MANMOHAN PRAVINCHANDRA MADANI,AHMEDABAD vs. THE ITIO, WARD-3(2)(10), AHMEDABAD

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

bogus. He has\nalso not conducted any verification or inquiry with customers, nor has he\ndisproved the inventory or purchase records. Merely relying on the\ncomparative analysis of deposits before and during the demonetization period\nis not sufficient to treat the cash

PINKESH SUBHASHCHANDRA PATEL,ANAND vs. THE INCOME TAX OFFICER, WARD-1(3)(1), PETLAD

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

Bench: Smt. Annapurna Guptaआयकर अपील सं./I.T.A. No. 391/Ahd/2024 ("नधा"रण वष" / Assessment Year : 2017-18) बनाम/ Pinkesh Subhashchandra The Income Tax Officer Patel Ward-1(3)(1), Petlad Vs. 116, Sardar Chowk, Near Dairy, Tal. Petlad, Bharel, Dist. Anand, Gujarat 388480 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Bgrpp8413J (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Shri Dhrunal Bhatt, Ar. ""यथ" क" ओर से/Respondent By : Shri Prateek Sharma, Sr. Dr 04/02/2025 Date Of Hearing Date Of Pronouncement 30/04/2025 O R D E R The Present Appeal Has Been Filed By The Assessee Against The Order Passed By The Commissioner Of Income Tax(Appeals), National Faceless Appeal Centre (Nfac), Delhi (In Short ‘The Cit(A)’) Under Section 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) Dated 02.02.2024 Pertaining To Assessment Year 2017- 18. 2. The Grounds Raised In The Appeal By The Assessee Are As Under:

bogus and no such cash was received by the assessee. The statement recorded on oath is reproduced hereunder for sake of clarity. ITA No. 391/Ahd/2024 [Pinkesh Subhashchandra Patel vs. ITO] A.Y. 2017-18 - 7 – d) Now the last source given by the assessee for cash deposition perused and found false. The assessee stated that some cash was deposited from Chandla

HARSHVARDHAN T.SONI,DAHOD vs. THE ACIT, PANCHAMAHAL CIRCLE, GODHRA PRESENT JURISDICTION THE ACIT., ANAND CIRCLE,, ANAND

In the result, the appeal of the assessee is allowed

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

cash deposits were such small amounts. The appellant has claimed that the gold that was sold was bought from two parties of Mumbai. There is no evidence that how that gold was transferred to the appellant just before the sale. It is also surprising that the payment of the purported purchase was made after the appellant had sold the gold

SHALIN RAJENDRAKUMAR SHAH,AHMEDABAD vs. THE ITO, WARD-5(3)(2), AHMEDABAD

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

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

deposits with retail sales bill with name of the customers. Thus, the initial burden is fully discharged by the assessee. Whereas the Ld. A.O. without rejection of books of accounts and without enquiry with the purchaser of smaller denominations, made the additions which is not sustainable in law. 7.1. Further the sales are found recorded in the sales register, stock

ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), AHMEDABAD vs. REKHA INDRAVADAN CHOKSHI, AHMEDABAD

In the result, the Department’s appeal is dismissed

Bench: Smt. Annapurna Gupta (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

bogus and these entries of purchases have been created only to create stock in books of the assessee in order to accommodate cash sales and in order to generate cash that was deposited

REKHABEN INDRAVADAN CHOKSHI,AHMEDABAD vs. INCOME TAX OFFICER,WARD-5(2)(4), AHMEDABAD

In the result, the Department’s appeal is dismissed

Bench: Smt. Annapurna Gupta (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

bogus and these entries of purchases have been created only to create stock in books of the assessee in order to accommodate cash sales and in order to generate cash that was deposited

MOHD. NAUSHAD ANSARI (PROP. GULSAN SEV FOODS),AHMEDABAD vs. THE ITO, WARD-5(3)(3), AHMEDABAD

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

Bench: Ms.Suchitra R. Kamble & Shri Makarand V.Mahadeokarasstt.Year : 2017-18 Mohd Naushad Ansari The Ito, Ward-5(3)(3) Prop: Gulsan Sev Foods Vs. Anandnagar Road 51, Pujara Ni Chali Ahmedabad. Nr.Sarangpur Bridge Kamdar Medan – Gomtipur Ahmedabad 380 021 Pan: Aiwpa 6480 G (Applicant) (Responent) : Shri M.K. Patel, Ar Assessee By : Shri Amit Pratap Singh, Sr.Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 28/07/2025 घोषणा क" तारीख /Date Of Pronouncement: 30/07/2025 आदेश आदेश/O R D E R आदेश आदेश Per Makarand V.Mahadeokar, Am: This Appeal By The Assessee Is Directed Against The Order Dated 29.01.2025 Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As “Cit(A)”], Under Section 250 Of The Income-Tax Act, 1961 [Hereinafter Referred To As “The Act”], Confirming The Addition Of Rs.28,54,000/- Made By The Assessing Officer Under Section 68 Of The Act In Respect Of Cash Deposits Made In The Bank Accounts Of The Assessee During The Demonetisation Period. The Assessment Was Completed Under Section 143(3) Of The Act By The Income Tax Officer, Ward 5(3)(3), Ahmedabad [Hereinafter Referred To As “Assessing Officer Or Ao”], Vide Order Dated 29.12.2019. 2. Facts Of The Case 2

purchase ledger, and certain confirmations, in compliance with the various notices issued under section 142(1) of the Act. The AR submitted that despite such documentary record being placed on file, the Assessing Officer concluded 4 that the assessee had failed to satisfactorily explain the source of the cash deposits made during the demonetisation period, without assigning any cogent reasons

INCOME TAX OFFICER, WARD-1(3)(1), AHMEDABAD, AHMEDABAD vs. RAMESHKUMAR MELAPCHAND SHAH, AHMEDABAD

In the result, the appeal filed by the Revenue in ITA No

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

deposited in various bank accounts as credits not satisfactorily explained. The AO during the course of assessment proceedings has inferred that claim of the appellant stating that the same was cash in hand as per cash book which was sourced by the sales was unacceptable and correspondingly the purchase were bogus

RAMESHKUMAR MELAPCHAND SHAH,AHMEDABAD vs. THE ITO, WARD-5(2)(4), AHMEDABAD

In the result, the appeal filed by the Revenue in ITA No

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

deposited in various bank accounts as credits not satisfactorily explained. The AO during the course of assessment proceedings has inferred that claim of the appellant stating that the same was cash in hand as per cash book which was sourced by the sales was unacceptable and correspondingly the purchase were bogus

KAUSHIK PRAVINCHANDRA GOHEL,BHAVNAGAR vs. THE ASSESSING OFFICER, WARD-1(2), BHAVNAGAR

In the result, the appeal of the assessee is allowed with respect to levy of penalty under Section 271(1)(b) of the Act for A

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

cash deposits made in these accounts are subsequently transferred to ITA Nos.690 to 694/Ahd/2023 Kaushik Pravinchandra Gohel vs. Assessing Officer Asst.Years– 2015-16 to 2017-18 bank accounts of shell entities. The funds are subsequently being remitted abroad by these shell entities for prima facie bogus imports etc. Accordingly, even as per the report of the Investigation Wing, Renukamata Society

KAUSHIK PRAVINCHANDRA GOHEL,BHAVNAGAR vs. THE ASSESSING OFFICER, WARD-1(2), BHAVNAGAR

In the result, the appeal of the assessee is allowed with respect to levy of penalty under Section 271(1)(b) of the Act for A

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

cash deposits made in these accounts are subsequently transferred to ITA Nos.690 to 694/Ahd/2023 Kaushik Pravinchandra Gohel vs. Assessing Officer Asst.Years– 2015-16 to 2017-18 bank accounts of shell entities. The funds are subsequently being remitted abroad by these shell entities for prima facie bogus imports etc. Accordingly, even as per the report of the Investigation Wing, Renukamata Society

KAUSHIK PRAVINCHANDRA GOHEL,BHAVNAGAR vs. THE ASSESSING OFFICER, WARD-1(2), BHAVNAGAR

In the result, the appeal of the assessee is allowed with respect to levy of penalty under Section 271(1)(b) of the Act for A

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

cash deposits made in these accounts are subsequently transferred to ITA Nos.690 to 694/Ahd/2023 Kaushik Pravinchandra Gohel vs. Assessing Officer Asst.Years– 2015-16 to 2017-18 bank accounts of shell entities. The funds are subsequently being remitted abroad by these shell entities for prima facie bogus imports etc. Accordingly, even as per the report of the Investigation Wing, Renukamata Society

KAUSHIK PRAVINCHANDRA GOHEL,BHAVNAGAR vs. THE ASSESSING OFFICER, WARD-1(2), BHAVNAGAR

In the result, the appeal of the assessee is allowed with respect to levy of penalty under Section 271(1)(b) of the Act for A

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

cash deposits made in these accounts are subsequently transferred to ITA Nos.690 to 694/Ahd/2023 Kaushik Pravinchandra Gohel vs. Assessing Officer Asst.Years– 2015-16 to 2017-18 bank accounts of shell entities. The funds are subsequently being remitted abroad by these shell entities for prima facie bogus imports etc. Accordingly, even as per the report of the Investigation Wing, Renukamata Society

KAUSHIK PRAVINCHANDRA GOHEL,BHAVNAGAR vs. THE ASSESSING OFFICER, WARD-1(2), BHAVNAGAR

In the result, the appeal of the assessee is allowed with respect to levy of penalty under Section 271(1)(b) of the Act for A

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

cash deposits made in these accounts are subsequently transferred to ITA Nos.690 to 694/Ahd/2023 Kaushik Pravinchandra Gohel vs. Assessing Officer Asst.Years– 2015-16 to 2017-18 bank accounts of shell entities. The funds are subsequently being remitted abroad by these shell entities for prima facie bogus imports etc. Accordingly, even as per the report of the Investigation Wing, Renukamata Society

THE ACIT, MEHSANA CIRCLE, MEHSANA vs. SHRI UMESH VADILAL KHAMAR, MEHSANA

In the result, the appeal of the Revenue is dismissed

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar

bogus purchases. Rs. 2,21,48,539/- Cash payments. Rs. 1,80,13,314/- Unexplained source of Cash Deposits. Rs. 5,88,584/- Disallowed

KRUTIKA ASHWIN SARVAIYA,AHMEDABAD vs. THE ITO, WARD-5(3)(4), AHMEDABAD

In the result, the appeal of the assessee in ITA

Bench: Shri Ramit Kochar (Accountant Member)

purchaser. The A.O. proposed to make addition with respect to cash deposited during the demonetization period amounting to Rs.20 Lacs under the provisions of Section 69A of the Act. The A.O. at Para No. 5 has stated that the reply filed by the assessee is reproduced hereunder but no such reply was reproduced by A.O. at para

MANISH N. AMIN,AHMEDABAD vs. THE ITO, WARD-3(3)(2), AHMEDABAD

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

Bench: Shri Tr Senthil Kumar & Shri Narendra Prasad Sinhaassessment Years: 2017-18

deposits. Ground No. 5-No Adverse Finding on Sales 5. The learned CIT(A) failed to appreciate that there was no finding that the sales were bogus, fictitious, or outside the books, and therefore the source of cash stood fully explained, making the invocation of section 69A wholly unsustainable. Ground No. 6- Violation of Principles of Natural Justice

FURNISH HOME,AHMEDABAD vs. THE ITO, WARD-3(3)(1) OLD WARD-3(3)(2), AHMEDABAD

The appeal of the asessee is allowed, whereas, Revenue’s appeal is dismissed

Bench: SHRI SANJAY GARG (Judicial Member), SMT. ANNAPURNA GUPTA (Accountant Member)

deposited in the bank account of the assessee and finding no merit in the reasoning of the Ld. CIT(A) for confirming the addition made on this account to the tune of Rs.6,96,360/-, we hold that the entire additions made on this account was grossly unjustified and direct deletion of the entire addition made to the income