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

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

section 2(24BA) of I.T.Act as under: “Manufacture” with its grammatical variations means a change in non-living physical object or article or thing:- a) Resulting in transformation of the object or article or thing into a new and distinct object or article or thing having a different name, character and use, or b) Bringing into existence

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

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

section 2(24BA) of I.T.Act as under: “Manufacture” with its grammatical variations means a change in non-living physical object or article or thing:- a) Resulting in transformation of the object or article or thing into a new and distinct object or article or thing having a different name, character and use, or b) Bringing into existence

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 bars the allowability of unexplained expenditure. 21. On the same issue he further relied on the decision of the Hon’ble Bombay High court in the case of PCIT vs Drisha Impex Pvt Ltd dated 7th April, 2025 (ITA No 1240 with ITA No 2087 of 2018), and submitted that the entire purchase being bogus needs to be disallowed

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

section 151 by considering the issues. During the hearing the learned counsel produced “office note” of revenue department which is mentioned above. After a quick look on the “office note” of revenue dated 16/03/2016, it is observed that the verification of documents with books of accounts of assessee & an application of mind related bogus purchase was made by the assessing

NASA AGRO INDUSTRIES PRIVATE LIMITED,FAZILKA vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-II, BATHINDA

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

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

32. Ground No 4 (already discussed above ) 33. Ground no 5 : Here the Ld A/R of the assessee has prayed that in case the alleged purchases are treated as bogus, in such a situation, he prays that the entire purchase alleged as bogus amounting to Rs. 51.57 lakhs should not be disallowed but only the profit element embedded in such

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

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

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

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

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 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

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

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 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

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