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

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

7. In view of the same, we see no reason to interfere in the order of the ld.CIT(A) upholding the disallowance of claim of weighted deduction to the assessee under section 35(2AB) of the Act, amounting in all to Rs.87,65,436/-, in the absence of the requisite approval by the prescribed authority to the in-house

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

7. In view of the same, we see no reason to interfere in the order of the ld.CIT(A) upholding the disallowance of claim of weighted deduction to the assessee under section 35(2AB) of the Act, amounting in all to Rs.87,65,436/-, in the absence of the requisite approval by the prescribed authority to the in-house

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

bogus purchases in accordance with law and thus revision under section. 263 is nothing but a change of opinion and hence order u/s. 263 is bad in law. 2. The directions given to AO in para 7

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 of the Act treating the purchases from M/s. Mahadev Trading Co. as bogus, resulting in the assessed income being enhanced to Rs. 1,55,90,420/-. The CIT(A), while partly allowing the appeal of the assessee, restricted the disallowance to Rs. 7

THE JT.CIT, CIRCLE-6(1),, AHMEDABAD vs. SHRI NILESH RAMESHCHANDRA SHAH,, AHMEDABAD

In the result, appeal filed by the Revenue is hereby dismissed

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

section 271(1)(c) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Year 2010-11. I.T.A No. 267/Ahd/2020 A.Y. 2010-11 Page No 2 Jt. CIT Vs. Shri Nilesh Rameshchandra Shah 2. The Registry has noted that there is a delay of 8 days in filing the above appeal by the Revenue

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

bogus and 15% of the purchases was considered as income of the assessee and accordingly an addition of Rs.43,70,583/- was made. No transaction was found made with the other party M/s. A.M. Enterprise during the year. The assessment was completed under Section 143(3) read with Section 147 of the Act on 27.12.2019 at total income of Rs.42

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

bogus and 15% of the purchases was considered as income of the assessee and accordingly an addition of Rs.43,70,583/- was made. No transaction was found made with the other party M/s. A.M. Enterprise during the year. The assessment was completed under Section 143(3) read with Section 147 of the Act on 27.12.2019 at total income of Rs.42

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

purchase\nexpenses.\n67. ISSUE NO.4 REGARDING TREATMENT OF ALLEGED BOGUS\nSUB-CONTRACT EXPENSES UNDER SECTION 69A AND 69C OF\nTHE ACT AND CHARGING THE SAME AT THE RATE SPECIFIED\nIN TERMS OF SECTION 115BBE OF THE ACT.\n68. The next issue being taken for consideration is the\ntreatment of the alleged bogus sub-contract expenses as deemed\nincome

INDIAN ION EXCHANGE & CHEMICALS LIMITED,AHMEDABAD vs. THE ITO, WARD-2(1)(1) PREVIOUSLY WARD-2(1)(3), AHMEDABAD

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

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaassessment Year: 2014-15

Section 148 of the Act. In the course of hearing, the Ld. AR of the assessee did not press this ground. Hence, this ground is dismissed. 6. The next ground pertains to addition of Rs.92,20,100/- on account of bogus purchase from M/s. Siddh Syndicate. Shri Biren Shah, Ld. AR of the assessee, explained that the assessee company

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

7. Aggrieved by the order of the Ld. CIT(A) confirming the disallowance @ 2% of the alleged bogus purchases of Rs.12,61,68,630/-, the assessee is now in appeal before the Tribunal. 8. We have heard the rival contentions and perused the material available on record. We find that the reason for making the impugned addition was that

BALDEVBHAI LALABHAI LUHAR,AHMEDABAD vs. INCOME TAX OFFICER, WARD-1(1)(2), PRATYAKSHAR BHAVAN,AHMEDABAD

In the result, the ground no

Bench: Shri Siddhartha Nautiyal & Shri Makarand Vasant Mahadeokar

7– Appeal No. 553 2012, Gujarat High Court wherein it was held that where purchases were not bogus but where made from the parties other then those mentioned in books of account, not the entire purchase price but only profit element embedded in such purchases can be added to income of assessee. Accordingly, the AO estimated the GP ratio

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

Section 148 of the Act. In the course of hearing Shri Ketan Shah, Ld. AR of the assessee, did not press these grounds. Hence, the ground number 1 to 3 as taken by the assessee are dismissed. 6. Ground number 4 to 7 pertain to addition of Rs. 42,95,000/- made on account of bogus purchase

SANKET RAMNIKLAL JOISAR,AHMEDABAD vs. INCOME TAX WARD 1(2)(1), AHD, AHMEDABAD

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

7 of the assessment order. Ld. Counsel for\nthe assessee pointed out that during assessment proceedings, the\nassessee furnished complete details of purchases made by him\nduring the year in his business of wholesale of waste, scrap and\nmaterials for re-cycling purposes. The complete books of\naccounts were furnished to the AO and all supporting documents\nalso were filed

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

section 144B. On merits, it was contended that the Assessing Officer erred in disallowing the purchase expenditure of ₹77,61,745/- by treating it as bogus, without properly appreciating the evidence and explanations furnished during the assessment proceedings. 7

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 purchase bills through Shri Gurukamal Singh, proprietor of M/s Preet Enterprise, operating through multiple entities. It was alleged that the assessee had shown purchases from M/s Hamalloys Exim and M/s Bankey Bihari Industries, which were stated to be involved in issuance of accommodation bills without actual supply of goods. 7. During the reassessment proceedings, the Assessing Officer examined

HAJIMOHMADSAFI ABDULREHMAN SHAIKH,VADODARA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 2(1)(1), VADODARA

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

purchases as bogus without properly appreciating the facts and evidences on record. It was further contended that the Assessing Officer had relied upon statements of third parties and enquiries conducted under sections 131/133(6) of the Act without affording adequate opportunity of cross-examination and without furnishing copies of material relied upon. The assessee also challenged the addition