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

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 of such statements to appellant, thus, denying opportunity of cross examination to appellant

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

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

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

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

34 of the paper book alleged claim of bogus purchase amount of Rs.4,05,57,307/-. The amount of bogus purchase was informed from the Sales Tax order. During the assessment proceedings, the assessee had confronted about the alleged bogus purchase related to 8 different parties as provided by the Sales Tax Department. However, the assessee as per his reply

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

34. The Ld. DR however, is not agreeable on this issue , and he drew reference to the decision of 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

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 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

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

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 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