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

GUJARAT VAIBHAV PUBLICATIONS PVT. LTD.,AHMEDABAD vs. THE ITO, WARD-2(1)(1), AHMEDABAD

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

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

bogus purchase at the rate of 15% which was reduced to 8% by the Ld. CIT(A). He further submitted that, considering the gross profit of 2.57% disclosed by the assessee, the estimation of profit @ 8% as upheld by the Ld. CIT(A) was reasonable. 10. We have considered the rival submissions. The contention of the assessee is that

GUJARAT VAIBHAV PUBLICATIONS PVT. LTD.,AHMEDABAD vs. THE ITO, WARD-2(1)(1), AHMEDABAD

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

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

bogus purchase at the rate of 15% which was reduced to 8% by the Ld. CIT(A). He further submitted that, considering the gross profit of 2.57% disclosed by the assessee, the estimation of profit @ 8% as upheld by the Ld. CIT(A) was reasonable. 10. We have considered the rival submissions. The contention of the assessee is that

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

section 151A of the Act, thereby making the entire proceedings and resultant impugned orders void ab initio. Espee Pharma Chem Pvt Ltd vs.ITO, A.Y 2019-20 3 3. In confirming the addition made of Rs. 42,95,000/- towards bogus purchase u/s 69C by passing an order u/s 148 of the Act, without providing the approval granted u/s 151

ARCOY INDUSTRIES (INDIA) PRIVATE LIMITED,AHMEDABAD vs. THE DCIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, all the captioned four appeals of the assessee are hereby allowed

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

purchases made from other concerns in other years, there are corresponding concerns in table 2 in the annexure to his statement. 10. He categorically admitted that all the loans and advances are merely bogus in nature. He also submitted date-wise and party-wise details of such bogus transactions. Further, Shri Bharat Padiya, Executive Director of Dishman Group has also

ARCOY INDUSTRIES (INDIA) PRIVATE LIMITED,AHMEDABAD vs. THE DCIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, all the captioned four appeals of the assessee are hereby allowed

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

purchases made from other concerns in other years, there are corresponding concerns in table 2 in the annexure to his statement. 10. He categorically admitted that all the loans and advances are merely bogus in nature. He also submitted date-wise and party-wise details of such bogus transactions. Further, Shri Bharat Padiya, Executive Director of Dishman Group has also

ARCOY INDUSTRIES (INDIA) PRIVATE LIMITED,AHMEDABAD vs. THE DCIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, all the captioned four appeals of the assessee are hereby allowed

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

purchases made from other concerns in other years, there are corresponding concerns in table 2 in the annexure to his statement. 10. He categorically admitted that all the loans and advances are merely bogus in nature. He also submitted date-wise and party-wise details of such bogus transactions. Further, Shri Bharat Padiya, Executive Director of Dishman Group has also

ACIT, ANAND CIRCLE, ANAND vs. NARENDRAKUMAR HANSRAJBHAI PATEL, KHEDA

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinhaआयकर अपील सं /Ita No.834/Ahd/2024 िनधा"रण वष" /Assessment Year : 2021-22 The Acit Narendrakumar Hansrajbhai बनाम/ Dy./Asst.Commissioner Of Patel V/S. Income Tax (Anand Circle) I C/O. Mahakali Saw Mill Anand – 388 001 Mansarovar Marker Kamla Kamia, Kheda – 387 320 "थायी लेखा सं./Pan: Cmmpp 6784 N (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Mishal Mehta, Ca Revenue By : Shri Alpesh Parmar, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 28/08/2025 घोषणा की तारीख /Date Of Pronouncement: 29/10/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm: The Present Appeal Has Been Preferred By The Revenue Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 27/02/2024 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2021-2022. 2. The Revenue Has Raised The Following Grounds Of Appeal: “1. Whether, On Facts & In Circumstances Of The Case & In Law, The Ld.Cit(A) Is Justified In Deleting The Addition Of Rs. 10,64,04,151/-Made U/S 69C Of The Act Without Appreciating The Fact The Assessee Failed To Substantiate The Expenditure Claimed With Supporting Evidences? Asst.Cit Vs. Narendrakumar Hansrajbhai Patel Asst. Year : 2021-22

bogus merely because certain suppliers did not respond to the AO’s notices or had filed low returns. In view of the detailed evidence produced by the assessee demonstrating the genuineness of purchases and sales, the CIT(A) held that the addition of ₹10,64,04,151/- made by the AO under section

DEPUTY COMMISSIONER OF INCOME -TAX, CENTRAL CIRCLE-1(1), AHMEDABAD, AHMEDABAD vs. MONARCH NETWORTH CAPITAL LIMITED, MUMBAI

Accordingly\ndismissed as not pressed.\n17. In the combined result, all three appeals filed by the Revenue for\nA.Ys.2013–14, 2014–15 and 2015–16 are dismissed

151.\nThough the communication of reasons was delayed, it was not fatal to the\njurisdiction.\n5. 1. However, on merits, the CIT(A) found substantial force in the\nsubmissions of the assessee. After detailed examination, the CIT(A) held that\nthe AO had merely relied on general statements and third-party\ninvestigations without establishing a direct nexus between the assessee

NARMADA CONCAST PRIVATE LIMITED,BHAVNAGAR vs. THE DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), AHMEDABAD

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

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

151 of the Act.” 7.1. On perusal of the above “reasons recorded” by the Assessing Officer makes it very clear that the he had reason to conclude that the assessee had entered into high value financial transactions of Rs. 1,00,00,224/- facilitating bogus accommodation entries during the year as reported in the investigation report of Banka Group. Thus

DEPUTY COMMISSIONER OF INCOME -TAX, CENTRAL CIRCLE-1(1), AHMEDABAD, AHMEDABAD vs. MONARCH NETWORTH CAPITAL LIMITED, MUMBAI

Accordingly\ndismissed as not pressed.\n17. In the combined result, all three appeals filed by the Revenue for\nA.Ys.2013–14, 2014–15 and 2015–16 are dismissed

151.\nThough the communication of reasons was delayed, it was not fatal to the\njurisdiction.\n5.1. However, on merits, the CIT(A) found substantial force in the\nsubmissions of the assessee. After detailed examination, the CIT(A) held that\nthe AO had merely relied on general statements and third-party\ninvestigations without establishing a direct nexus between the assessee

AMEE GOVINDBHAI PATEL,MEHSANA vs. THE INCOME TAX OFFICER ,WARD-1,, MEHSANA

In the result, the appeal of the assessee is, therefore, allowed in above terms

Bench: Shri Sanjay Garg & Smt. Annapurna Gupta

bogus purchases, expenses, etc. The assessee ought to have disclosed income received by oil means by filing return of income for the year under consideration. 4. From the above facts & discussion, it is noted that me lessee was in possession of unaccounted income which was above taxable limit. The assessee ought to have disclosed fully and truly all the material

OMKARA IMPEX AND MERCHANDISE LLP,AHMEDABAD vs. THE ACIT, CIRCLE-3(3)(2), AHMEDABAD

In the result, the appeal of the assessee is allowed for statistical\npurposes

151. The assessee did not file its return of income in\nresponse to the notice under Section 148 of the Act. The AO issued multiple\nnotices under Sections 142(1) and 143(2) of the act, calling for details.\nHowever, the assessee remained non-compliant and failed to furnish\nsupporting documents to substantiate the purchases. The AO passed a best

ACIT, CENTRAL CIRCLE-2, VADODARA, VADODARA vs. HK ISPAT PVT LTD, GODHRA

In the result, all the appeals filed by the Revenue for AYs 2014–15 to 2021–

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra R. Kamblesn

151 wherein it was held as under. "Section 68 of the Income-tax Act, 1961 Cash credit (Loans) -Assessing Officer treated a part of loan taken by assessee, taken from agriculturists, as non- genuine and made addition under section 68 However, assessee produced copy of 7/12 extract from land register maintained by land revenue, loan confirmation letter, copy

ACIT, CENTRAL CIRCLE-2, VADODARA, VADODARA vs. HK ISPAT PVT LTD, GODHRA

In the result, all the appeals filed by the Revenue for AYs 2014–15 to 2021–

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra R. Kamblesn

151 wherein it was held as under. "Section 68 of the Income-tax Act, 1961 Cash credit (Loans) -Assessing Officer treated a part of loan taken by assessee, taken from agriculturists, as non- genuine and made addition under section 68 However, assessee produced copy of 7/12 extract from land register maintained by land revenue, loan confirmation letter, copy

H K ISPAT PVT. LTD.,PANCHMAHAL vs. THE DY.CIT, CENTRAL CIRCLE-2, VADODARA

In the result, all the appeals filed by the Revenue for AYs 2014–15 to 2021–

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra R. Kamblesn

151 wherein it was held as under. "Section 68 of the Income-tax Act, 1961 Cash credit (Loans) -Assessing Officer treated a part of loan taken by assessee, taken from agriculturists, as non- genuine and made addition under section 68 However, assessee produced copy of 7/12 extract from land register maintained by land revenue, loan confirmation letter, copy

MANISH RANJAN, DEPUTY COMMISSIONER OF INCOME -TAX, CENTRAL CIRCLE-1(1), AHMEDABAD, AHMEDABAD vs. MONARCH NETWORTH CAPITAL LIMITED, MUMBAI

Accordingly, the ground raised by the Revenue for A.Y. 2015–16 is dismissed

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokar

151. Though the communication of reasons was delayed, it was not fatal to the jurisdiction. 5.1. However, on merits, the CIT(A) found substantial force in the submissions of the assessee. After detailed examination, the CIT(A) held that the AO had merely relied on general statements and third-party investigations without establishing a direct nexus between the assessee

CHINMAY YOGESHKUMAR AGRAWAL, HUF,AHMEDABAD vs. THE ITO, WARD-3(1)(1), AHMEDABAD

In the result, the appeal filed by the assessee is allowed for statistical purposes

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

151 of the Act, the Assessing Officer was mandatorily required to obtain approval from the Principal Chief Commissioner or Principal Director General or, in their absence, from the Chief Commissioner or Director General. The approval dated 31.03.2021, having been taken from a subordinate/junior authority, is therefore in clear violation of the statutory mandate. Consequently, the impugned notice issued under section

ITO, WARD-4(2)(3), AHMEDABAD, AHMEDABAD vs. MAHESHWARI SALES CORPORATION, AHMEDABAD

In the result, the appeal filed by the Revenue stands dismissed

Bench: Annapurna Gupta & Shri Siddhartha Nautiyalआयकर अपील सं /Ita No.1306/Ahd/2025 िनधा"रण वष" /Assessment Year : 2018-19 The Ito Maheshwari Sales Corporation बनाम/ Ward-4(2)(3) C-111, Ganesh Meridin V/S. Ahmedabad Nr.Sola Bridge, Sola Ahmedabad-380 058 "थायी लेखा सं./Pan: Aalfm 4917 H (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Mehul K. Patel, Ar Revenue By : Smt. Mamta Singh, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 01/09/2025 घोषणा की तारीख /Date Of Pronouncement: 30/10/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm: This Appeal By The Revenue Is Directed Against The Order Of The Ld.Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As “Cit(A)”], Dated 11/04/2025, Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2018-2019. 2. The Revenue Has Raised The Following Grounds Of Appeal: Ito Vs. Maheshwari Sales Corporation Asst. Year : 2018-19

bogus sales aggregating Rs. 63,84,998/-. Consequently, the said sum was treated as unexplained cash credit under section 68 of the Act and added to the total income of the assessee. 4. In appeal before CIT(Appeals), the assessee submitted that the addition made by the Assessing Officer was based solely on suspicion and general findings of the Investigation