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

197) (Bombay) where Assessing Officer treated purchases made by assessee as bogus and made addition in respect of same, since assessee had maintained inventory of stock and payments for such purchases were made by account payee cheques and tax invoices were obtained, such purchases could not be rejected and addition to be restricted to the extent of profit element

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

197) (Bombay) where Assessing Officer treated purchases made by assessee as bogus and made addition in respect of same, since assessee had maintained inventory of stock and payments for such purchases were made by account payee cheques and tax invoices were obtained, such purchases could not be rejected and addition to be restricted to the extent of profit element

INCOME TAX OFFICER, WARD-1(8), 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

197) (Bombay) where Assessing Officer treated purchases made by assessee as bogus and made addition in respect of same, since assessee had maintained inventory of stock and payments for such purchases were made by account payee cheques and tax invoices were obtained, such purchases could not be rejected and addition to be restricted to the extent of profit element

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

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

197) (Bombay) where Assessing Officer\ntreated purchases made by assessee as bogus and made addition in respect of same,\nsince assessee had maintained inventory of stock and payments for such purchases\nwere made by account payee cheques and tax invoices were obtained, such\npurchases could not be rejected and addition to be restricted to the extent of profit\nelement.\n6.6

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

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

197) (Bombay) where Assessing Officer\ntreated purchases made by assessee as bogus and made addition in respect of same,\nsince assessee had maintained inventory of stock and payments for such purchases\nwere made by account payee cheques and tax invoices were obtained, such\npurchases could not be rejected and addition to be restricted to the extent of profit\nelement.\n6.6

DINESHCHANDRA LADDHA,AHMEDABAD vs. THE ITO WARD 1(2)(1), AHMEDABAD

In the result, the appeal of the asessee is allowed

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

Section 250 of the Income Tax Act, 1961 (hereinafter referred to as the “Act”) and relates to Assessment Year (A.Y.) 2018-19. 2. The grounds of appeal raised by the assessee read as under: “1. In his order dated 21/03/2024, the Ld. AO has erred in law by making an addition of Rs. 76,34,197 u/s 690 rws 115BBE

KALYAN JEWELS PVT. LTD,AHMEDABAD vs. ITO, WARD-2(1)(2),, AHMEDABAD

In the result, appeal of the assessee is allowed

Bench: S/Shri Waseem Ahmed & T.R. Senthil Kumarassessment Year : 2009-10 Kalyan Jewells P.Ltd. Ito, Ward-2(1)(2) 49, Super Mall Vs Ahmedabad. Nr.Lal Bungalow, Ahmedabad 380 015 Pan : Aacck 4717 B

bogus purchase. The assessee company has also obtained accommodation entries of Rs.1,37,815/- during the year under consideration in the form of purchase from the one of the benami concern of Rajendra Jain. Further, information received from the Addl. DIT (Investigation)-Unit-l, Ahmedabad in respect of accommodation entries paid by the companies and controlled by shri pratik shah

INCOME TAX OFFICER, WARD-1(3)(1), AHMEDABAD, AHMEDABAD vs. RAJESHKUMAR RAMESHCHANDRA SHAH, AHMEDABAD

In the result, appeal filed by the Revenue is dismissed

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

bogus sales and there is either no corresponding stock with the appellant or there were no such purchases against these sales. 5.3.13 The Supreme Court in the case of Lalchand Bhagat Ambica Ram vs CIT [1959] 37 ITR 288 (SC) has held that where the cash deposited was out of the books of account & cash book and where such books

BHAUMIK JEWELLERS PRIVATE LIMITED,AHMEDABAD vs. THE ITO, WARD-1(1)(2), AHMEDABAD

In the result, the appeal of the assessee stands allowed

Bench: Shri Sanjay Garg & Annapurna Guptaआयकर अपील सं /Ita No.1642/Ahd/2024 िनधा"रण वष" /Assessment Year : 2017-18 Bhaumik Jewellers Private The Ito बनाम/ Limited Ward-1(1)(2) V/S. 111, Gold Souk Complex Ahmedabad B/H. Sapphire Complex Cg Road Ahmedabad – 380 009 "थायी लेखा सं./Pan: Aagcb 2423 B (अपीलाथ)/ Appellant) (*+ यथ)/ Respondent) Assessee By : Shri Biren Shah, Ar Revenue By : Shri Sher Singh, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 17/12/2025 घोषणा की तारीख /Date Of Pronouncement: 03/02/2026 आदेश/O R D E R Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Commissioner Of Income Tax (Appeals) National Faceless Appeal Centre (Nfac), Delhi [In Short “The Cit(A)”] Passed Under Section 250 Of The Income Tax Act, 1961 (In Short “The Act”), Dated 26/07/2024 Arising Out Of The Assessment Order Passed By The Assessing Officer (In Short “The Ao”) Under Section 143(3) Of The Act For The Assessment Year 2017-18. The Assessee In This Appeal Has Agitated The Confirmation Of The Addition Of Rs. 9,65,97,834/- Made By The Ao Under Section 68 Of The Act Bhaumik Jewellers Private Limited Vs. The Ito Asst. Year : 2017-18

section 115BBE of the Act, treating the same as income from undisclosed sources. 4. Aggrieved by the order of the AO, the assessee preferred an appeal before the CIT(A). The CIT(A), however, confirmed the action of the AO. The CIT(A) relied heavily upon the decision of the Hyderabad Bench of the Tribunal in the case of Vaishnavi

CHIRAG ISHWARBHAI PATEL,AHMEDABAD vs. THE ITO, WARD-7(2)(1), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकर अपील सं./Ita No. 1182 & 1192/Ahd/2019 िनधा"रण वष"/Asstt. Year: 2010-11 Chirag Ishwarbhai Patel, I.T.O., 49 Dharamanth Prabhu Society, Vs. Ward-3(3)(6), Near Adishawar Society, Ahmedabad. Nikol Road, Naroda, Ahmedabad.

purchases from him, reopening notice against assesses was justified" 2.4. Further, the appellant has also not brought any specific evidences suggesting that this issue was considered in original Assessment Proceedings. The Hon'ble Gujarat High Court in the case of Praful Chunilal Patel v/s ACIT, 236 ITR 832 (Guj) has held as under: j "Section 147 of the Income

CHIRAG ISHWARBHAI PATEL,AHMEDABAD vs. THE ITO, WARD-3(3)(6), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकर अपील सं./Ita No. 1182 & 1192/Ahd/2019 िनधा"रण वष"/Asstt. Year: 2010-11 Chirag Ishwarbhai Patel, I.T.O., 49 Dharamanth Prabhu Society, Vs. Ward-3(3)(6), Near Adishawar Society, Ahmedabad. Nikol Road, Naroda, Ahmedabad.

purchases from him, reopening notice against assesses was justified" 2.4. Further, the appellant has also not brought any specific evidences suggesting that this issue was considered in original Assessment Proceedings. The Hon'ble Gujarat High Court in the case of Praful Chunilal Patel v/s ACIT, 236 ITR 832 (Guj) has held as under: j "Section 147 of the Income

THE ACIT, CENTRAL CIRCLE-2(2) vs. M/S. MARDIA CHEMICALS LTD.,,

In the result, the appeal of revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

197 to 213-A of the paper- book filed alongwith its written submission dated 24th December, 2001, wherein the details of interest expenses, corroborative evidences of payment proofs etc. are also given. The appellant also brought to my notice the appeal orders of my predecessors for A. Y. 1994-95 to A. Y. 1996-97, wherein, in case

THE ACIT, CENTRAL CAIRCLE-2(2) vs. M/S. MARDIA CHEMICALS LTD.,,

In the result, the appeal of revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

197 to 213-A of the paper- book filed alongwith its written submission dated 24th December, 2001, wherein the details of interest expenses, corroborative evidences of payment proofs etc. are also given. The appellant also brought to my notice the appeal orders of my predecessors for A. Y. 1994-95 to A. Y. 1996-97, wherein, in case

THE ACIT, CENTRAL CIRCLE-2(2) vs. M/S. MARDIA CHEMICALS LTD.,

In the result, the appeal of revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

197 to 213-A of the paper- book filed alongwith its written submission dated 24th December, 2001, wherein the details of interest expenses, corroborative evidences of payment proofs etc. are also given. The appellant also brought to my notice the appeal orders of my predecessors for A. Y. 1994-95 to A. Y. 1996-97, wherein, in case

THE ACIT, CENTRAL CIRCLE-2(2) vs. M/S. MARDIA CHEMICALS LTD.,

In the result, the appeal of revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

197 to 213-A of the paper- book filed alongwith its written submission dated 24th December, 2001, wherein the details of interest expenses, corroborative evidences of payment proofs etc. are also given. The appellant also brought to my notice the appeal orders of my predecessors for A. Y. 1994-95 to A. Y. 1996-97, wherein, in case

THE ACIT, CEN- CIR 2(2), AHMEDABAD vs. M/S MARDIA CHEMICALS LTD, AHMEDABAD

In the result, the appeal of revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

197 to 213-A of the paper- book filed alongwith its written submission dated 24th December, 2001, wherein the details of interest expenses, corroborative evidences of payment proofs etc. are also given. The appellant also brought to my notice the appeal orders of my predecessors for A. Y. 1994-95 to A. Y. 1996-97, wherein, in case

THE DCIT, CENTRAL CIRCLE-1(1),, AHMEDABAD vs. SHRI UMANG H. THAKKAR, AHMEDABAD

In the result, the appeal filed by the assessee bearing ITA No

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumarआयकर अपील सं / Ita No. 2150/Ahd/2008 िनधा"रण वष"/Assessment Year: 2005-06 बनाम Shri Umang Hiralal Thakkar, The Dy. Commissioner Of Vs. Dharmadev House, Income-Tax, Shyamal Cross Road, Satellite, Central Circle 1(1), Ahmedabad – 380015 Ahmedabad Pan : Aavpt 8621 R आयकर अपील सं / Ita No. 2548/Ahd/2008 िनधा"रणवष"/Assessment Year: 2005-06 बनाम Shri Umang Hiralal Thakkar, The Dy. Commissioner Of Vs. 305, Sahajanand Plaza, Bhatta Income-Tax, Ch Ar Rasta, Paldi, Ahmedabad Central Circle 1(1), Pan : Aavpt 8621 R Ahmedabad अपीलाथ"/ (Appellant) अपीलाथ" "" यथ" "" यथ"/ (Respondent) अपीलाथ" अपीलाथ" "" "" यथ" यथ" िनधा"रती की ओर से / Assessee By : Shri Bandish Soparkar, Ar & Shri Parin Shah, Ar ""थ" की ओर से / Revenue By : Shri Akhilendra Pratap Yadav, Cit-Dr तारीख/Date Of Hearing : 09.05.2024 सुनवाई क" क" तारीख सुनवाई सुनवाई सुनवाई क" क" तारीख तारीख घोषणा क" क" तारीख तारीख /Date Of Pronouncement: 30.07.2024 घोषणा घोषणा घोषणा क" क" तारीख तारीख आदेश आदेश/O R D E R आदेश आदेश

bogus, and accordingly he treated the source of investment in jewellery to be unexplained and added the same to the income of the assessee. While doing so, he noted in his order that the withdrawals made from his capital account were surely not used for investment in jewellery, but were used for his personal purposes. The personal expenditures and other

SHRI UMANG HIRALAL THAKKAR,AHMEDABAD vs. THE DY.CIT.,CENT.CIRCLE-1(1),, AHMEDABAD

In the result, the appeal filed by the assessee bearing ITA No

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumarआयकर अपील सं / Ita No. 2150/Ahd/2008 िनधा"रण वष"/Assessment Year: 2005-06 बनाम Shri Umang Hiralal Thakkar, The Dy. Commissioner Of Vs. Dharmadev House, Income-Tax, Shyamal Cross Road, Satellite, Central Circle 1(1), Ahmedabad – 380015 Ahmedabad Pan : Aavpt 8621 R आयकर अपील सं / Ita No. 2548/Ahd/2008 िनधा"रणवष"/Assessment Year: 2005-06 बनाम Shri Umang Hiralal Thakkar, The Dy. Commissioner Of Vs. 305, Sahajanand Plaza, Bhatta Income-Tax, Ch Ar Rasta, Paldi, Ahmedabad Central Circle 1(1), Pan : Aavpt 8621 R Ahmedabad अपीलाथ"/ (Appellant) अपीलाथ" "" यथ" "" यथ"/ (Respondent) अपीलाथ" अपीलाथ" "" "" यथ" यथ" िनधा"रती की ओर से / Assessee By : Shri Bandish Soparkar, Ar & Shri Parin Shah, Ar ""थ" की ओर से / Revenue By : Shri Akhilendra Pratap Yadav, Cit-Dr तारीख/Date Of Hearing : 09.05.2024 सुनवाई क" क" तारीख सुनवाई सुनवाई सुनवाई क" क" तारीख तारीख घोषणा क" क" तारीख तारीख /Date Of Pronouncement: 30.07.2024 घोषणा घोषणा घोषणा क" क" तारीख तारीख आदेश आदेश/O R D E R आदेश आदेश

bogus, and accordingly he treated the source of investment in jewellery to be unexplained and added the same to the income of the assessee. While doing so, he noted in his order that the withdrawals made from his capital account were surely not used for investment in jewellery, but were used for his personal purposes. The personal expenditures and other

PAWAN EDIFICE PVT. LTD.,VADODARA vs. THE DY.CIT, CIRCLE-2(1)(2), VADODARA

Appeals are partly allowed for\nstatistical reasons

purchase, there is no contemporaneous\nsettlement agreement, confirmation from the counter-party, or other\nprimary document on record evidencing the nature and basis of the\nsettlement. This absence of supporting documentation is unusual,\nparticularly given the significance of the amount and the nature of the\nclaim.\n65.\nIt is also noted that out of the total sum of Rs.15