DCIT, CIRCLE-2(1)(1),, BARODA vs. M/S. SUN PHARMACEUTICALS INDUSTRIES LTD. , BARODA

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

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Waseem Ahmed, Accountant Memebr

bogus by the Maharashtra VAT department. To our understanding, based upon the information received from the 3rd party, until and unless it is confronted to the assessee, no adverse inference can be drawn. There can be various reasons for the cancellation of the registration such as ITA No. 1462, 1463, 1519 & 1520/Ahd/2018 [Sun Pharma Laboratories

DCIT, CIRCLE-2(1)(1),, BARODA vs. M/S. SUN PHARMACEUTICALS INDUSTRIES LTD. , BARODA

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

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Waseem Ahmed, Accountant Memebr

bogus by the Maharashtra VAT department. To our understanding, based upon the information received from the 3rd party, until and unless it is confronted to the assessee, no adverse inference can be drawn. There can be various reasons for the cancellation of the registration such as ITA No. 1462, 1463, 1519 & 1520/Ahd/2018 [Sun Pharma Laboratories

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

Section Bhagat Marketing Pvt. Ltd. vs. PCIT Asst.Year –2016-17 - 3– 147 r.w.s 144B of the Income-tax Act, 1961 was passed on March 27, 2022, determining the assessed income at Rs. 1,13,02,151/-. The Assessing Officer (A.O.) made an addition of Rs. 1,13,12,210/-, which constituted 12.5% of alleged non-genuine purchases amounting

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

1). Ahmedabad as per provisions of section 151 of the Act and the same was approved on 11.03.2019.” 11. It is found from the above reason that the Assessing Officer had received information regarding suspicious transactions of the assessee ITA Nos.1358 & 1359/Ahd/2025 (Assessment Years: 2015-16 & 2016-17) Gujarat Vaibhav Publications Pvt. Ltd. vs. ITO Page 8 of 11 with

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

1). Ahmedabad as per provisions of section 151 of the Act and the same was approved on 11.03.2019.” 11. It is found from the above reason that the Assessing Officer had received information regarding suspicious transactions of the assessee ITA Nos.1358 & 1359/Ahd/2025 (Assessment Years: 2015-16 & 2016-17) Gujarat Vaibhav Publications Pvt. Ltd. vs. ITO Page 8 of 11 with

THE DCIT, CENTRAL CIRCLE-3,, BARODA vs. M/S. ULTRATECH TRANSMISSION PVT. LTD, BARODA

In the result, appeal of the Revenue is partly allowed for assessment year 2016-17

1 see no justification on the part of the AO to make disallowance of Rs.1,86,97,354/- being expenses in respect of payment to sub-contractors. The A.O. is directed to delete the same. This ground of appeal is allowed.” 6. The Revenue is in appeal before us against the aforesaid order passed by Ld. CIT(Appeals) deleting

THE DCIT, CENTRAL CIRCLE-3,, BARODA vs. M/S. ULTRA TECH TRANSMISSION,, BARODA

In the result, appeal of the Revenue is partly allowed for assessment year 2016-17

1 see no justification on the part of the AO to make disallowance of Rs.1,86,97,354/- being expenses in respect of payment to sub-contractors. The A.O. is directed to delete the same. This ground of appeal is allowed.” 6. The Revenue is in appeal before us against the aforesaid order passed by Ld. CIT(Appeals) deleting

THE DCIT, CENTRAL CIRCLE-3,, BARODA vs. M/S. ULTRA TECH TRANSMISSION,, BARODA

In the result, appeal of the Revenue is partly allowed for assessment year 2016-17

1 see no justification on the part of the AO to make disallowance of Rs.1,86,97,354/- being expenses in respect of payment to sub-contractors. The A.O. is directed to delete the same. This ground of appeal is allowed.” 6. The Revenue is in appeal before us against the aforesaid order passed by Ld. CIT(Appeals) deleting

THE DCIT, CENTRAL CIRCLE-3,, BARODA vs. ULTRA TECH TRANSMISSION,, BARODA

In the result, appeal of the Revenue is partly allowed for assessment year 2016-17

1 see no justification on the part of the AO to make disallowance of Rs.1,86,97,354/- being expenses in respect of payment to sub-contractors. The A.O. is directed to delete the same. This ground of appeal is allowed.” 6. The Revenue is in appeal before us against the aforesaid order passed by Ld. CIT(Appeals) deleting

THE DCIT, CENTRAL CIRCLE-3,, BARODA vs. M/S. ULTRA TECH TRANSMISSION,, BARODA

In the result, appeal of the Revenue is partly allowed for assessment year 2016-17

1 see no justification on the part of the AO to make disallowance of Rs.1,86,97,354/- being expenses in respect of payment to sub-contractors. The A.O. is directed to delete the same. This ground of appeal is allowed.” 6. The Revenue is in appeal before us against the aforesaid order passed by Ld. CIT(Appeals) deleting

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

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

1. In assuming jurisdiction U/s 148 of the Income Tax Act by issuing notice for the AY 2019-20, it is said that the whole proceedings are bad in law and void ab initio. 2. In assuming jurisdiction U/s 148 of the Income Tax Act by issuing notice for the AY 2019-20 dated

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

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 69C of the Act. was unsustainable

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

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