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

purchase amount of Rs. 99,49,624/- under Section 69C of the Act, treating it as unexplained expenditure. 10.3 On appeal, the Ld. CIT(A) upheld the AO's finding that the suppliers were non-genuine but disagreed with the 100% disallowance. Relying on jurisdictional precedents, the Ld. CIT(A) restricted the addition to 6% of the purchase value, concluding

RUDRA GLOBAL INFRA PRODUCTS LTD.,BHAVNAGAR vs. THE ACIT, CIRCLE-1, BHAVNAGAR

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

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

bogus purchases made by assessee from a hawala biller, made an addition under section 68 Rudra Global Infra Products Ltd. vs. ACIT

MANISH DEVENDRAKUMAR SHAH,AHMEDABAD vs. THE ITO, WARD-5(3)(1), AHMEDABAD

The appeal of the assessee is allowed in full

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.918/Ahd/2024 िनधा"रण वष" /Assessment Year : 2014-15 Manish Devendrakumar Shah The Ito बनाम/ 206, 2Nd Floor, Kalash 1 Ward-5(3)(1) V/S. Navrangpura Ahmedabad Ahmedabad – 380 009 "थायी लेखा सं./Pan: Aqjps 4226 K (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri S.N. Divatia, Ar & Shri Samir Vora, Ar Revenue By : Shri Rignesh Das, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 20 /02/2025 घोषणा की तारीख /Date Of Pronouncement: 25/02/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

Section 68 of the Act, concluding that the assessee failed to justify his investment in a company with no business operations, the assessee was aware of price rigging as he purchased shares through preferential allotment, the price spike was unnatural, indicating manipulation. The CIT(A) relied on judicial precedents, such as, Swati Bajaj (Calcutta High Court), Suman Poddar (Supreme Court

M/S. FLOURISH PUREFOODS PVT.LTD.,,AHMEDABAD vs. THE DCIT.,CENT.CIRCLE-2(1),, AHMEDABAD

In the result, this ground of appeal of the assessee is allowed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyali.T(Ss).A. No.518/Ahd/2019 (Assessment Year: 2015-16) Flourish Purefoods Pvt. Ltd., Vs. Deputy Commissioner Of Income 11-12, Ecs House, Garden View, Tax, Nr. Global Hospital, Bodakdev, Central Circle-2(1), Ahmedabad-380054 Ahmedabad [Pan No.Aadcv2683B] (Appellant) .. (Respondent)

section 68 of the Act, is directed to be deleted. The second ground of appeal of the assessee relates to claim of depreciation of Rs. 18,92,228/- on capital assets: 12. The brief facts of the case are that the assessee claimed depreciation of Rs. 18,92,228/- on capital assets purchased from J S Enterprise for the assessment

RAJENDRAKUMAR CHHANALAL SHAH,MEHSANA vs. THE ITO, WARD-1, PATAN

In the result, the appeal of the assessee is allowed

Bench: Dr. B.R.R. Kumar, Vice-Shri T.R. Senthil Kumar

68,630/-, by observing as under:- “5.1 I have gone through the facts of the case, findings by the AO and the submissions made by the appellant. Grounds No. 1 of appeal are related to disallowance of purchases made by two parties. Reason for making this addition was that AO issued Notice

DEPUTY COMMISSIONER OF INCOME -TAX CENTRAL CIRCLE-1(1), AHMEDABAD, AHMEDABAD, GUJARAT vs. BHAVESHKUMAR GIRISHBHAI BHANDARI, AHMEDABAD, GUJARAT

Appeal is allowed in ITA 978/Ahd/2025 and ITA\n978/Ahd/2025 as well

68 of the Act for unexplained cash credits and\nan addition of Rs. 21,36,579/- for disallowance of certain expenses\nunder section 37(1) of the Act. Later, a report from the Investigation Wing,\nAhmedabad was received by the Assessing Officer (AO), which contained\ninformation regarding accommodation entries and manipulation of penny\nstock transactions allegedly carried

SHRI RAJENDRA J KESHWANI (HUF),AHMEDABAD vs. THE PR. CIT- CENTRAL, AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.118/Ahd/2021 िनधा"रण वष" /Assessment Year : 2015-16 Shri Rajendra J. Keshwani The Pr.Cit बनाम/ (Huf) Central Circle V/S. 44, Asopalav Bungalows Ahmedabad Nr.Mukthidham Jain Temple Thaltej – 380 054 (Gujarat) "थायी लेखा सं./Pan: Aaehk 1973 J अपीलाथ%/ (Appellant) &' यथ%/ (Respondent) ….. Assessee By : Shri M.K. Patel, Advocate Revenue By : Shri V. Nandakumar, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 12/02/2025 घोषणा की तारीख /Date Of Pronouncement: 18/02/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

purchased off-market through Shaswat Stockbrokers Pvt. Ltd. The case was selected for scrutiny, and assessment was completed under Section 143(3) of the Act, wherein the AO treated the LTCG as bogus and made an addition under Section 68

ALANG STEEL RECYCLING PRIVATE LIMITED,BHAVNAGAR vs. THE PR. CIT-1, AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalalang Steel Recycling The Pr. Cit-1, Private Limited Vs. Ahmedabad – 380 015 Ground Floor, 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 R.P. Rastogi, Cit-Dr 08.12.2025 Date Of Hearing Date Of Pronouncement 16.01.2026

bogus purchases during the reassessment proceedings and disallowed 100% of the purchases amounting to ₹77,61,745/- . The Principal Commissioner has not disputed the quantum of disallowance made by the Assessing Officer. The sole basis for invoking section 263 is that, according to the Principal Commissioner, the disallowance should have been made under section 69C read with section 115BBE

DEPUTY COMMISSIONER OF INCOME -TAX CENTRAL CIRCLE-1(1), AHMEDABAD, AHMEDABAD, GUJARAT vs. GIRISHKUMAR AMRATLAL BHANDARI HUF, HIMATNAGAR, GUJARAT

In the result, the appeal of the Department is allowed and the order of\nthe Assessing Officer is restored

68 of the Act for unexplained cash credits and\nan addition of Rs.21,36,579/- for disallowance of certain expenses\nunder section 37(1) of the Act. Later, a report from the Investigation Wing,\nAhmedabad was received by the Assessing Officer (AO), which contained\ninformation regarding accommodation entries and manipulation of penny\nstock transactions allegedly carried out by the Kushal

DEPUTY COMMISSIONER OF INCOME -TAX CENTRAL CIRCLE-1(1), AHMEDABAD, AHMEDABAD, GUJARAT vs. BHAVESHKUMAR GIRISHBHAI BHANDARI, AHMEDABAD, GUJARAT

In the result, the appeal of the Department is allowed and the order of\nthe Assessing Officer is restored

68 of the Act for unexplained cash credits and\nan addition of Rs.21,36,579/- for disallowance of certain expenses\nunder section 37(1) of the Act. Later, a report from the Investigation Wing,\nAhmedabad was received by the Assessing Officer (AO), which contained\ninformation regarding accommodation entries and manipulation of penny\nstock transactions allegedly carried out by the Kushal

JHAVERI TRADING AND INVESTMENT PVT.LTD.,AHMEDABAD vs. THE DCIT, CENT. CIR. 1(1), AHMEDABAD

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

Bench: Shri Waseem Ahmed & Shri Tr Senthil Kumarआयकर अपील सं./Ita Nos. 401 To 403/Ahd/2023 "नधा"रण वष"/Asstt. Years: (2012-2013 To 2014-2015) & आयकर अपील सं./Ita Nos. 399 & 400/Ahd/2023 "नधा"रण वष"/Asstt. Years: (2010-2011 & 2011-12)

bogus is incorrect. 24. In view of holistic consideration of all the facts, as discussed herein above the various pleas in the ground of appeal taken by the appellant are rejected and the action of the AO in making addition of Rs 12,19,45,000/- under Section 68 of the Act is justified and hence confirmed. Thus, the ground

JHAVERI TRADING AND INVESTMENT PVT.LTD.,AHMEDABAD vs. THE DCIT, CENT. CIR. 1(1), AHMEDABAD

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

Bench: Shri Waseem Ahmed & Shri Tr Senthil Kumarआयकर अपील सं./Ita Nos. 401 To 403/Ahd/2023 "नधा"रण वष"/Asstt. Years: (2012-2013 To 2014-2015) & आयकर अपील सं./Ita Nos. 399 & 400/Ahd/2023 "नधा"रण वष"/Asstt. Years: (2010-2011 & 2011-12)

bogus is incorrect. 24. In view of holistic consideration of all the facts, as discussed herein above the various pleas in the ground of appeal taken by the appellant are rejected and the action of the AO in making addition of Rs 12,19,45,000/- under Section 68 of the Act is justified and hence confirmed. Thus, the ground

JHAVERI TRADING AND INVESTMENT PVT.LTD.,AHMEDABAD vs. THE DCIT, CENT. CIR. 1(1), AHMEDABAD

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

Bench: Shri Waseem Ahmed & Shri Tr Senthil Kumarआयकर अपील सं./Ita Nos. 401 To 403/Ahd/2023 "नधा"रण वष"/Asstt. Years: (2012-2013 To 2014-2015) & आयकर अपील सं./Ita Nos. 399 & 400/Ahd/2023 "नधा"रण वष"/Asstt. Years: (2010-2011 & 2011-12)

bogus is incorrect. 24. In view of holistic consideration of all the facts, as discussed herein above the various pleas in the ground of appeal taken by the appellant are rejected and the action of the AO in making addition of Rs 12,19,45,000/- under Section 68 of the Act is justified and hence confirmed. Thus, the ground

JHAVERI TRADING AND INVESTMENT PVT.LTD.,AHMEDABAD vs. THE DCIT, CENT. CIR. 1(1), AHMEDABAD

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

Bench: Shri Waseem Ahmed & Shri Tr Senthil Kumarआयकर अपील सं./Ita Nos. 401 To 403/Ahd/2023 "नधा"रण वष"/Asstt. Years: (2012-2013 To 2014-2015) & आयकर अपील सं./Ita Nos. 399 & 400/Ahd/2023 "नधा"रण वष"/Asstt. Years: (2010-2011 & 2011-12)

bogus is incorrect. 24. In view of holistic consideration of all the facts, as discussed herein above the various pleas in the ground of appeal taken by the appellant are rejected and the action of the AO in making addition of Rs 12,19,45,000/- under Section 68 of the Act is justified and hence confirmed. Thus, the ground

JHAVERI TRADING AND INVESTMENT PVT.LTD.,AHMEDABAD vs. THE DCIT, CENT. CIR. 1(1), AHMEDABAD

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

Bench: Shri Waseem Ahmed & Shri Tr Senthil Kumarआयकर अपील सं./Ita Nos. 401 To 403/Ahd/2023 "नधा"रण वष"/Asstt. Years: (2012-2013 To 2014-2015) & आयकर अपील सं./Ita Nos. 399 & 400/Ahd/2023 "नधा"रण वष"/Asstt. Years: (2010-2011 & 2011-12)

bogus is incorrect. 24. In view of holistic consideration of all the facts, as discussed herein above the various pleas in the ground of appeal taken by the appellant are rejected and the action of the AO in making addition of Rs 12,19,45,000/- under Section 68 of the Act is justified and hence confirmed. Thus, the ground

RAVIKUMAR KAMLESHBHAI SHAH,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD -5(2)(1), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: SHRI WASEEM AHMED (Accountant Member), MS. MADHUMITA ROY (Judicial Member)

section 68 of the Act can be made. But the assessee contended that before rejecting the books of accounts, the fair opportunity of being heard should be given to him. 5.3 But the AO was not satisfied with the explanation furnished by the assessee on the reasoning detailed below: “In view of the above discussion, it can be logically concluded

M/S. PUSHPAK BULLION PVT. LTD.,AHMEDABAD vs. THE DCIT, CIRCLE-3(1)(1), AHMEDABAD

In the result, the appeal filed by the assessee is hereby partly allowed

Bench: Jurisdictional High Court & The Hon’Ble Gujarat High Court Dismissed The Writ Petition Filed By The Assessee Vide Judgment Dated 27-06-2016 In Sca No. 18512 Of 2015 & Upheld The Validity Of The Reassessment Notice.

purchasing the goods or otherwise, has not been proved, even though the transactions were made through banking channels. 7.4 After considering all the factual and legal aspects of the case, the addition of Rs.14,17,30,000/- made u/s 68 of the Act is sustained and the ground no.1.2 of the appeal is dismissed. …………………… Assessing Officer being unexplained credits

SADBHAV ENGINEERING LTD.,AHMEDABAD vs. DCIT, CENTRAL CIRCLE 1(3), AHMEDABAD, DCIT, CENTRAL CIRCLE 1(3), AHMEDABAD

In the result, all the appeals of the assessee are partly allowed\nand that of the Revenue are dismissed

section 153A of the Act is to be treated as return\nfiled under section 139(1) of the Act. The Ld.Counsel for the assessee\nhas borrowed this proposition to contend that accordingly fresh\nclaims can be made in returns filed u/s 153A of the Act. But, we find,\nthat these decisions have been rendered while addressing completely\ndifferent issue, relating