Vijay Trading Co. v. ITO

388 ITR 377High Court2016#889 most cited

What is Vijay Trading Co. v. ITO authority for?

When purchases are found bogus, only the profit element embedded therein, and not the entire purchase value, can be added to the assessee's income.

119

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2018 to 2026.

Also referred to as

Vijay Trading Co v ITO · bogus purchases · entire purchases addition · profit element · gross profit addition · restricted disallowance · Section 37(1) · Section 69B · genuineness of purchases · Gujarat High Court

Also reported as

76 Taxmann.com 366

Sections most often in play

Section 115BBE Section 153C Section 37(1)Section 131 Section 44AB Section 69B Section 132(4A)Section 133A

Issues it is cited on

section 142(3)section 89 section 147of section 142(2)section 69d section 292c section 69b section 33(4)audi alteram partem section 292 section 34(1)section 149(1)(b)

Judgments citing Vijay Trading Co. v. ITO

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

…t the assessee in relation to the questions at the instance of the assessee, and in favour of the assessee and against the Revenue in relation to the questions at the instance of the Revenue.” In the case of Vijay Trading Co. vs. ITO reported in (iv) (2016) 388 ITR 377 (Guj), the Hon’ble Gujarat High Court Lf has held as under: “Held, that it was not the entire amount covered by such purchase, but the profit element embedded therein which would be subject to tax. It would be appropriate to restrict the disallowance made in this regard to 25 per cent of the cost of such purchases in each year.” (v) In the case…

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

…t the assessee in relation to the questions at the instance of the assessee, and in favour of the assessee and against the Revenue in relation to the questions at the instance of the Revenue.” In the case of Vijay Trading Co. vs. ITO reported in (iv) (2016) 388 ITR 377 (Guj), the Hon’ble Gujarat High Court Lf has held as under: “Held, that it was not the entire amount covered by such purchase, but the profit element embedded therein which would be subject to tax. It would be appropriate to restrict the disallowance made in this regard to 25 per cent of the cost of such purchases in each year.” (v) In the case…

DCIT, CC-20, New Delhi vs. Devesh Mittal, Delhi

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

ITA 943/DEL/2022[2016-17]Status: DisposedITAT Delhi30 May 2024AY 2016-17

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

…t the assessee in relation to the questions at the instance of the assessee, and in favour of the assessee and against the Revenue in relation to the questions at the instance of the Revenue.” In the case of Vijay Trading Co. vs. ITO reported in (iv) (2016) 388 ITR 377 (Guj), the Hon’ble Gujarat High Court Lf has held as under: “Held, that it was not the entire amount covered by such purchase, but the profit element embedded therein which would be subject to tax. It would be appropriate to restrict the disallowance made in this regard to 25 per cent of the cost of such purchases in each year.” (v) In the case…

DCIT, CC-20, New Delhi vs. Devesh Mittal, Delhi

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

ITA 942/DEL/2022[2015-16]Status: DisposedITAT Delhi30 May 2024AY 2015-16

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

…t the assessee in relation to the questions at the instance of the assessee, and in favour of the assessee and against the Revenue in relation to the questions at the instance of the Revenue.” In the case of Vijay Trading Co. vs. ITO reported in (iv) (2016) 388 ITR 377 (Guj), the Hon’ble Gujarat High Court Lf has held as under: “Held, that it was not the entire amount covered by such purchase, but the profit element embedded therein which would be subject to tax. It would be appropriate to restrict the disallowance made in this regard to 25 per cent of the cost of such purchases in each year.” (v) In the case…

DCIT, CC-20, New Delhi vs. Devesh Mittal, Delhi

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

ITA 941/DEL/2022[2014-15]Status: DisposedITAT Delhi30 May 2024AY 2014-15

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

…t the assessee in relation to the questions at the instance of the assessee, and in favour of the assessee and against the Revenue in relation to the questions at the instance of the Revenue.” In the case of Vijay Trading Co. vs. ITO reported in (iv) (2016) 388 ITR 377 (Guj), the Hon’ble Gujarat High Court Lf has held as under: “Held, that it was not the entire amount covered by such purchase, but the profit element embedded therein which would be subject to tax. It would be appropriate to restrict the disallowance made in this regard to 25 per cent of the cost of such purchases in each year.” (v) In the case…

DCIT, CC-20, New Delhi vs. Globus Agrofoods Pvt. Ltd., Delhi

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

ITA 940/DEL/2022[2016-17]Status: DisposedITAT Delhi30 May 2024AY 2016-17

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

…t the assessee in relation to the questions at the instance of the assessee, and in favour of the assessee and against the Revenue in relation to the questions at the instance of the Revenue.” In the case of Vijay Trading Co. vs. ITO reported in (iv) (2016) 388 ITR 377 (Guj), the Hon’ble Gujarat High Court Lf has held as under: “Held, that it was not the entire amount covered by such purchase, but the profit element embedded therein which would be subject to tax. It would be appropriate to restrict the disallowance made in this regard to 25 per cent of the cost of such purchases in each year.” (v) In the case…

DCIT, CC-20, New Delhi vs. Globus Agrofoods Pvt.Ltd., New Delhi

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

ITA 939/DEL/2022[2015-16]Status: DisposedITAT Delhi30 May 2024AY 2015-16

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

…t the assessee in relation to the questions at the instance of the assessee, and in favour of the assessee and against the Revenue in relation to the questions at the instance of the Revenue.” In the case of Vijay Trading Co. vs. ITO reported in (iv) (2016) 388 ITR 377 (Guj), the Hon’ble Gujarat High Court Lf has held as under: “Held, that it was not the entire amount covered by such purchase, but the profit element embedded therein which would be subject to tax. It would be appropriate to restrict the disallowance made in this regard to 25 per cent of the cost of such purchases in each year.” (v) In the case…

DCIT, CC-20, New Delhi vs. Kwality Techmech Pvt. Ltd., Delhi

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

ITA 938/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

…t the assessee in relation to the questions at the instance of the assessee, and in favour of the assessee and against the Revenue in relation to the questions at the instance of the Revenue.” In the case of Vijay Trading Co. vs. ITO reported in (iv) (2016) 388 ITR 377 (Guj), the Hon’ble Gujarat High Court Lf has held as under: “Held, that it was not the entire amount covered by such purchase, but the profit element embedded therein which would be subject to tax. It would be appropriate to restrict the disallowance made in this regard to 25 per cent of the cost of such purchases in each year.” (v) In the case…

DCIT Central Circle-20, Delhi vs. Kwality Techmech Pvt. Ltd., Delhi

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

ITA 937/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

…t the assessee in relation to the questions at the instance of the assessee, and in favour of the assessee and against the Revenue in relation to the questions at the instance of the Revenue.” In the case of Vijay Trading Co. vs. ITO reported in (iv) (2016) 388 ITR 377 (Guj), the Hon’ble Gujarat High Court Lf has held as under: “Held, that it was not the entire amount covered by such purchase, but the profit element embedded therein which would be subject to tax. It would be appropriate to restrict the disallowance made in this regard to 25 per cent of the cost of such purchases in each year.” (v) In the case…

DCIT, New Delhi vs. Parmanand and Sons Foods Products P.Ltd, New Delhi

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

ITA 934/DEL/2022[2016-17]Status: DisposedITAT Delhi30 May 2024AY 2016-17

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

…t the assessee in relation to the questions at the instance of the assessee, and in favour of the assessee and against the Revenue in relation to the questions at the instance of the Revenue.” In the case of Vijay Trading Co. vs. ITO reported in (iv) (2016) 388 ITR 377 (Guj), the Hon’ble Gujarat High Court Lf has held as under: “Held, that it was not the entire amount covered by such purchase, but the profit element embedded therein which would be subject to tax. It would be appropriate to restrict the disallowance made in this regard to 25 per cent of the cost of such purchases in each year.” (v) In the case…

DCIT, New Delhi vs. Parmanand and Sons Foods Products P.Ltd, Delhi

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

ITA 933/DEL/2022[2015-16]Status: DisposedITAT Delhi30 May 2024AY 2015-16

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

…t the assessee in relation to the questions at the instance of the assessee, and in favour of the assessee and against the Revenue in relation to the questions at the instance of the Revenue.” In the case of Vijay Trading Co. vs. ITO reported in (iv) (2016) 388 ITR 377 (Guj), the Hon’ble Gujarat High Court Lf has held as under: “Held, that it was not the entire amount covered by such purchase, but the profit element embedded therein which would be subject to tax. It would be appropriate to restrict the disallowance made in this regard to 25 per cent of the cost of such purchases in each year.” (v) In the case…

DCIT, Central Circle-20, New Delhi vs. Paramanand and Sons Foods Products Pvt. Ltd., Delhi

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

ITA 932/DEL/2022[2014-15]Status: DisposedITAT Delhi30 May 2024AY 2014-15

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

…t the assessee in relation to the questions at the instance of the assessee, and in favour of the assessee and against the Revenue in relation to the questions at the instance of the Revenue.” In the case of Vijay Trading Co. vs. ITO reported in (iv) (2016) 388 ITR 377 (Guj), the Hon’ble Gujarat High Court Lf has held as under: “Held, that it was not the entire amount covered by such purchase, but the profit element embedded therein which would be subject to tax. It would be appropriate to restrict the disallowance made in this regard to 25 per cent of the cost of such purchases in each year.” (v) In the case…

DCIT, CC-20, New Delhi vs. Paramanand and Sons Foods Products Pvt. Ltd., New Delhi

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

ITA 931/DEL/2022[2013-14]Status: DisposedITAT Delhi30 May 2024AY 2013-14

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

…t the assessee in relation to the questions at the instance of the assessee, and in favour of the assessee and against the Revenue in relation to the questions at the instance of the Revenue.” In the case of Vijay Trading Co. vs. ITO reported in (iv) (2016) 388 ITR 377 (Guj), the Hon’ble Gujarat High Court Lf has held as under: “Held, that it was not the entire amount covered by such purchase, but the profit element embedded therein which would be subject to tax. It would be appropriate to restrict the disallowance made in this regard to 25 per cent of the cost of such purchases in each year.” (v) In the case…

DCIT, Central Circle-20, New Delhi vs. Parmanand and Sons Foods Products Pvt. Ltd., Delhi

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

ITA 930/DEL/2022[2012-13]Status: DisposedITAT Delhi30 May 2024AY 2012-13

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

…t the assessee in relation to the questions at the instance of the assessee, and in favour of the assessee and against the Revenue in relation to the questions at the instance of the Revenue.” In the case of Vijay Trading Co. vs. ITO reported in (iv) (2016) 388 ITR 377 (Guj), the Hon’ble Gujarat High Court Lf has held as under: “Held, that it was not the entire amount covered by such purchase, but the profit element embedded therein which would be subject to tax. It would be appropriate to restrict the disallowance made in this regard to 25 per cent of the cost of such purchases in each year.” (v) In the case…

Parmanand & Sons Food Products Pvt. Ltd., Delhi vs. ACIT Central Circle-20, Delhi

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

ITA 722/DEL/2022[2016-17]Status: DisposedITAT Delhi30 May 2024AY 2016-17

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

…t the assessee in relation to the questions at the instance of the assessee, and in favour of the assessee and against the Revenue in relation to the questions at the instance of the Revenue.” In the case of Vijay Trading Co. vs. ITO reported in (iv) (2016) 388 ITR 377 (Guj), the Hon’ble Gujarat High Court Lf has held as under: “Held, that it was not the entire amount covered by such purchase, but the profit element embedded therein which would be subject to tax. It would be appropriate to restrict the disallowance made in this regard to 25 per cent of the cost of such purchases in each year.” (v) In the case…

Parmanand & Sons Food Products Pvt. Ltd., Delhi vs. ACIT Central Circle-20, Delhi

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

ITA 721/DEL/2022[2015-16]Status: DisposedITAT Delhi30 May 2024AY 2015-16

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

…t the assessee in relation to the questions at the instance of the assessee, and in favour of the assessee and against the Revenue in relation to the questions at the instance of the Revenue.” In the case of Vijay Trading Co. vs. ITO reported in (iv) (2016) 388 ITR 377 (Guj), the Hon’ble Gujarat High Court Lf has held as under: “Held, that it was not the entire amount covered by such purchase, but the profit element embedded therein which would be subject to tax. It would be appropriate to restrict the disallowance made in this regard to 25 per cent of the cost of such purchases in each year.” (v) In the case…

Parmanand & Sons Food Products Pvt. Ltd., Delhi vs. ACIT Central Circle-20, Delhi

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

ITA 720/DEL/2022[2014-15]Status: DisposedITAT Delhi30 May 2024AY 2014-15

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

…t the assessee in relation to the questions at the instance of the assessee, and in favour of the assessee and against the Revenue in relation to the questions at the instance of the Revenue.” In the case of Vijay Trading Co. vs. ITO reported in (iv) (2016) 388 ITR 377 (Guj), the Hon’ble Gujarat High Court Lf has held as under: “Held, that it was not the entire amount covered by such purchase, but the profit element embedded therein which would be subject to tax. It would be appropriate to restrict the disallowance made in this regard to 25 per cent of the cost of such purchases in each year.” (v) In the case…

Parmanand & Sons Food Products Pvt. Ltd., Delhi vs. ACIT Central Circle-20, Delhi

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

ITA 719/DEL/2022[2013-14]Status: DisposedITAT Delhi30 May 2024AY 2013-14

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

…t the assessee in relation to the questions at the instance of the assessee, and in favour of the assessee and against the Revenue in relation to the questions at the instance of the Revenue.” In the case of Vijay Trading Co. vs. ITO reported in (iv) (2016) 388 ITR 377 (Guj), the Hon’ble Gujarat High Court Lf has held as under: “Held, that it was not the entire amount covered by such purchase, but the profit element embedded therein which would be subject to tax. It would be appropriate to restrict the disallowance made in this regard to 25 per cent of the cost of such purchases in each year.” (v) In the case…

Parmanand & Sons Food Products Pvt. Ltd., Delhi vs. ACIT Central Circle-20, Delhi

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

ITA 718/DEL/2022[2012-13]Status: DisposedITAT Delhi30 May 2024AY 2012-13

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

…t the assessee in relation to the questions at the instance of the assessee, and in favour of the assessee and against the Revenue in relation to the questions at the instance of the Revenue.” In the case of Vijay Trading Co. vs. ITO reported in (iv) (2016) 388 ITR 377 (Guj), the Hon’ble Gujarat High Court Lf has held as under: “Held, that it was not the entire amount covered by such purchase, but the profit element embedded therein which would be subject to tax. It would be appropriate to restrict the disallowance made in this regard to 25 per cent of the cost of such purchases in each year.” (v) In the case…

Devesh Mittal, Delhi vs. DCIT, CC-20, Delhi

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

ITA 717/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

…t the assessee in relation to the questions at the instance of the assessee, and in favour of the assessee and against the Revenue in relation to the questions at the instance of the Revenue.” In the case of Vijay Trading Co. vs. ITO reported in (iv) (2016) 388 ITR 377 (Guj), the Hon’ble Gujarat High Court Lf has held as under: “Held, that it was not the entire amount covered by such purchase, but the profit element embedded therein which would be subject to tax. It would be appropriate to restrict the disallowance made in this regard to 25 per cent of the cost of such purchases in each year.” (v) In the case…