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

purchases only miniscule payments were made in the year under consideration without even enquiring whether further payments were made in the subsequent years, the AO concluded that the transactions of bogus. The legal position in this regard is almost settled that once a notice u/s 133(6) is issued and the parties do not respond to the said notices

ACIT, CIRCLE-1, BHAVNAGAR, BHAVNAGAR vs. LEELA GREENSHIP RECYCLING PRIVATE LIMITED, BHAVNAGAR

In the result, both the appeals are treated as partly allowed for statistical purposes in terms of above directions

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No. 2111/Ahd/2024 िनधा"रण वष" /Assessment Year : 2018-19 Leela Greenship Recycling Pvt. Ltd., The Deputy Office No.303, 3Rd Floor, बनाम/ Commissioner V/S. B Wing, Leela Efcee, Of Income Tax, Near Aksharwadi Temple, Circle-1, Waghawadi Road, Bhavnagar. Bhavnagar-364002. "थायी लेखा सं./Pan: Aagcg8956L

bogus and as unexplained expenditure under section 69C of the Act, since the assessee utterly failed to establish the genuineness of such transactions during the reassessment proceedings. The DR emphasized that the proprietor of the said concern could not be traced during field inquiries and failed to respond to notices issued under section 133(6). Therefore, the very existence

LEELA GREENSHIP RECYCLING PVT. LTD.,BHAVNAGAR vs. THE DY. CIT, CIRCLE-1, BHAVNAGAR

In the result, both the appeals are treated as partly allowed for\nstatistical purposes in terms of above directions

bogus and as unexplained expenditure under section 69C of\nthe Act, since the assessee utterly failed to establish the genuineness of such\ntransactions during the reassessment proceedings. The DR emphasized that\nthe proprietor of the said concern could not be traced during field inquiries\nand failed to respond to notices issued under section 133(6). Therefore, the\nvery existence

BALDEVBHAI LALABHAI LUHAR,AHMEDABAD vs. INCOME TAX OFFICER, WARD-1(1)(2), PRATYAKSHAR BHAVAN,AHMEDABAD

In the result, the ground no

Bench: Shri Siddhartha Nautiyal & Shri Makarand Vasant Mahadeokar

133(6) issued to seven parties returned unserved and in case of five other parties, no reply was received. The assessee has not furnished the copies of delivery challan and transport receipt. In view of above, it is held that the purchase remained unverified and the AO has correctly rejected books of account and added GP of 4% on sales

RAJENDRAKUMAR CHHANALAL SHAH,MEHSANA vs. THE ITO, WARD-1, PATAN

In the result, the appeal of the assessee is allowed

Bench: Dr. B.R.R. Kumar, Vice-Shri T.R. Senthil Kumar

133(6) of the IT Act, 1961 to the parties however, no reply was submitted by any of the above parties for confirmation of purchases made by the assessee. Accordingly, AO disallowed 3 percent of total purchase considering it to be bogus purchase. 5.2 In response to the notice, the assessee submitted his reply on 24.12.2022, wherein the assessee submitted

ALANG STEEL RECYCLING PRIVATE LIMITED,BHAVNAGAR vs. THE DY.CIT, CIRCLE-1, BHAVNAGAR

The appeal of the assessee is allowed for statistical purposes

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalalang Steel Recycling The Dy. Cit-1, Private Limited Vs. Circle-1, Ground Floor, Bhavnagar – 364 001 Shop No.G-1 Sukun-1, Bhilwara Circle Bhavnagar – 364 001 [ Pan: Aamca 4837 A ] (Appellant) .. (Respondent) Assessee Represented By : Shri Parimalsinh B. Parmar, Ar Revenue Represented By : Shri Abhijit, Sr.Dr 08.12.2025 Date Of Hearing Date Of Pronouncement 16.01.2026

section 133(6) of the Act remained unanswered. Considering the lack of corroborative evidence and relying upon the investigation inputs, the Assessing Officer treated the purchases of ₹77,61,745/- as bogus

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

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

133 of the Act. The DR further stated that such denials suggest consciousness of guilt or an attempt to obscure the truth. The DR also stated that evasive denials or ambiguous statements can be perceived as incriminating as they may indicate an attempt to conceal wrongdoing or mislead investigators. The purchases from vendors who are not verifiable are bogus purchases

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

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

133 of the Act. The DR further stated that such denials suggest consciousness of guilt or an attempt to obscure the truth. The DR also stated that evasive denials or ambiguous statements can be perceived as incriminating as they may indicate an attempt to conceal wrongdoing or mislead investigators. The purchases from vendors who are not verifiable are bogus purchases

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

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

133 of the Act. The DR further stated that such denials suggest consciousness of guilt or an attempt to obscure the truth. The DR also stated that evasive denials or ambiguous statements can be perceived as incriminating as they may indicate an attempt to conceal wrongdoing or mislead investigators. The purchases from vendors who are not verifiable are bogus purchases

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

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

133 of the Act. The DR further stated that such denials suggest consciousness of guilt or an attempt to obscure the truth. The DR also stated that evasive denials or ambiguous statements can be perceived as incriminating as they may indicate an attempt to conceal wrongdoing or mislead investigators. The purchases from vendors who are not verifiable are bogus purchases

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

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

133 of the Act. The DR further stated that such denials suggest consciousness of guilt or an attempt to obscure the truth. The DR also stated that evasive denials or ambiguous statements can be perceived as incriminating as they may indicate an attempt to conceal wrongdoing or mislead investigators. The purchases from vendors who are not verifiable are bogus purchases

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

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

133 of the Act. The DR further stated that such denials suggest consciousness of guilt or an attempt to obscure the truth. The DR also stated that evasive denials or ambiguous statements can be perceived as incriminating as they may indicate an attempt to conceal wrongdoing or mislead investigators. The purchases from vendors who are not verifiable are bogus purchases

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

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

133 of the Act. The DR further stated that such denials suggest consciousness of guilt or an attempt to obscure the truth. The DR also stated that evasive denials or ambiguous statements can be perceived as incriminating as they may indicate an attempt to conceal wrongdoing or mislead investigators. The purchases from vendors who are not verifiable are bogus purchases

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

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

133 of the Act. The DR further stated that such denials suggest consciousness of guilt or an attempt to obscure the truth. The DR also stated that evasive denials or ambiguous statements can be perceived as incriminating as they may indicate an attempt to conceal wrongdoing or mislead investigators. The purchases from vendors who are not verifiable are bogus purchases

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

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

133 of the Act. The DR further stated that such denials suggest consciousness of guilt or an attempt to obscure the truth. The DR also stated that evasive denials or ambiguous statements can be perceived as incriminating as they may indicate an attempt to conceal wrongdoing or mislead investigators. The purchases from vendors who are not verifiable are bogus purchases

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

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

133 of the Act. The DR further stated that such denials suggest consciousness of guilt or an attempt to obscure the truth. The DR also stated that evasive denials or ambiguous statements can be perceived as incriminating as they may indicate an attempt to conceal wrongdoing or mislead investigators. The purchases from vendors who are not verifiable are bogus purchases

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

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

133 of the Act. The DR further stated that such denials suggest consciousness of guilt or an attempt to obscure the truth. The DR also stated that evasive denials or ambiguous statements can be perceived as incriminating as they may indicate an attempt to conceal wrongdoing or mislead investigators. The purchases from vendors who are not verifiable are bogus purchases

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

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

133 of the Act. The DR further stated that such denials suggest consciousness of guilt or an attempt to obscure the truth. The DR also stated that evasive denials or ambiguous statements can be perceived as incriminating as they may indicate an attempt to conceal wrongdoing or mislead investigators. The purchases from vendors who are not verifiable are bogus purchases

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

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

133 of the Act. The DR further stated that such denials suggest consciousness of guilt or an attempt to obscure the truth. The DR also stated that evasive denials or ambiguous statements can be perceived as incriminating as they may indicate an attempt to conceal wrongdoing or mislead investigators. The purchases from vendors who are not verifiable are bogus purchases