“circular trading”

CHHAYA KETAN MEHTA,MUMBAI vs. INCOME TAX OFFICER - 33(1)(3), MUMBAI

In the result, the appeal is allowed

ndoubted genuineness of said transactions but also established how the\nprice of shares of the penny stock companies were rigged and were\nraised through circular trading. It was observed that the whole\ntransaction was pre-conceived resulting in creation of bogus claim and,\ntherefore, were sham. Accordingly, the alleged LTCG

DCIT, CENTRAL CIRCLE 7(1), MUMBAI vs. SUPERWAYS ENTERPRISES PRIVATE LIMITED, MUMBAI

In the result, Revenue's appeals are dismissed and assessee's appeals are\npartly allowed

that the purchase and sales transactions cannot\nbe termed as bogus transactions to generate accommodation entries. Though they\nmay be in the nature of circular trading carried out with the objective of increasing\nthe turnover to avail bank credit facilities.\n\nHe observed, through such transactions bank funds are made ... without carrying on any genuine business activities. He\nsubmitted, though learned First Appellate Authority agreed with the AO that the\nassessee is involved in circular trading, however, he has reversed the decision of the\nAO in rejecting the books of account. Proceeding further, he submitted, after\nconsidering all relevant facts

DCIT, CENTRAL CIRCLE 7(1), MUMBAI vs. SUPERWAYS ENTERPRISES PRIVATE LIMITED, MUMBAI

In the result, Revenue’s appeals are dismissed and assessee’s appeals are partly allowed

Bench: Shri Saktijit Dey & Shri Jagadish

sales transactions cannot be termed as bogus transactions to generate accommodation entries. Though they Superways Enerprises P. Ltd. may be in the nature of circular trading carried out with the objective of increasing the turnover to avail bank credit facilities. 10. He observed, through such transactions bank funds are made ... fund. Therefore, that will have no relevance from the point of view of income tax once it is established that income from such circular trading is disclosed to tax. He further observed that the accounts of the assessee have been duly audited both under the provisions of Income

DCIT, CENTRAL CIRCLE 7(1), MUMBAI vs. SUPERWAYS ENTERPRISES PRIVATE LIMITED, MUMBAI

In the result, Revenue’s appeals are dismissed and assessee’s appeals are partly allowed

Bench: Shri Saktijit Dey & Shri Jagadish

sales transactions cannot be termed as bogus transactions to generate accommodation entries. Though they Superways Enerprises P. Ltd. may be in the nature of circular trading carried out with the objective of increasing the turnover to avail bank credit facilities. 10. He observed, through such transactions bank funds are made ... fund. Therefore, that will have no relevance from the point of view of income tax once it is established that income from such circular trading is disclosed to tax. He further observed that the accounts of the assessee have been duly audited both under the provisions of Income

DCIT, CENTRAL CIRCLE 7(1), MUMBAI vs. SUPERWAYS ENTERPRISES PRIVATE LIMITED, MUMBAI

In the result, Revenue’s appeals are dismissed and assessee’s appeals are partly allowed

Bench: Shri Saktijit Dey & Shri Jagadish

sales transactions cannot be termed as bogus transactions to generate accommodation entries. Though they Superways Enerprises P. Ltd. may be in the nature of circular trading carried out with the objective of increasing the turnover to avail bank credit facilities. 10. He observed, through such transactions bank funds are made ... fund. Therefore, that will have no relevance from the point of view of income tax once it is established that income from such circular trading is disclosed to tax. He further observed that the accounts of the assessee have been duly audited both under the provisions of Income

DCIT, CENTRAL CIRCLE 7(1), MUMBAI vs. SUPERWAYS ENTERPRISES PRIVATE LIMITED, MUMBAI

In the result, Revenue’s appeals are dismissed and assessee’s appeals are partly allowed

Bench: Shri Saktijit Dey & Shri Jagadish

sales transactions cannot be termed as bogus transactions to generate accommodation entries. Though they Superways Enerprises P. Ltd. may be in the nature of circular trading carried out with the objective of increasing the turnover to avail bank credit facilities. 10. He observed, through such transactions bank funds are made ... fund. Therefore, that will have no relevance from the point of view of income tax once it is established that income from such circular trading is disclosed to tax. He further observed that the accounts of the assessee have been duly audited both under the provisions of Income

SUPERWAYS ENTERPIRSES PRIVATE LIMITED ,MUMBAI vs. DCIT CENTRAL CIRCLE -7(1), MUMBAI

In the result, Revenue’s appeals are dismissed and assessee’s appeals are partly allowed

Bench: Shri Saktijit Dey & Shri Jagadish

sales transactions cannot be termed as bogus transactions to generate accommodation entries. Though they Superways Enerprises P. Ltd. may be in the nature of circular trading carried out with the objective of increasing the turnover to avail bank credit facilities. 10. He observed, through such transactions bank funds are made ... fund. Therefore, that will have no relevance from the point of view of income tax once it is established that income from such circular trading is disclosed to tax. He further observed that the accounts of the assessee have been duly audited both under the provisions of Income

SUPERWAYS ENTERPIRSES PRIVATE LIMITED ,MUMBAI vs. DCIT CENTRAL CIRCLE 7(1), MUMBAI

In the result, Revenue’s appeals are dismissed and assessee’s appeals are partly allowed

Bench: Shri Saktijit Dey & Shri Jagadish

sales transactions cannot be termed as bogus transactions to generate accommodation entries. Though they Superways Enerprises P. Ltd. may be in the nature of circular trading carried out with the objective of increasing the turnover to avail bank credit facilities. 10. He observed, through such transactions bank funds are made ... fund. Therefore, that will have no relevance from the point of view of income tax once it is established that income from such circular trading is disclosed to tax. He further observed that the accounts of the assessee have been duly audited both under the provisions of Income

SUPERWAYS ENTERPIRSES PRIVATE LIMITED ,MUMBAI vs. DCIT CENTRAL CIRCLE 7(1), MUMBAI

In the result, Revenue’s appeals are dismissed and assessee’s appeals are partly allowed

Bench: Shri Saktijit Dey & Shri Jagadish

sales transactions cannot be termed as bogus transactions to generate accommodation entries. Though they Superways Enerprises P. Ltd. may be in the nature of circular trading carried out with the objective of increasing the turnover to avail bank credit facilities. 10. He observed, through such transactions bank funds are made ... fund. Therefore, that will have no relevance from the point of view of income tax once it is established that income from such circular trading is disclosed to tax. He further observed that the accounts of the assessee have been duly audited both under the provisions of Income

SUPERWAYS ENTERPIRSES PRIVATE LIMITED ,MUMBAI vs. DCIT CENTRAL CIRCLE 7(1), MUMBAI

In the result, Revenue’s appeals are dismissed and assessee’s appeals are partly allowed

Bench: Shri Saktijit Dey & Shri Jagadish

sales transactions cannot be termed as bogus transactions to generate accommodation entries. Though they Superways Enerprises P. Ltd. may be in the nature of circular trading carried out with the objective of increasing the turnover to avail bank credit facilities. 10. He observed, through such transactions bank funds are made ... fund. Therefore, that will have no relevance from the point of view of income tax once it is established that income from such circular trading is disclosed to tax. He further observed that the accounts of the assessee have been duly audited both under the provisions of Income

SUPERWAYS ENTERPIRSES PRIVATE LIMITED LTD ,MUMBAI vs. DCIT CENTRAL CIRCLE 7(1), MUMBAI

purchase and sales transactions cannot\nbe termed as bogus transactions to generate accommodation entries. Though they\n\nmay be in the nature of circular trading carried out with the objective of increasing\nthe turnover to avail bank credit facilities.\n\nHe observed, through such transactions bank funds are made available ... carrying on any genuine business activities. He\n\nsubmitted, though learned First Appellate Authority agreed with the AO that the\nassessee is involved in circular trading, however, he has reversed the decision of the\nAO in rejecting the books of account. Proceeding further, he submitted, after\nconsidering all relevant facts

SUPERWAYS ENTERPIRSES PRIVATE LIMITED ,MUMBAI vs. DCIT CENTRAL CIRCLE 7(1), MUMBAI

In the result, Revenue’s appeals are dismissed and assessee’s appeals are partly allowed

Bench: Shri Saktijit Dey & Shri Jagadish

sales transactions cannot be termed as bogus transactions to generate accommodation entries. Though they Superways Enerprises P. Ltd. may be in the nature of circular trading carried out with the objective of increasing the turnover to avail bank credit facilities. 10. He observed, through such transactions bank funds are made ... fund. Therefore, that will have no relevance from the point of view of income tax once it is established that income from such circular trading is disclosed to tax. He further observed that the accounts of the assessee have been duly audited both under the provisions of Income

IMPRESSIVE TRADING PRIVATE LIMITED,MUMBAI vs. INCOME TAX OFFICER 10(1)(1), MUMBAI

In the result, all the above appeals in ITA Nos

Bench: Shri Narendra Kumar Choudhry & Shri Prabhash Shankar

Impressive Trading Pvt Ltd., Mumbai account maintained with Kotak Mahindra Bank. The assessee company was engaged in circular trading. Accordingly, certain part of the credit entries in bank account was determined as assessee’s undisclosed commission on percentage basis in all the assessment years, based on the report

IMPRESSIVE TRADING PRIVATE LIMITED,MUMBAI vs. INCOME TAX OFFICER 10(1)(1), MUMBAI

In the result, all the above appeals in ITA Nos

Bench: Shri Narendra Kumar Choudhry & Shri Prabhash Shankar

Impressive Trading Pvt Ltd., Mumbai account maintained with Kotak Mahindra Bank. The assessee company was engaged in circular trading. Accordingly, certain part of the credit entries in bank account was determined as assessee’s undisclosed commission on percentage basis in all the assessment years, based on the report

IMPRESSIVE TRADING PVT. LTD.,MUMBAI vs. INCOME TAX OFFICER 10(1)(1), MUMBAI

In the result, all the above appeals in ITA Nos

nA.Y. 2013-14, 2014-15 & 2015-16\nImpressive Trading Pvt Ltd., Mumbai\naccount maintained with Kotak Mahindra Bank. The assessee company\nwas engaged in circular trading. Accordingly, certain part of the credit\nentries in bank account was determined as assessee's undisclosed\ncommission on percentage basis in all the assessment

DCIT - 19(1), MUMBAI, LALBAUGH vs. BHARAT RAMJI BHAI MANEK, GRANT ROAD MUMBAI

In the result, the appeal of the revenue bearing ITA No

Bench: SHRI ANIKESH BANERJEE (Judicial Member), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

Operandi: The CIT(A) failed to consider the holistic picture painted by the Investigation Wing. The detailed modus operandi-preferential allotment, price rigging through circular trading, use of exit providers, and statements of entry operators like Shri Raj Kumar Kedia and Shri Anil Agarwal establishes a pre-meditated scheme

ASSISTANT COMMISSIONER OF INCOME TAX 32(1), MUMBAI vs. SUMAN GANDHI, MUMBAI

In the result, the appeal and the cross objection both are dismissed

Bench: Shri Saktijit Dey & Shri Arun Khodpiaasst. Cit-32(1) Suman Gandhi Room No. 252, Kautilya Bhavan, 2204/2205, Montereal Building, Bkc Bandra E, Vs. Shastri Nagar, Andheri (W), Mumbai-400 051 Mumbai-400 058 Pan/Gir No. Amzps 3507 P (Revenue) : (Assessee) Co No. 268/Mum/2025 (Arising Out Of Ita No. 3415/Mum/2025) (Assessment Year: 2014-15) Suman Gandhi Asst. Cit-32(1) 2204/2205, Montereal Building, Room No. 252, Kautilya Bhavan, Shastri Nagar, Andheri (W), Vs. Bkc Bandra E, Mumbai-400 058 Mumbai-400 051 Pan/Gir No. Amzps 3507 P (Assessee) : (Revenue) Assessee By : Shri K. Shivaram, Sr. Advocate & Shri Sashi Bekal Revenue By : Shri Swapnil Choudhary – Sr. Ar Date Of Hearing : 28.01.2026 Date Of Pronouncement : 29.01.2026 O R D E R Per Saktijit Dey: Captioned Appeal By The Department & Cross Objection By The Assessee, Arise Out Of Order Dated 20.03.2025, Passed By National Faceless Appeal Centre (‘Nfac’ For Short), Delhi For The Assessment Year (A.Y. For Short) 2014-15. 2

Assessing Officer noticed that there were instances of client code modifications. The Assessing Officer believed that the same was done to indulge in circular trading to pass on profits or losses to the clients of the assessee company as per requirements. After hearing the assessee, the Assessing Officer made additions

DCIT, CENTRAL CIRCLE 7(1), MUMBAI vs. SUPREME HOLDINGS & HOSPITALITY (INDIA) LIMITED, MUMBAI

In the result, all the appeals of the Revenue and Cross Objections by the assessee are dismissed

Bench: Shri Saktijit Dey & Shri Jagadish

same is confirmed. 16. The entire allegation of the ld. AO seems to be based on finding that these entities were doing some circular trading and they had defrauded the bank by adopting modus operandi of rotation of funds from one entity to another and misusing the LC facility from ... based on the statement recorded and finding of the search parties is that these groups were doing either bogus sales or purchases or circular trading to get LC from the bank. There might be movement of funds from one company to other and overdrawing the money from the banks through