court in the cases of M/s. Sanjay Oil Cake Industries Vs. CIT (10 DTR 153) and Hon’ble Ahmedabad Tribunal in the case of M/s. Vijay Proteins Ltd. Vs. ACIT (58 ITD 428) has extensively dealt with this issue and came to conclusion that disallowance of 25% of impugned purchases would suffice the Page 4 of 16 DCIT Vs. S.S. Pulses [A.Y 2012-13] matter. Similarly, the Hon’ble Jaipur Tribunal in the case of Deepak Dalela Vs.…

ALKA KHANDAKA,JAIPUR vs. INCOME TAX OFFICER WARD 1(2), JAIPUR

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

ITA 1014/JPR/2025[2017-2018]Status: DisposedITAT Jaipur16 Oct 2025AY 2017-2018

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Sauravh Harsh, AdvFor Respondent: Mrs. Anita Rinesh, JCIT

Section 131Section 142(1)Section 143(2)Section 143(3)Section 44ASection 68

…ase vouchers and issuing bogus sale vouchers. Thus there was no justification of the Learned Assessing Officer for taking u/s 153 in the case and subsequently completing the assessment by making addition of Rs. 1,02,92,954/-. Sunjay Oil Case Industries v. CIT 10 DTR 153 (Guj.) case is not applicable— The Learned Assessing Officer has referred the aforesaid case law on page no.36 of the assessment order. It is submitted that the ratio of this case has not been found applicable in the case of the assessee in Assessment Year 2006-07 wherein addition was made by disallowing 25% of the bogus purchases to the tune of R…

DEPUTY COMMISSIONER OF INCOME TAX-1(1), RAIPUR vs. SHANTA TECHNO PRIVATE LIMITED, RAIPUR

ITA 155/RPR/2025[2018-19]Status: DisposedITAT Raipur18 Jun 2025AY 2018-19

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 155/Rpr/2025 (िनधा"रण वष" Assessment Year: 2018-19)

For Appellant: NoneFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 142(1)Section 147Section 148Section 250Section 69C

…along with the conduct of the assessee has led to the inescapable conclusion that the assessee had taken accommodation entries and alleged purchases were not genuine. 5.2 The Hon’ble Gujarat High Court in the cases of M/s Sanjay Oil Cake Industries Vs. CIT (10 DTR 153) and Hon’ble Ahmedabad Tribunal in the case of M/s. Vijay Proteins Ltd. Vs. ACIT (58 ITD 428) has extensively dealt with this issue and came to conclusion that disallowance of 25% of impugned purchases would suffice the matter. Similarly, the Hon’ble Jaipur Tribunal in the case of Deepak Dalela Vs. ITO (50 DTR 502) had extensively dealt with this…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-4, JAIPUR, 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

…nt proceedings were held as genuine and not bogus. The Ld. A.O. for making disallowance of 25% of said alleged purchases of Rs. 1,73,34,424/- relied on judgement in case of Sanjay Oil Cake Industries. The judgement of Sanjay Oil Cake Industries Vs. CIT (2008) 10 DTR 153 (Guj.) is not applicable. In this connection it is submitted that the facts of the said case are quite different from the facts of the party from whom assessee made purchases. These are as under: - Facts in case of Sanjay Oil Cake Industries Facts of the parties from whom assessee made purchases (i) It was found that parties were not Parties are…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-4, JAIPUR, 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

…nt proceedings were held as genuine and not bogus. The Ld. A.O. for making disallowance of 25% of said alleged purchases of Rs. 1,73,34,424/- relied on judgement in case of Sanjay Oil Cake Industries. The judgement of Sanjay Oil Cake Industries Vs. CIT (2008) 10 DTR 153 (Guj.) is not applicable. In this connection it is submitted that the facts of the said case are quite different from the facts of the party from whom assessee made purchases. These are as under: - Facts in case of Sanjay Oil Cake Industries (i) (ii) (iii) It was found that parties were not traceable - only bills and sales tax No. were furnished.…

ITO-19(3)(1), MUMBAI vs. THANA RAM MANGI LAL CHOUDHARY, MUMBAI

In the result, the appeal is partly allowed

ITA 2698/MUM/2024[2009-10]Status: DisposedITAT Mumbai29 Aug 2024AY 2009-10

Bench: Shri Amarjit Singh, Hon’Ble & Shri Anikesh Banerjee, Hon’Bleassessment Year: 2009-10 Ito-19(3)(1), Mumbai Thana Ram Mangi Lal Choudhary Vs 33/36, Prabhu Shree Ram Mandir, 4Th Kumbharwada, Maharashtra-400004. Pan: Afepc 1898 P (Appellant) (Respondent)

For Appellant: NoneFor Respondent: Shri P.D. Chougule Addl. CIT/ Sr. DR

Section 142(1)Section 145(3)Section 147Section 148

…to the inescapable conclusion 4 Thana Ram Mangi Lal Choudhary A.Y. 2009-10 that the assessee had taken accommodation entries and alleged purchases were not genuine. 6.2 The Hon’ble Gujarat High Court in the cases of M/s. Sanjay Oil Cake Industries Vs. CIT (10 DTR 153) and Hon’ble Ahmedabad Tribunal in the case of M/s. Vijay Proteins Ltd. Vs. ACIT (58 ITD 428) has extensively dealt with this issue and came to conclusion that disallowance of 25% of impugned purchases would suffice the matter. Similarly, the Hon’ble Jaipur Tribunal in the case of Deepak DalelaVs. ITO (50 DTR 502) had extensively dealt with this i…

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

…ered along with the conduct of the assessee has led to the inescapable conclusion that the assessee had taken accommodation entries and alleged purchases were not genuine. The Hon'ble Gujarat High Court in the cases of M/s. Sanjay Oil Cake Industries Vs. CIT (10 DTR 153) and Hon'ble Ahmedabad Tribunal in the case of M/s. Vijay Proteins Ltd. Vs. ACIT (58 ITD 428) has extensively dealt with this issue and came to conclusion that disallowance of 25% of impugned purchases would suffice the matter Similarly, the Hon'ble Jaipur Tribunal in the case of Deepak Dalela Vs. ITO (50 DTR 502) had extensively dealt with this i…

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

…ered along with the conduct of the assessee has led to the inescapable conclusion that the assessee had taken accommodation entries and alleged purchases were not genuine. The Hon'ble Gujarat High Court in the cases of M/s. Sanjay Oil Cake Industries Vs. CIT (10 DTR 153) and Hon'ble Ahmedabad Tribunal in the case of M/s. Vijay Proteins Ltd. Vs. ACIT (58 ITD 428) has extensively dealt with this issue and came to conclusion that disallowance of 25% of impugned purchases would suffice the matter Similarly, the Hon'ble Jaipur Tribunal in the case of Deepak Dalela Vs. ITO (50 DTR 502) had extensively dealt with this i…

SHRI KHANDELWAL DIAMONDS PRIVATE LIMITED,JAIPUR vs. ACIT, CIRCLE 1, JAIPUR, JAIPUR

In the result, appeal of the assessee is partly allowed

ITA 375/JPR/2023[2012-13]Status: DisposedITAT Jaipur30 Oct 2023AY 2012-13

Bench: Him On The Reason Of Issuing Notice U/S 148 On Borrowed Satisfaction Of Another Wing Of The Department.

For Appellant: Sh. Mukesh Khandelwal (CA)For Respondent: Sh. Anup Singh (Addl. CIT) a

Section 143(3)Section 148

…ed a sum of Rs. 8,77,442 being 25% of purchases of Rs. 35,09,770 made from three concerns alleged to be belonging to Bhanwar Lal Jain group by relying on the judgement of the Hon`ble Gujarat High Court rendered in the case of Sanjay Oilcake Industries (2008) (10 DTR 153). First Appeal : An appeal was preferred to the Ld. CIT (A) who concurred with the view of the ld. AO sustained the order. Grounds of Appeal : At this juncture the appellant would like to take one additional ground which is legal in nature and which is being taken for the first time. As the issue is legal in nature and all facts thereto are ar…

SHRI KHANDELWAL DIAMONDS PRIVATE LIMITED,JAIPUR vs. DCIT, CIRCLE 1, JAIPUR, JAIPUR

In the result, appeal of the assessee is allowed

ITA 245/JPR/2023[2014-15]Status: DisposedITAT Jaipur18 Jul 2023AY 2014-15

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Mukesh Khandelwal (C.A.)For Respondent: Shri C.P. Meena (Addl.CIT) a

Section 132(4)Section 142(1)Section 143(2)Section 143(3)

…sum of Rs. 80,48,367 being 25% of purchases of Rs. 3,21,93,468 made from eleven concerns alleged to be belonging to Bhanwar Lal Jain group by relying on the judgement of the Hon`ble Gujarat High Court rendered in the case of Sanjay Oilcake Industries (2008) (10 DTR 153). First Appeal : An appeal was preferred to the Ld. CIT (A) who concurred with the view of the ld. AO sustained the order. Grounds of Appeal : At this juncture the appellant would like to take one additional ground which is legal in nature and which is being taken for the first time. As the issue is legal in nature and all facts thereto are arisin…

P P JEWELLERS PVT. LTD.,DELHI vs. ACIT, CENTRAL CIRCLE- 25, NEW DELHI

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

ITA 6931/DEL/2017[2013-14]Status: DisposedITAT Delhi23 Mar 2023AY 2013-14

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar Usi.T.A. No. 6332/Del/2017 (A.Y 2011-12) P P Jewellers Pvt. Ltd., Vs. Acit, H-5, Netaji Subhash Place, Central Circle : 25, Pitampura, Delhi – 110 034. New Delhi. Pan No. Aaacp0874G & I.T.A. No. 6529/Del/2017 (A.Y 2011-12) Acit, Vs. P P Jewellers Pvt. Ltd., Central Circle : 25, H-5, Netaji Subhash Place, New Delhi. Pitampura, Delhi – 110 034. Pan No. Aaacp0874G & I.T.A. No. 6931/Del/2017 (A.Y 2013-14) P P Jewellers Pvt. Ltd., Vs. Acit, H-5, Netaji Subhash Place, Central Circle : 25, Pitampura, Delhi – 110 034. New Delhi. (Respondents) Pan No. Aaacp0874G (Appellants)

For Appellant: Shri R. R. Singla, C. AFor Respondent: Shri K. K. Mishra, Sr. D. R

Section 132(4)Section 133ASection 139(1)Section 143(1)Section 147

…IN THE INCOME TAX APPELLATE TRIBUNAL [DELHI BENCH: “F” NEW DELHI ] BEFORE DR. B. R. R. KUMAR, ACCOUNTANT MEMBER AND SHRI YOGESH KUMAR US, JUDICIAL MEMBER I.T.A. No. 6332/DEL/2017 (A.Y 2011-12) P P Jewellers Pvt. Ltd., Vs. ACIT, H-5, Netaji Subhash Place, Central Circle : 25, Pitampura, Delhi – 110 034. New Delhi. PAN No. AAACP0874G AND I.T.A. No. 6529/DEL/2017 (A.Y 2011-12) ACIT, Vs. P P Jewellers Pvt. Ltd., Central Circle : 25, H-5, Netaji Subhash Place, New Delhi. Pitampura, Delhi – 110 034. PAN No. AAACP0874G AND I.T.A. No. 6931/DEL/2017 (A.Y 2013-14) P P Jewellers Pvt. Ltd., Vs. ACIT, H-5, Netaji Subhash P…

DCIT, CENTRAL CIRCLE- 25, NEW DELHI vs. P P JEWELLERS PVT. LTD., DELHI

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

ITA 6529/DEL/2017[2011-12]Status: DisposedITAT Delhi23 Mar 2023AY 2011-12

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar Usi.T.A. No. 6332/Del/2017 (A.Y 2011-12) P P Jewellers Pvt. Ltd., Vs. Acit, H-5, Netaji Subhash Place, Central Circle : 25, Pitampura, Delhi – 110 034. New Delhi. Pan No. Aaacp0874G & I.T.A. No. 6529/Del/2017 (A.Y 2011-12) Acit, Vs. P P Jewellers Pvt. Ltd., Central Circle : 25, H-5, Netaji Subhash Place, New Delhi. Pitampura, Delhi – 110 034. Pan No. Aaacp0874G & I.T.A. No. 6931/Del/2017 (A.Y 2013-14) P P Jewellers Pvt. Ltd., Vs. Acit, H-5, Netaji Subhash Place, Central Circle : 25, Pitampura, Delhi – 110 034. New Delhi. (Respondents) Pan No. Aaacp0874G (Appellants)

For Appellant: Shri R. R. Singla, C. AFor Respondent: Shri K. K. Mishra, Sr. D. R

Section 132(4)Section 133ASection 139(1)Section 143(1)Section 147

…IN THE INCOME TAX APPELLATE TRIBUNAL [DELHI BENCH: “F” NEW DELHI ] BEFORE DR. B. R. R. KUMAR, ACCOUNTANT MEMBER AND SHRI YOGESH KUMAR US, JUDICIAL MEMBER I.T.A. No. 6332/DEL/2017 (A.Y 2011-12) P P Jewellers Pvt. Ltd., Vs. ACIT, H-5, Netaji Subhash Place, Central Circle : 25, Pitampura, Delhi – 110 034. New Delhi. PAN No. AAACP0874G AND I.T.A. No. 6529/DEL/2017 (A.Y 2011-12) ACIT, Vs. P P Jewellers Pvt. Ltd., Central Circle : 25, H-5, Netaji Subhash Place, New Delhi. Pitampura, Delhi – 110 034. PAN No. AAACP0874G AND I.T.A. No. 6931/DEL/2017 (A.Y 2013-14) P P Jewellers Pvt. Ltd., Vs. ACIT, H-5, Netaji Subhash P…

P P JEWELLERS PVT. LTD.,DELHI vs. ACIT, CENTRAL CIRCLE- 25, NEW DELHI

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

ITA 6332/DEL/2017[2011-12]Status: DisposedITAT Delhi23 Mar 2023AY 2011-12

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar Usi.T.A. No. 6332/Del/2017 (A.Y 2011-12) P P Jewellers Pvt. Ltd., Vs. Acit, H-5, Netaji Subhash Place, Central Circle : 25, Pitampura, Delhi – 110 034. New Delhi. Pan No. Aaacp0874G & I.T.A. No. 6529/Del/2017 (A.Y 2011-12) Acit, Vs. P P Jewellers Pvt. Ltd., Central Circle : 25, H-5, Netaji Subhash Place, New Delhi. Pitampura, Delhi – 110 034. Pan No. Aaacp0874G & I.T.A. No. 6931/Del/2017 (A.Y 2013-14) P P Jewellers Pvt. Ltd., Vs. Acit, H-5, Netaji Subhash Place, Central Circle : 25, Pitampura, Delhi – 110 034. New Delhi. (Respondents) Pan No. Aaacp0874G (Appellants)

For Appellant: Shri R. R. Singla, C. AFor Respondent: Shri K. K. Mishra, Sr. D. R

Section 132(4)Section 133ASection 139(1)Section 143(1)Section 147

…IN THE INCOME TAX APPELLATE TRIBUNAL [DELHI BENCH: “F” NEW DELHI ] BEFORE DR. B. R. R. KUMAR, ACCOUNTANT MEMBER AND SHRI YOGESH KUMAR US, JUDICIAL MEMBER I.T.A. No. 6332/DEL/2017 (A.Y 2011-12) P P Jewellers Pvt. Ltd., Vs. ACIT, H-5, Netaji Subhash Place, Central Circle : 25, Pitampura, Delhi – 110 034. New Delhi. PAN No. AAACP0874G AND I.T.A. No. 6529/DEL/2017 (A.Y 2011-12) ACIT, Vs. P P Jewellers Pvt. Ltd., Central Circle : 25, H-5, Netaji Subhash Place, New Delhi. Pitampura, Delhi – 110 034. PAN No. AAACP0874G AND I.T.A. No. 6931/DEL/2017 (A.Y 2013-14) P P Jewellers Pvt. Ltd., Vs. ACIT, H-5, Netaji Subhash P…

M/S. G.B.IMPEX,JAIPUR vs. ITO, WARD-6(3), JAIPUR

In the result, the appeal of the assessee is dismissed

ITA 235/JPR/2020[2007-08]Status: DisposedITAT Jaipur30 Apr 2021AY 2007-08

For Appellant: Shri P.C. Parwal (C.A.)For Respondent: Shri A.S. Nehra (ACIT) a

Section 145(3)

…ding before the undersigned, written submission alongwith copy of ITR, copy of bank account, copy of sale bills etc. have been filed by them. Accordingly, the AO after relying on the decision of Gujarat High Court in case of Sanjay Oil Cake Industries Vs. CIT 10 DTR 153 rejected the books of accounts and made trading addition of Rs.97,61,863/- by disallowing 25% of purchases of Rs.3,90,47,452/-. On appeal, the Ld. CIT(A) confirmed the action of AO in rejecting the books of account u/s 145(3) of the Act. As regard to the disallowance of 25% out of alleged 3 M/s G.B. Impex vs. ITO unverifiable purchases received f…

SHRI SUNDER DAS SONKIA,JAIPUR vs. ITO, WARD 1(2), JAIPUR

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

ITA 1383/JPR/2019[2010-11]Status: DisposedITAT Jaipur18 Jan 2021AY 2010-11

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita No. 1383/Jp/2019 Assessment Year: 2010-11 Shri Sunder Das Sonkia, Cuke I.T.O., Vs. Sonkia Bhawan, Sms, Highway, Ward-1(2), Jaipur. Jaipur. Pan No.: Akhps 7413 G Vihykfkhz@Appellant Izr;Fkhz@Respondent Vk;Dj Vihy La-@Ita No. 09/Jp/2020 Assessment Year: 2010-11 I.T.O., Cuke Shri Sunder Das Sonkhiya, Vs. Ward-1(2), Prop.- M/S Naveen Jewellers, Jaipur. Sonkhiya Bhawan, Chaura Rasta, Jaipur. Pan No.: Akhps 7413 G Vihykfkhz@Appellant Izr;Fkhz@Respondent Fu/Kzkfjrh Dh Vksj Ls@ Assessee By : Shri S.R. Sharma (Ca) & Shri Rajnikant Bhatra (Ca) Jktlo Dh Vksj Ls@ Revenue By : Smt. Rooni Paul (Addl.Cit) Lquokbz Dh Rkjh[K@ Date Of Hearing : 02/12/2020 Mn?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 18/01/2021 Vkns'K@ Order Per: Sandeep Gosain, J.M. These Are The Appeal Filed By The Assessee & The Cross Appeal Filed By The Revenue Arise Against The Order Of The Ld. Cit(A)-4, Jaipur Dated 08/11/2019 For The A.Y. 2010-11. The Grounds Taken By The Assessee & The Revenue Are As Under:

For Appellant: Shri S.R. Sharma (CA) &For Respondent: Smt. Rooni Paul (Addl.CIT)

Section 132Section 143Section 143(3)Section 145(3)Section 147Section 148

…ments as furnished by assessee in assessment proceedings were held as genuine and not bogus. However, the A.O. for made disallowance of 25% of alleged purchases of Rs. 11,60,43,873/- by relying on judgement in case of Sanjay Oil Cake Industries Vs. CIT (2008) 10 DTR 153 (Guj.). From the facts of the present case, we found that judgement of Sanjay 21 ITA 1383/JP/2019 & 09/JP/2020_ Sh. Sunder Das Sonkia Vs ITO Oil Cake Industries (supra) is not applicable to the facts of the present case. The facts of the said case were different from the case of the assessee and that distinction has been mentioned hereinbelow: F…