INCOME TAX OFFICER, WARD-1(8), BHAVNAGAR, BHAVNAGAR vs. MADHAV COPPER LIMITED, BHAVNAGAR

In the result, all six appeals, three by the Revenue and three by the assessee, stand dismissed

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokar

Section of AO’s Order 147 r.w.s. 143(3) r.w.s. 143(3) r.w.s. 144B 144B 144B Amount of Alleged Bogus 92,95,26,352/- 49,84,90,503/- 412,48,43,029/- Purchases added (Rs.) Gross Profit Rate Applied by AO 12.50% 12.50% 12.50% Addition Made

M/S. GSP CROP SCIENCE PVT. LTD.,,AHMEDABAD vs. THE DCIT, CIRCLE-2(1)(1),, AHMEDABAD

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

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

10 16. Coming to the submissions made by the ld.counsel for the assessee, we note that, he had contended that no credence could be given to the statement of entry providers or for that matter, Shri Kamal Jhaveri for the reasons that – i. he had not named the assessee as one of the beneficiaries of the bogus bills

M/S. GSP CROP SCIENCE PVT. LTD.,,AHMEDABAD vs. THE DCIT, CIRCLE-2(1)(1),, AHMEDABAD

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

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

10 16. Coming to the submissions made by the ld.counsel for the assessee, we note that, he had contended that no credence could be given to the statement of entry providers or for that matter, Shri Kamal Jhaveri for the reasons that – i. he had not named the assessee as one of the beneficiaries of the bogus bills

BHAGAT MARKETING PVT LTD,AHMEDABAD vs. PCIT-1, AHMEDABAD

In the result, in light of the above observations and the judicial precedents on the subject, the appeal of the assessee is allowed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

bogus purchases in accordance with law and thus revision under section. 263 is nothing but a change of opinion and hence order u/s. 263 is bad in law. 2. The directions given to AO in para 7, 7.1 and 8 of order under section 263 by the ld. Pr.CIT are already carried

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1, BHAVNAGAR, BHAVNAGAR vs. RUDRA GLOBAL INFRA PRODUCTS LIMITED, BHAVNAGAR

In the result, the appeal of the Revenue as well as the Cross-Objection filed by the assessee, both are dismissed

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

section 250 of the Income-tax Act, 1961 [“the Act”] for the Assessment Year (AY) 2022-23. 2. The sole grievance of the Revenue reads as under:- “Whether the CIT (A) has erred in facts and law in deleting the addition of Rs. 41,71,10,137/- being non-genuine and bogus purchases, without appreciating the fact that the assessee

DHARMESSH SHAH,AHMEDABAD vs. THE ITO, WARD-1, PATAN

In the result the appeal of the assessee is partly allowed

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2019-20 Dharmessh Shah The Ito, Ward-1 A-301, Vasantkunj Vs Patan. Garden Residency Sanjivan Road Paldi, Ahmedabad. Pan : Aelps 5203 A (Applicant) (Responent) : Shri Kunal T. Sanghavi, Ar Assessee By : Shri Prathvij Raj Meena, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 30/04/2025 घोषणा क" तारीख /Date Of Pronouncement: 05/05/2025 आदेश आदेश/O R D E R आदेश आदेश

bogus Input Tax Credit. The AO issued notice under section 148A(b), duly considered the assessee's response, and passed an order under section 148A(d), followed by issue of notice under section 148. The Ld. CIT(A) has upheld the validity of such reopening by relying on Explanation 1(i) to Section 148 of the Act, which was inserted

ESPEE PHARMA CHEM PVT. LTD.,AHMEDABAD vs. THE ITO, WARD-2(1)(1), AHMEDABAD

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

Bench: Ms. Suchitra Raghunath Kamble & Shri Narendra Prasad Sinhaassessment Year:2019-20

bogus purchase u/s 69C, if any, should be curtailed to the profit element in it and not the entire amount of purchase which has been done in the present case, it be held as such and the additions be deleted to that extent. 9 The AO erred in passing the impugned order dated 26

HAJIMOHMADSAFI ABDULREHMAN SHAIKH,VADODARA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 2(1)(1), VADODARA

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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

bogus purchases had been set aside in entirety by the Hon’ble ITAT for fresh adjudication and therefore the earlier relief granted by the CIT(A) stood merged with the order of the Tribunal. It was observed that the Assessing Officer had rightly re-examined the entire issue in accordance with the directions of the ITAT and hence the contention

HAJIMOHMADSAFI ABDULREHMAN SHAIKH,VADODARA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 2(1)(1), VADODARA

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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

bogus purchases had been set aside in entirety by the Hon’ble ITAT for fresh adjudication and therefore the earlier relief granted by the CIT(A) stood merged with the order of the Tribunal. It was observed that the Assessing Officer had rightly re-examined the entire issue in accordance with the directions of the ITAT and hence the contention

HAJIMOHMADSAFI ABDULREHMAN SHAIKH,VADODARA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 2(1)(1), VADODARA

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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

bogus purchases had been set aside in entirety by the Hon’ble ITAT for fresh adjudication and therefore the earlier relief granted by the CIT(A) stood merged with the order of the Tribunal. It was observed that the Assessing Officer had rightly re-examined the entire issue in accordance with the directions of the ITAT and hence the contention

HAJIMOHMADSAFI ABDULREHMAN SHAIKH,VADODARA vs. DEPUTY COMISSIONER OF INCOME TAX, CIRCLE 2(1)(1), VADODARA

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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

bogus purchases had been set aside in entirety by the Hon’ble ITAT for fresh adjudication and therefore the earlier relief granted by the CIT(A) stood merged with the order of the Tribunal. It was observed that the Assessing Officer had rightly re-examined the entire issue in accordance with the directions of the ITAT and hence the contention

CONCORD BIOTECH LTD.,AHMEDABAD vs. THE DY.CIT, CIRCLE-1(1)(1), AHMEDABAD

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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

section 147 by making an addition of Rs. 37,39,250/- treating the same as bogus purchases, and assessed the total income at Rs. 1,15,55,22,678/- vide order dated 29.03.2022. 4. Aggrieved by the reassessment order, the assessee preferred an appeal before the Commissioner of Income-tax (Appeals). Before the CIT(A), the assessee contended that

THE ITO, WARD-1(2)(3), AHMEDABAD vs. SHRI MAHESH SOMABHAI PATEL, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

26-03-2024 Date of pronouncement : 19-06-2024 आदेश/ORDER PER : T.R. SENTHIL KUMAR, JUDICIAL MEMBER:- This appeal is filed by the Revenue as against the appellate order dated 06.11.2019 passed by the Commissioner of Income Tax (Appeals)-10, Ahmedabad, arising out of the assessment order passed under section 143(3) of the Income Tax Act, 1961 (hereinafter referred

THE DY. CIT, CIRCLE-1(1)(2),, AHMEDABAD vs. JMC PROJECTS (INDIA) LIMITED,, AHMEDABAD

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

10. We have heard the rival contentions and perused the material on records. The additional ground raised by the assessee for A.Y. 2009-10 and A.Y. 2010-11 challenges the validity of assessments framed under section 143(3) read with section 153A of the Act, in the absence of incriminating material for unabated years. The essence of the dispute

THE ACIT,(OSD)-I,RANGE-4,, AHMEDABAD vs. JMC PROJECTS (INDIA) LTD.,, AHMEDABAD

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

10. We have heard the rival contentions and perused the material on records. The additional ground raised by the assessee for A.Y. 2009-10 and A.Y. 2010-11 challenges the validity of assessments framed under section 143(3) read with section 153A of the Act, in the absence of incriminating material for unabated years. The essence of the dispute

THE DY. CIT, CIRCLE-1(1)(2),, AHMEDABAD vs. JMC PROJECTS (INDIA) LIMITED,, AHMEDABAD

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

10. We have heard the rival contentions and perused the material on records. The additional ground raised by the assessee for A.Y. 2009-10 and A.Y. 2010-11 challenges the validity of assessments framed under section 143(3) read with section 153A of the Act, in the absence of incriminating material for unabated years. The essence of the dispute

JMC PROJECTS (INDIA) LTD.,,AHMEDABAD vs. THE ACIT, CENTRAL CIRCLE-1(1),, AHMEDABAD

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

10. We have heard the rival contentions and perused the material on records. The additional ground raised by the assessee for A.Y. 2009-10 and A.Y. 2010-11 challenges the validity of assessments framed under section 143(3) read with section 153A of the Act, in the absence of incriminating material for unabated years. The essence of the dispute

THE ACIT,(OSD)-I,RANGE-4,, AHMEDABAD vs. JMC PROJECTS (INDIA) LTD.,, AHMEDABAD

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

10. We have heard the rival contentions and perused the material on records. The additional ground raised by the assessee for A.Y. 2009-10 and A.Y. 2010-11 challenges the validity of assessments framed under section 143(3) read with section 153A of the Act, in the absence of incriminating material for unabated years. The essence of the dispute