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

1)(a) (Rs.)\nNA\n6,61,29,990/-\n6,58,34,650/-\nDate of AO's Order\n23.03.2023\n27.09.2022\n23.12.2022\nSection of AO's Order\n147 r.w.s.144B\n143(3) r.w.s.144B\n143(3) r.w.s.144B\nAmount of Alleged Bogus Purchases added (Rs.)\n92,95,26,352/-\n49,84,90,503/-\n412,48,43,029/-\nGross Profit Rate Applied by AO\n12.50%\n12.50

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

Section of AO’s Order 147 r.w.s. 143(3) r.w.s. 143(3) r.w.s. 144B 144B 144B Amount of Alleged Bogus 92,95,26,352/- 49,84,90,503/- 412,48,43,029/- Purchases added (Rs.) Gross Profit Rate Applied by AO 12.50% 12.50% 12.50% Addition Made

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

Section of AO’s Order 147 r.w.s. 143(3) r.w.s. 143(3) r.w.s. 144B 144B 144B Amount of Alleged Bogus 92,95,26,352/- 49,84,90,503/- 412,48,43,029/- Purchases added (Rs.) Gross Profit Rate Applied by AO 12.50% 12.50% 12.50% Addition Made

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

Section of AO’s Order 147 r.w.s. 143(3) r.w.s. 143(3) r.w.s. 144B 144B 144B Amount of Alleged Bogus 92,95,26,352/- 49,84,90,503/- 412,48,43,029/- Purchases added (Rs.) Gross Profit Rate Applied by AO 12.50% 12.50% 12.50% Addition Made

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

1)(a)\n(Rs.)\nNA\n6,61,29,990/-\n6,58,34,650/-\nDate of AO's Order\n23.03.2023\n27.09.2022\n23.12.2022\nSection of AO's Order\n147 r.w.s.\n144B\n143(3) r.w.s.\n144B\n143(3) r.w.s.\n144B\nAmount of Alleged Bogus\nPurchases added (Rs.)\n92,95,26,352/-\n49,84,90,503/-\n412,48,43,029/-\nGross Profit Rate Applied

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

1)(a)\n(Rs.)\nNA\n6,61,29,990/-\n6,58,34,650/-\nDate of AO's Order\n23.03.2023\n27.09.2022\n23.12.2022\nSection of AO's Order\n147 r.w.s.\n144B\n143(3) r.w.s.\n144B\n143(3) r.w.s.\n144B\nAmount of Alleged Bogus\nPurchases added (Rs.)\n92,95,26,352/-\n49,84,90,503/-\n412,48,43,029/-\nGross Profit Rate Applied

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

section 69C was factually and legally misplaced. However, while fully accepting the genuineness of the payments and noting that the sales have also been offered to tax, the learned CIT(A) took into account the possibility of inflation of purchases or involvement of accommodation bills to some extent and, therefore, proceeded to estimate the profit element embedded in such purchases

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

270A of the Act. 6. Aggrieved by the reassessment order, the assessee preferred an appeal before the Commissioner of Income-tax (Appeals). In the grounds of appeal, the assessee challenged the validity of reopening under section 147, alleging lack of jurisdiction and violation of procedure under section 144B. On merits, it was contended that the Assessing Officer erred in disallowing

GANDHINAGAR DISTRICT CO.OP.MILK PRODUCERS UNION LIMITED,GANDHINAGAR vs. THE ACIT, CIRCLE GANDHINAGA, GANDHINAGAR

In the result, appeal of the assessee is allowed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

270A, 271(1)(b) and 271(1)(c) of the Act. 9. The Appellant craves leave to add, amend, alter, edit, delete, modify or change all or any of the grounds of appeal at the time of or before the hearing of the appeal.” 3. The brief facts of the case are that the assessee filed the original return

PATEL KENWOOD PRIVATE LIMITED,ANKLESHWAR vs. INCOME TAX OFFICER, VADODARA

In the result, the appeal of the assessee is allowed

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.62/Ahd/2024 िनधा"रण वष" /Assessment Year : 2018-19 Patel Kenwood Pvt.Ltd. The Ito बनाम/ Plot No.100 To 103 Ward-2(1)(1) V/S. Timber Market Vadodara Gidc Ankleshwar Ankleshwar – 393 002 Gujarat "थायी लेखा सं./Pan: Aaccp 0220 G अपीलाथ%/ (Appellant) &' यथ%/ (Respondent) Assessee By : Ms. Nilisha Shah, Ar Revenue By : Shri Ritesh Parmar, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 17/10/2024 घोषणा की तारीख /Date Of Pronouncement: 29/10/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

bogus. Consequently, the AO disallowed the amount and added it back to the assessee's total income, completing the assessment under section 143(3) of the Act on 05.02.2021. The total income was determined at Rs.3,44,99,970/-. 2.1. Subsequently, the AO initiated penalty proceedings under section 270A of the Act for under-reporting of income in the nature

AIR WIND GREEN ENERGY LIMITED,BHAVNAGAR vs. THE PCIT, AHMEDABAD -1, AHMEDABAD

In the result, appeal filed by the assessee is allowed

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), SHRI T.R. SENTHIL KUMAR (Judicial Member)

Section 69C of the Act while disallowing the bogus purchases made by the assessee. However, he went on to hold that since admittedly the assessee had taken bogus accommodation entry of purchases, the AO had erred in not initiating penalty proceedings u/s.270A(9) of the Act. Accordingly, he directed the AO to initiate penalty proceedings u/s.270A

SHITAL VIPULKUMAR DHOLAKIA,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-1(1)(3), AHMEDABAD

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

1) along with questionnaire were issued from time to time. The\nassessment was completed by the AO under section 143(3) r.w.s.144B of\nthe Act vide order dated 22.12.2022, determining total income at\nRs.1,46,25,25,370/- after making a disallowance of Rs.1,45,77,00,806/-\nu/s 40A(3) of the Act in respect of purchases claimed from

PRECISION INFRATECH PRIVATE LIMITED,AHMEDABAD vs. THE DY.CIT, CIRCLE-3(1)(1), AHMEDABAD

In the result, both the appeals of the assessee are allowed for statistical purpose

Bench: Ms Suchitra Kamble & Shri Narendra Prasad Sinha

section 270A of the Act. 6. The appellant craves leave to add, amend, alter, edit, delete, modify or change all or any of the grounds of appeal at the time of or before the hearing of the appeal. 3. Shri. Parimalsinh B. Parmar, the Ld. A.R of the assessee submitted that the Ld. CIT(A) while adjudicating the appeals

PRECISION INFRATECH PRIVATE LIMITED,AHMEDABAD vs. THE DY.CIT, CIRCLE-3(1)(1), AHMEDABAD

In the result, both the appeals of the assessee are allowed for statistical purpose

Bench: Ms Suchitra Kamble & Shri Narendra Prasad Sinha

section 270A of the Act. 6. The appellant craves leave to add, amend, alter, edit, delete, modify or change all or any of the grounds of appeal at the time of or before the hearing of the appeal. 3. Shri. Parimalsinh B. Parmar, the Ld. A.R of the assessee submitted that the Ld. CIT(A) while adjudicating the appeals

KUSUMBEN RAJENDRAKUMAR SONI,AHMEDABAD vs. THE ITO, WARD-6(1)(1), AHMEDABAD

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

1.\n-2-\nThe learned Commissioner of Income Tax (Appeals) [CIT(A)]\nerred in confirming the addition of Rs.5,21,27,915/- by treating\nthe entire purchases as non-genuine and alleging the same as\nunaccounted money. The addition is based on conjectures and\nsurmises, without properly considering the appellant's\nsubmissions, supporting evidence, and\nconfirmations.”\n2.\nThe order

ASHOK AMARNATH AGRAWAL,VADODARA vs. THE DY.CIT, CIRCLE-2(1)(1), VADODARA

In the result, appeal of the assessee in ITA No

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

purchaser and completion of transaction. In some cases, the whole amount has been received in cash and then part cash has been returned to the tune of cheque payment received. On further perusal details/information (Para 8 of appraisal report of Kushal Group of Ahmedabad) received in respect of Kushal Limited, various other significant findings/observations point wise discussed as under

ASHOK AMARNATH AGRAWAL,VADODARA vs. THE DY.CIT, CIRCLE-2(1)(1), VADODARA

In the result, appeal of the assessee in ITA No

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

purchaser and completion of transaction. In some cases, the whole amount has been received in cash and then part cash has been returned to the tune of cheque payment received. On further perusal details/information (Para 8 of appraisal report of Kushal Group of Ahmedabad) received in respect of Kushal Limited, various other significant findings/observations point wise discussed as under

KALPANABEN VADILAL SHAH,AHMEDABAD vs. THE ITO, WARD-5(3)(1), AHMEDABAD

In the result, appeal filed by the assessee is allowed in above\nterms

Section 250 of the Income Tax Act, 1961\n(hereinafter referred to as the “Act\") and relates to Assessment\nYear (A.Y.) 2017-18.\nITA No. 928/Ahd/2025 [Kalpanaben\nVadilal Shah vs.ITO] A.Y. 2017-18\n-2-\n1.\nThe Commissioner of Income Tax (Appeals), NFAC, has erred\nin law and on facts while upholding the order passed by\nassessing officer

KAUSHAL PRAVINKUMAR SHAH,AHMEDABAD vs. THE ITO, WARD-3(3)(2), AHMEDABAD

1) were issued calling for details of income, computation, cash book,\nbank statements, sale and purchase bills, and source of cash deposits. The\nassessee furnished certain submissions, including claims of gifts from\nrelatives and business transactions in chemicals.\n4. The Assessing Officer, after considering the submissions of the\nassessee and verifying the evidences, concluded that the explanations were\nnot acceptable