INCOME TAX OFFICER, JAMMU vs. SH. PUNEET SEHDEV, PROP., JAMMU

Bench: Shri L. P. Sahu & Shri Ravish Sood

bogus purchases. The AO did not appreciate that these were genuine purchases and all the purchases were duly accounted for in the books of accounts and their sales were duly accepted in toto. As such, the A.O has blown hot & cold in the same breath/. Shri Puneet Sehdev Vs. ITO, Ward 2(2), Jammu

SH. PUNEET SEHDEV PROP;,JAMMU vs. THE INCOME-TAX OFFICER,, JAMMU

Bench: Shri L. P. Sahu & Shri Ravish Sood

bogus purchases. The AO did not appreciate that these were genuine purchases and all the purchases were duly accounted for in the books of accounts and their sales were duly accepted in toto. As such, the A.O has blown hot & cold in the same breath/. Shri Puneet Sehdev Vs. ITO, Ward 2(2), Jammu

SH. PUNEET SEHDEV PROP,JAMMU vs. THE INCOME-TAX OFFICER, JAMMU

Bench: Shri L. P. Sahu & Shri Ravish Sood

bogus purchases. The AO did not appreciate that these were genuine purchases and all the purchases were duly accounted for in the books of accounts and their sales were duly accepted in toto. As such, the A.O has blown hot & cold in the same breath/. Shri Puneet Sehdev Vs. ITO, Ward 2(2), Jammu

PUNEET SAHDEV,JAMMU vs. THE INCOME TAX OFFICER, JAMMU

Bench: Shri L. P. Sahu & Shri Ravish Sood

bogus purchases. The AO did not appreciate that these were genuine purchases and all the purchases were duly accounted for in the books of accounts and their sales were duly accepted in toto. As such, the A.O has blown hot & cold in the same breath/. Shri Puneet Sehdev Vs. ITO, Ward 2(2), Jammu

MESERS SUPERTECH FORGINGS(INDIA) PVT.LTD.,JALANDHAR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE IV, JALANDHAR

In the result, the appeal of the Assessee is allowed

Section 37(1) of the Income-tax Act, 1961 - Business expenditure - Allowability of (Bogus purchase) - Certain portion of purchases made by assessee was disallowed - Commissioner (Appeals) found that entire disallowance was based on third party information gathered by Investigation Wing of Department, which had not been independently subjected to further verification by Assessing Officer and he had not provided copy

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR vs. M/S PUNJAB RICE LAND PRIVATE LIMITED , TARN TARAN

In the result, both the appeals of the revenue are dismissed and

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

2,55,52,126/- respectively during the year consideration. Accordingly, the AO rejected the contention of the assessee regarding maintaining the complete stock record and acceptance of the same while passing order u/s 143(3) and disallowed the purchases amounting to Rs. 3,21,96,804/- and added to the income of the assesse for the assessment year

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR vs. M/S PUNJAB RICE LAND PRIVATE LIMITED, TARN TARAN

In the result, both the appeals of the revenue are dismissed and

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

2,55,52,126/- respectively during the year consideration. Accordingly, the AO rejected the contention of the assessee regarding maintaining the complete stock record and acceptance of the same while passing order u/s 143(3) and disallowed the purchases amounting to Rs. 3,21,96,804/- and added to the income of the assesse for the assessment year

NEERAJ KUMAR SETHI,DELHI vs. ITO, NATIONAL FACELESS APPEAL CENTRE (NFAC)

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

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

section 144B of the Act, 1961 dated 29.03.2022. 2 I.T.A. No. 9/Asr/2024 Assessment Year: 2014-15 2. The grounds of appeal preferred by the assessee in form 36 has been subsequently revised and the revised grounds are as follows: “1. That the assessment order framed by the AO is void ab-initio having been framed without giving reasonable opportunity

INCOME TAX OFFICER, WARD-1, FARIDKOT, BSNL BUILDING vs. M/S VOHRA SOLVEX PVT. LTD, SADIQ ROAD

In the result, C.O. filed by the assessee is allowed

Bench: Sh. Udayan Dasgupta & Sh. Krinwant Sahay

section 68 solely on basis of information received from Investigation Wing that lenders from whom assessee-company acquired loans were indulged in bogus accommodation entries, since assessee was not granted an opportunity to cross-examine persons whose statements were recorded during Investigation, Impugned addition made on basis of such investigation which was not privy to assessee were to be deleted

SHRI SHAM SUNDER AGGARWAL,KAPURTHALA vs. PRINCIPAL COMMISSIONER OF INCOME TAX -2 , KAPUTHALA

In the result, the appeal of the assessee, ITA

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

2 of sub-section 1 of Section 263 also provides that the order which is passed without making inquiries/verification, which should have been made, shall be deemed to be erroneous in so far as it is prejudicial to the interest of revenue. 8. Therefore, the said order passed on 29.12.2016 is set-aside to the file of the assessing officer

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR vs. M/S NARULA OIL & FATS PRIVATE LIMITED, AHMEDABAD

In the result, the appeals of the revenue are dismissed and appeals of assessee are allowed in the terms indicated above

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

purchases are shown on credit of much longer period from bogus and paper concerns. M/s Narula Solvex P Ltd. is a sister concern of the assessee company, operates in same line of business, managed by common management and accordingly it is natural that similar practice is adopted by the assessee also.” 6.1 Related argumentby challenging the maintainability of section 153D

M/S NARULA FOODS PRIVATE LIMITED,FEROZEPUR vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR

In the result, the appeals of the revenue are dismissed and appeals of assessee are allowed in the terms indicated above

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

purchases are shown on credit of much longer period from bogus and paper concerns. M/s Narula Solvex P Ltd. is a sister concern of the assessee company, operates in same line of business, managed by common management and accordingly it is natural that similar practice is adopted by the assessee also.” 6.1 Related argumentby challenging the maintainability of section 153D

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR vs. M/S NARULA OIL & FATS PRIVTE LIMITED, AHMEDABAD

In the result, the appeals of the revenue are dismissed and appeals of assessee are allowed in the terms indicated above

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

purchases are shown on credit of much longer period from bogus and paper concerns. M/s Narula Solvex P Ltd. is a sister concern of the assessee company, operates in same line of business, managed by common management and accordingly it is natural that similar practice is adopted by the assessee also.” 6.1 Related argumentby challenging the maintainability of section 153D

MEASAGE NARULA SOLVEX PRIVATE LIMITED,MOGA vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR

In the result, the appeals of the revenue are dismissed and appeals of assessee are allowed in the terms indicated above

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

purchases are shown on credit of much longer period from bogus and paper concerns. M/s Narula Solvex P Ltd. is a sister concern of the assessee company, operates in same line of business, managed by common management and accordingly it is natural that similar practice is adopted by the assessee also.” 6.1 Related argumentby challenging the maintainability of section 153D

MEASAGE NARULA SOLVEX PRIVATE LIMITED,MOGA vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE , AMRITSAR

In the result, the appeals of the revenue are dismissed and appeals of assessee are allowed in the terms indicated above

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

purchases are shown on credit of much longer period from bogus and paper concerns. M/s Narula Solvex P Ltd. is a sister concern of the assessee company, operates in same line of business, managed by common management and accordingly it is natural that similar practice is adopted by the assessee also.” 6.1 Related argumentby challenging the maintainability of section 153D

M/S NARULA FOODS PRIVATE LIMITED,FEROZEPUR vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR

In the result, the appeals of the revenue are dismissed and appeals of assessee are allowed in the terms indicated above

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

purchases are shown on credit of much longer period from bogus and paper concerns. M/s Narula Solvex P Ltd. is a sister concern of the assessee company, operates in same line of business, managed by common management and accordingly it is natural that similar practice is adopted by the assessee also.” 6.1 Related argumentby challenging the maintainability of section 153D

M/S NARULA FOODS PRIVATE LIMITED,FEROZEPUR vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR

In the result, the appeals of the revenue are dismissed and appeals of assessee are allowed in the terms indicated above

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

purchases are shown on credit of much longer period from bogus and paper concerns. M/s Narula Solvex P Ltd. is a sister concern of the assessee company, operates in same line of business, managed by common management and accordingly it is natural that similar practice is adopted by the assessee also.” 6.1 Related argumentby challenging the maintainability of section 153D

MEASAGE SAT KARTAR SOLVEX PRIVATE LIMITED,FEROZEPUR vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR

In the result, the appeals of the revenue are dismissed and appeals of assessee are allowed in the terms indicated above

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

purchases are shown on credit of much longer period from bogus and paper concerns. M/s Narula Solvex P Ltd. is a sister concern of the assessee company, operates in same line of business, managed by common management and accordingly it is natural that similar practice is adopted by the assessee also.” 6.1 Related argumentby challenging the maintainability of section 153D

M/S NARULA OIL & FATS PRIVATE LIMITED,AHEMDABAD vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR

In the result, the appeals of the revenue are dismissed and appeals of assessee are allowed in the terms indicated above

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

purchases are shown on credit of much longer period from bogus and paper concerns. M/s Narula Solvex P Ltd. is a sister concern of the assessee company, operates in same line of business, managed by common management and accordingly it is natural that similar practice is adopted by the assessee also.” 6.1 Related argumentby challenging the maintainability of section 153D