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

E R आदेश आदेश आदेश PER BENCH: These cross appeals by the Assessee and the Revenue pertain to the Assessment Years 2018–19, 2020–21 and 2021– ITA No.254 to 256 and 274 to 276 /Ahd/2024 2 22 and are directed against the respective orders passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [hereinafter

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

E R आदेश आदेश आदेश PER BENCH: These cross appeals by the Assessee and the Revenue pertain to the Assessment Years 2018–19, 2020–21 and 2021– ITA No.254 to 256 and 274 to 276 /Ahd/2024 2 22 and are directed against the respective orders passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [hereinafter

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

E R आदेश आदेश PER ANNAPURNA GUPTA, ACCOUNTANT MEMBER These are two appeals by the assessee against the order of the Commissioner of Income Tax (Appeals)-2, Ahmedabad (in short referred to as “ld.CIT(A)”) of even date i.e. 25.1.2018 passed under section 250(6) of the Income Tax Act, 1961 ("the Act" for short) pertaining to Assessment Years

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

E R आदेश आदेश PER ANNAPURNA GUPTA, ACCOUNTANT MEMBER These are two appeals by the assessee against the order of the Commissioner of Income Tax (Appeals)-2, Ahmedabad (in short referred to as “ld.CIT(A)”) of even date i.e. 25.1.2018 passed under section 250(6) of the Income Tax Act, 1961 ("the Act" for short) pertaining to Assessment Years

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

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

purchases and vendors in question were part of the regular accounting, and no list of unverified or ITA No.2815/Ahd/2011 and other 17 appeals JMC Projects (India) Ltd. vs. DCIT-ACIT (By assessee and Revenue) Asst. Years : 2007-08 to 2015-16 bogus vendors was discovered during the search. Following the Vijaykumar D. Agarwal(supra) decision, the lack of such incriminating

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

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

purchases and vendors in question were part of the regular accounting, and no list of unverified or ITA No.2815/Ahd/2011 and other 17 appeals JMC Projects (India) Ltd. vs. DCIT-ACIT (By assessee and Revenue) Asst. Years : 2007-08 to 2015-16 bogus vendors was discovered during the search. Following the Vijaykumar D. Agarwal(supra) decision, the lack of such incriminating

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

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

purchases and vendors in question were part of the regular accounting, and no list of unverified or ITA No.2815/Ahd/2011 and other 17 appeals JMC Projects (India) Ltd. vs. DCIT-ACIT (By assessee and Revenue) Asst. Years : 2007-08 to 2015-16 bogus vendors was discovered during the search. Following the Vijaykumar D. Agarwal(supra) decision, the lack of such incriminating

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

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

purchases and vendors in question were part of the regular accounting, and no list of unverified or ITA No.2815/Ahd/2011 and other 17 appeals JMC Projects (India) Ltd. vs. DCIT-ACIT (By assessee and Revenue) Asst. Years : 2007-08 to 2015-16 bogus vendors was discovered during the search. Following the Vijaykumar D. Agarwal(supra) decision, the lack of such incriminating

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

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

purchases and vendors in question were part of the regular accounting, and no list of unverified or ITA No.2815/Ahd/2011 and other 17 appeals JMC Projects (India) Ltd. vs. DCIT-ACIT (By assessee and Revenue) Asst. Years : 2007-08 to 2015-16 bogus vendors was discovered during the search. Following the Vijaykumar D. Agarwal(supra) decision, the lack of such incriminating

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

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

purchases and vendors in question were part of the regular accounting, and no list of unverified or ITA No.2815/Ahd/2011 and other 17 appeals JMC Projects (India) Ltd. vs. DCIT-ACIT (By assessee and Revenue) Asst. Years : 2007-08 to 2015-16 bogus vendors was discovered during the search. Following the Vijaykumar D. Agarwal(supra) decision, the lack of such incriminating

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

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

purchases and vendors in question were part of the regular accounting, and no list of unverified or ITA No.2815/Ahd/2011 and other 17 appeals JMC Projects (India) Ltd. vs. DCIT-ACIT (By assessee and Revenue) Asst. Years : 2007-08 to 2015-16 bogus vendors was discovered during the search. Following the Vijaykumar D. Agarwal(supra) decision, the lack of such incriminating

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

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

purchases and vendors in question were part of the regular accounting, and no list of unverified or ITA No.2815/Ahd/2011 and other 17 appeals JMC Projects (India) Ltd. vs. DCIT-ACIT (By assessee and Revenue) Asst. Years : 2007-08 to 2015-16 bogus vendors was discovered during the search. Following the Vijaykumar D. Agarwal(supra) decision, the lack of such incriminating

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

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

purchases and vendors in question were part of the regular accounting, and no list of unverified or ITA No.2815/Ahd/2011 and other 17 appeals JMC Projects (India) Ltd. vs. DCIT-ACIT (By assessee and Revenue) Asst. Years : 2007-08 to 2015-16 bogus vendors was discovered during the search. Following the Vijaykumar D. Agarwal(supra) decision, the lack of such incriminating

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

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

purchases and vendors in question were part of the regular accounting, and no list of unverified or ITA No.2815/Ahd/2011 and other 17 appeals JMC Projects (India) Ltd. vs. DCIT-ACIT (By assessee and Revenue) Asst. Years : 2007-08 to 2015-16 bogus vendors was discovered during the search. Following the Vijaykumar D. Agarwal(supra) decision, the lack of such incriminating

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

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

purchases and vendors in question were part of the regular accounting, and no list of unverified or ITA No.2815/Ahd/2011 and other 17 appeals JMC Projects (India) Ltd. vs. DCIT-ACIT (By assessee and Revenue) Asst. Years : 2007-08 to 2015-16 bogus vendors was discovered during the search. Following the Vijaykumar D. Agarwal(supra) decision, the lack of such incriminating

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

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

purchases and vendors in question were part of the regular accounting, and no list of unverified or ITA No.2815/Ahd/2011 and other 17 appeals JMC Projects (India) Ltd. vs. DCIT-ACIT (By assessee and Revenue) Asst. Years : 2007-08 to 2015-16 bogus vendors was discovered during the search. Following the Vijaykumar D. Agarwal(supra) decision, the lack of such incriminating

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

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

purchases and vendors in question were part of the regular accounting, and no list of unverified or ITA No.2815/Ahd/2011 and other 17 appeals JMC Projects (India) Ltd. vs. DCIT-ACIT (By assessee and Revenue) Asst. Years : 2007-08 to 2015-16 bogus vendors was discovered during the search. Following the Vijaykumar D. Agarwal(supra) decision, the lack of such incriminating

DILIPKUMAR PASHABHAI PRAJAPATI,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-3(3)(5), AHMEDABAD

In the result, both the appeals of the assessee in ITA Nos

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.1095 & 1096/Ahd/2024 िनधा"रण वष" /Assessment Years : 2016-17 & 2017-18 Respectively Dilipkumar Pashabhai Prajapati The Income Tax Officer बनाम/ C/Sf 211 Pushp Business Campus Ward-3(3)(5) V/S. Nr. Vastral Cross Road Ahmedabad Sp Ring Road Vastral Ahmedabad – 382 418 "थायी लेखा सं./Pan:Atrpp 9632 R (अपीलाथ%/ Appellant) (&' यथ%/ Respondent) Assessee By : Shri Jinesh Shah, Ar Revenue By : Shri R.N. Dsouza, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 10/09/2024 घोषणा की तारीख /Date Of Pronouncement: 25/09/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

22 of the Rs. nt Order reassessment 90,37,67,440/ under due to failure - under Section of the section 68 as 147 read assessee to unexplained with provide credits due to Section adequate non- 144B evidence or compliance substantiate and lack of the substantiatio transactions n of the during the transactions. proceedings. ITA Nos.1095 & 1096/Ahd/2024 Dilipkumar Pashabhai Prajapati

DILIPKUMAR PASHABHAI PRAJAPATI,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-3(3)(5), AHMEDABAD

In the result, both the appeals of the assessee in ITA Nos

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.1095 & 1096/Ahd/2024 िनधा"रण वष" /Assessment Years : 2016-17 & 2017-18 Respectively Dilipkumar Pashabhai Prajapati The Income Tax Officer बनाम/ C/Sf 211 Pushp Business Campus Ward-3(3)(5) V/S. Nr. Vastral Cross Road Ahmedabad Sp Ring Road Vastral Ahmedabad – 382 418 "थायी लेखा सं./Pan:Atrpp 9632 R (अपीलाथ%/ Appellant) (&' यथ%/ Respondent) Assessee By : Shri Jinesh Shah, Ar Revenue By : Shri R.N. Dsouza, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 10/09/2024 घोषणा की तारीख /Date Of Pronouncement: 25/09/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

22 of the Rs. nt Order reassessment 90,37,67,440/ under due to failure - under Section of the section 68 as 147 read assessee to unexplained with provide credits due to Section adequate non- 144B evidence or compliance substantiate and lack of the substantiatio transactions n of the during the transactions. proceedings. ITA Nos.1095 & 1096/Ahd/2024 Dilipkumar Pashabhai Prajapati