ARCOY INDUSTRIES (INDIA) PRIVATE LIMITED,AHMEDABAD vs. THE DCIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, all the captioned four appeals of the assessee are hereby\nallowed

money given for purchase of the goods to the parties is returned\nthrough bogus sales. The difference of the purchases and sales of Rs 14,99,03,809/-\nhad been given as cash. It can be seen from the tables provided by Chirag Thakkar\nthat the purchase made from Overseas polymers Pvt Ltd, Anshul Agencies, Faith\nInnovation, Lakeland Chemical

ARCOY INDUSTRIES (INDIA) PRIVATE LIMITED,AHMEDABAD vs. THE DCIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, all the captioned four appeals of the assessee are hereby allowed

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

money given for purchase of the goods to the parties is returned through bogus sales. The difference of the purchases and sales of Rs 14,99,03,809/- had been given as cash. It can be seen from the tables provided by Chirag Thakkar that the purchase made from Overseas polymers Pvt Ltd, Anshul Agencies, Faith Innovation, Lakeland Chemical

ARCOY INDUSTRIES (INDIA) PRIVATE LIMITED,AHMEDABAD vs. THE DCIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, all the captioned four appeals of the assessee are hereby allowed

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

money given for purchase of the goods to the parties is returned through bogus sales. The difference of the purchases and sales of Rs 14,99,03,809/- had been given as cash. It can be seen from the tables provided by Chirag Thakkar that the purchase made from Overseas polymers Pvt Ltd, Anshul Agencies, Faith Innovation, Lakeland Chemical

ARCOY INDUSTRIES (INDIA) PRIVATE LIMITED,AHMEDABAD vs. THE DCIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, all the captioned four appeals of the assessee are hereby allowed

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

money given for purchase of the goods to the parties is returned through bogus sales. The difference of the purchases and sales of Rs 14,99,03,809/- had been given as cash. It can be seen from the tables provided by Chirag Thakkar that the purchase made from Overseas polymers Pvt Ltd, Anshul Agencies, Faith Innovation, Lakeland Chemical

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1, BHAVNAGAR, BHAVNAGAR vs. RUDRA GLOBAL INFRA PRODUCTS LIMITED, BHAVNAGAR

In the result, the appeal of the Revenue as well as the Cross-Objection filed by the assessee, both are dismissed

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

money is received by the assessee company from alleged bogus shareholders, whose names are given to the Assessing Officer, then the department is free to proceed to reopen their individual assessments in accordance with law. But the said amount cannot be taken as unexplained income in the hands of the assessee. 4. In view of the above

ACIT CC 2(3) AHMEDABAD, AHMEDABAD vs. AISHA DHIRAJ GOGIA, AHMEDABAD

In the result: 50. To summarize the final outcome:

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha["ी संजय गग", "ाियक सद" एवं "ी नरे" साद िस!ा, लेखा सद" के सम#।]

unexplained note about a third-party property to all the properties purchased by the assessees, herein, and thereby making impugned additions based on assumptions and presumptions, is arbitrary and devoid of any legal sanctity. The assessee provided evidence that the property mentioned in the note (C-339) was sold by its owner at a rate far lower than

HIRAL TAPANKUMAR CHUDGAR,VADODARA, GUJARAT vs. INCOME TAX OFFICER, WARD 1(3)(1), VADODARA, VADODARA, GUJARAT

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

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

unexplained money or investment under Sections 69A or 69 of the Income Tax Act, 1961, and no income has escaped assessment. Further CIT(Appeals) has erred in dismissing the appeal. Therefore, Section 115BBE cannot be invoked, and its application in this case is both legally and factually incorrect. The application of Section 115BBE should be deleted

REKHABEN INDRAVADAN CHOKSHI,AHMEDABAD vs. INCOME TAX OFFICER,WARD-5(2)(4), AHMEDABAD

In the result, the Department’s appeal is dismissed

Bench: Smt. Annapurna Gupta (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

bogus and fabricated in nature. Therefore, apparently looking into the instant facts, the purchases were only essentially book entries in order to accommodate the bogus/cash sales to account for the unexplained money

ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), AHMEDABAD vs. REKHA INDRAVADAN CHOKSHI, AHMEDABAD

In the result, the Department’s appeal is dismissed

Bench: Smt. Annapurna Gupta (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

bogus and fabricated in nature. Therefore, apparently looking into the instant facts, the purchases were only essentially book entries in order to accommodate the bogus/cash sales to account for the unexplained money

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

KARTIK CLOTHING & FABRICS PRIVATE LIMITED,AHMEDABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 2(1)(1), AHMEDABAD

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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

unexplained money under Section 69A and dismissed the appeal of the assessee. 5. The assessee is in appeal before us against the order passed by CIT(Appeals) dismissing the appeal of the assessee. Before us, the Counsel for the assessee submitted that the assessee is a trader in clothes and does not sell in cash. The assessee had submitted list

JHAVERI TRADING AND INVESTMENT PRIVATE LIMITED,AHMEDABAD vs. THE DY.CIT, CENT. CIRCLE-1(1), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleassessment Year 2012-13

bogus loss of Rs. 1,16,34,317/- for purchase of aforesaid shares be not treated as unexplained income u/s . 69 of the Income Tax Act. 3.3 In response to the said show cause notice, the assessee furnished objections dated 25-05-2019. After taking cognizance of the same, the Assessing Officer observed that physical shares in the aforesaid scrip

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

bogus. Though the AO has doubted the purchases, it is not the case of the AO that the assessee had not debited the amount of purchases from its books or that the assessee had made purchases out of its unexplained income. Once the purchases are accepted and the stock is not disputed, the sales flowing out of such stock Bhaumik

HIRAL TAPANKUMAR CHUDGAR,VADODARA, GUJARAT vs. INCOME TAX OFFICER, WARD 1(3)(1), VADODARA, VADODARA, GUJARAT

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

Bench: Shri T.R. Senthil Kumar, Judicial Member And\nShri Makarand Vasant Mahadeokar, Accountant Member\nITA Nos 43 & 44/Ahd/2025\nAssessment Years: 2017-18 & 2018-19\nHiral Tapankumar\nChudgar\n201/A, Premdarshan,\nBehind Jay Ambe School,\nSamasavli Raod, Vemali,\nVadodara-390008,\nGujarat\nPAN: ANCPC4000H\n(Appellant)\nIncome Tax Officer\nWard-1(3)(1),\nVs Vadodara\n(Respondent)\nAssessee Represented:\nShri Deepak Shah, A.R.\nRevenue Represented:\nShri Abhijit, Sr.D.R.\nDate of hearing\n: 18-06-

unexplained money or\ninvestment under Sections 69A or 69 of the Income Tax Act, 1961, and no\nincome has escaped assessment. Further CIT(Appeals) has erred in\ndismissing the appeal. Therefore, Section 115BBE cannot be invoked, and\nits application in this case is both legally and factually incorrect. The\napplication of Section 115BBE should be deleted

INCOME TAX OFFICER, WARD - 3(3)(5), AHMEDABAD, PANJARAPOLE, AHMEDABAD vs. VIKASH MORE, BODAKDEV, AHMEDABAD

In the result, appeal filed by the Revenue is dismissed

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinhaassessment Year: 2016-17

unexplained money under Section 69A read with Section 115BBE of the Act. The Ld. DR submitted that the assessee sold the shares of M/s Kushal Tradelink Pvt. Ltd. on account of transfer of shares at Rs.1,35,72,928/- as claimed as LTCG and the same was claimed as exempt income under Section

ACIT, ANAND CIRCLE, ANAND vs. NARENDRAKUMAR HANSRAJBHAI PATEL, KHEDA

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinhaआयकर अपील सं /Ita No.834/Ahd/2024 िनधा"रण वष" /Assessment Year : 2021-22 The Acit Narendrakumar Hansrajbhai बनाम/ Dy./Asst.Commissioner Of Patel V/S. Income Tax (Anand Circle) I C/O. Mahakali Saw Mill Anand – 388 001 Mansarovar Marker Kamla Kamia, Kheda – 387 320 "थायी लेखा सं./Pan: Cmmpp 6784 N (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Mishal Mehta, Ca Revenue By : Shri Alpesh Parmar, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 28/08/2025 घोषणा की तारीख /Date Of Pronouncement: 29/10/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm: The Present Appeal Has Been Preferred By The Revenue Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 27/02/2024 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2021-2022. 2. The Revenue Has Raised The Following Grounds Of Appeal: “1. Whether, On Facts & In Circumstances Of The Case & In Law, The Ld.Cit(A) Is Justified In Deleting The Addition Of Rs. 10,64,04,151/-Made U/S 69C Of The Act Without Appreciating The Fact The Assessee Failed To Substantiate The Expenditure Claimed With Supporting Evidences? Asst.Cit Vs. Narendrakumar Hansrajbhai Patel Asst. Year : 2021-22

unexplained expenditure under section 69C of the Act and added ₹10,64,04,151/- to the total income of the assessee, completing the assessment under section 143(3) of the Act. 4. Aggrieved by the addition, the assessee preferred an appeal before the Commissioner of Income Tax (Appeals). Before the CIT(A), the assessee submitted written arguments along with documentary

CHIMANBHAI CHHAGANBHAI POKAL, HUF,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-3(3)(1), AHMEDABAD

In the result, Ground No. 2 of the assessee's appeal allowed for\nstatistical purposes

unexplained cash credit u/s 68 of IT Act, 1961.\nGround No. 1:- Disallowance on account of bogus penny stock\n4.\nThe brief facts of the case are that the Assessing Officer received\ninformation from DDIT (Investigation), Calcutta that M/s. Jai Maa Kali\nEnterprise (Proprietor Shri Mukesh Kumar Gupta) indulged in suspicious\ntransactions relating to cash deposits. It was found that

NIRMAN,AHMEDABAD vs. DCIT, CIRCLE-2(1)(1),, AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalnirman, Vs. 35, Vasantkunj Society, New Dcit, Sharda Mandir Road, Paldi, Circle-2(1)(1), Ahmedabad-380007 Ahmedabad [Pan :Aabfn 7155 L] (Appellant) .. (Respondent) Appellant Represented By : Shri Parin Shah, Ar Respondent Represented By: Shri C. Dharani Nath, Sr Dr Date Of Hearing 03.02.2026 Date Of Pronouncement 13.02.2026 O R D E R Per Dr. B.R.R. Kumar, Vice-:-

unexplained money u/s 69A of the Act and added the same to the income of the assessee. 4. For the sake of ready reference, the reasons recorded for reopening the case are reproduced here asunder:- “BASIS OF FORMING REASON TO BELIEVE AND DETAILS OF ESCAPEMENT OF INCOME: As per the information received from Dy. Director of Income-Tax(Inv.), Unit

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

bogus in nature.\n5. Similarly, in respect of the gift of Rs. 8,50,000/- claimed to have been\nreceived from the assessee's brother, it was also explained to have\noriginated from M/s Veer Chem. The AO found that the firm did not have\nsufficient cash balance to support such withdrawal and that the bank entries\ndid not correlate