M/S. YASHASWI FISH MEAL AND OIL COMPANY,UDUPI vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1, MANGALORE

In the result, all the appeals of the assessee are partly allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

bogus booking of purchases found for FY 2017-18 during survey and applying the test of human probabilities reveal that the appellant has inflated its purchases. More importantly this was admitted by the appellant in the statement and has accepted and declared in the return of income for A.Y. 2016-17. ITA Nos.62 to 66/Bang/2023 M/s. Yashaswi Fish Meal

M/S. YASHASWI FISH MEAL AND OIL COMPANY,UDUPI vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1, MANGALORE

In the result, all the appeals of the assessee are partly allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

bogus booking of purchases found for FY 2017-18 during survey and applying the test of human probabilities reveal that the appellant has inflated its purchases. More importantly this was admitted by the appellant in the statement and has accepted and declared in the return of income for A.Y. 2016-17. ITA Nos.62 to 66/Bang/2023 M/s. Yashaswi Fish Meal

M/S. YASHASWI FISH MEAL AND OIL COMPANY,UDUPI vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1, MANGALORE

In the result, all the appeals of the assessee are partly allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

bogus booking of purchases found for FY 2017-18 during survey and applying the test of human probabilities reveal that the appellant has inflated its purchases. More importantly this was admitted by the appellant in the statement and has accepted and declared in the return of income for A.Y. 2016-17. ITA Nos.62 to 66/Bang/2023 M/s. Yashaswi Fish Meal

M/S. YASHASWI FISH MEAL AND OIL COMPANY,UDUPI vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1, MANGALORE

In the result, all the appeals of the assessee are partly allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

bogus booking of purchases found for FY 2017-18 during survey and applying the test of human probabilities reveal that the appellant has inflated its purchases. More importantly this was admitted by the appellant in the statement and has accepted and declared in the return of income for A.Y. 2016-17. ITA Nos.62 to 66/Bang/2023 M/s. Yashaswi Fish Meal

BYSANI SRINATH MAMATHA,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX (OSD) CENTRAL CIRCLE-1(3), BENGALURU

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

bogus purchases, there must be a rational basis, and it cannot be arbitrary. 5.7 Finally, the AR submitted that at the highest, if there were doubts about the genuineness of certain purchases, only the embedded profit could be brought to tax, not the entire amount. This principle has been upheld by the Bombay High Court in Jakharia Fabrics 118 taxmann.com

BYSANI SRINATH MAMATHA,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX, (OSD) CENTRAL CIRCLE-1(3), BENGALURU

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

bogus purchases, there must be a rational basis, and it cannot be arbitrary. 5.7 Finally, the AR submitted that at the highest, if there were doubts about the genuineness of certain purchases, only the embedded profit could be brought to tax, not the entire amount. This principle has been upheld by the Bombay High Court in Jakharia Fabrics 118 taxmann.com

BYSANI ADINARAYAGUPTHA SRINATH,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX(OSD), CENTRAL CIRCLE 1(3), BENGALURU

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

bogus purchases, there must be a rational basis, and it cannot be arbitrary. 5.7 Finally, the AR submitted that at the highest, if there were doubts about the genuineness of certain purchases, only the embedded profit could be brought to tax, not the entire amount. This principle has been upheld by the Bombay High Court in Jakharia Fabrics 118 taxmann.com

BYSANI ADINARAYAGUPTHA SRINATH,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX(OSD), CENTRAL CIRCLE-1(3), BENGALURU

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

bogus purchases, there must be a rational basis, and it cannot be arbitrary. 5.7 Finally, the AR submitted that at the highest, if there were doubts about the genuineness of certain purchases, only the embedded profit could be brought to tax, not the entire amount. This principle has been upheld by the Bombay High Court in Jakharia Fabrics 118 taxmann.com

BYSANI ADINARAYAGUPATHA SRINATH,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX (OSD), CENTRAL CIRCLE-1(3), BENGALURU

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

bogus purchases, there must be a rational basis, and it cannot be arbitrary. 5.7 Finally, the AR submitted that at the highest, if there were doubts about the genuineness of certain purchases, only the embedded profit could be brought to tax, not the entire amount. This principle has been upheld by the Bombay High Court in Jakharia Fabrics 118 taxmann.com

BYSANI SRINATH MAMATHA,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX (OSD), CENTRAL CIRCLE-1(3), BENGALURU

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

bogus purchases, there must be a rational basis, and it cannot be arbitrary. 5.7 Finally, the AR submitted that at the highest, if there were doubts about the genuineness of certain purchases, only the embedded profit could be brought to tax, not the entire amount. This principle has been upheld by the Bombay High Court in Jakharia Fabrics 118 taxmann.com

BYSANI ADINARAYAGUPTHA SRINATH,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX (OSD), CENTRAL CIRCLE-1(3), BENGALURU

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

bogus purchases, there must be a rational basis, and it cannot be arbitrary. 5.7 Finally, the AR submitted that at the highest, if there were doubts about the genuineness of certain purchases, only the embedded profit could be brought to tax, not the entire amount. This principle has been upheld by the Bombay High Court in Jakharia Fabrics 118 taxmann.com

BYSANI SRINATH MAMATHA,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX (OSD), CENTRAL CIRCLE-1(3), BENGALURU

In the result, the appeals of the assessee for

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

bogus purchases, there must be a rational basis, and it cannot be arbitrary. 5.7 Finally, the AR submitted that at the highest, if there were doubts about the genuineness of certain purchases, only the embedded profit could be brought to tax, not the entire amount. This principle has been upheld by the Bombay High Court in Jakharia Fabrics 118 taxmann.com

BYSANI ADINARAYAGUPTHA SRINATH,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX (OSD), CENTRAL CIRCLE-1(3), BENGALURU

In the result, the appeals of the assessee for Assessment Years

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

bogus purchases, there must be a rational basis, and it cannot be arbitrary. 5.7 Finally, the AR submitted that at the highest, if there were doubts about the genuineness of certain purchases, only the embedded profit could be brought to tax, not the entire amount. This principle has been upheld by the Bombay High Court in Jakharia Fabrics 118 taxmann.com

BYSANI SRINATH MAMATHA,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX (OSD) CENTRAL CIRCLE-1(3), BENGALURU

In the result, the appeals of the assessee for Assessment Years

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

bogus purchases, there must be a rational basis, and it cannot be arbitrary. 5.7 Finally, the AR submitted that at the highest, if there were doubts about the genuineness of certain purchases, only the embedded profit could be brought to tax, not the entire amount. This principle has been upheld by the Bombay High Court in Jakharia Fabrics 118 taxmann.com

BYSANI SRINATH MAMATHA,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX(OSD), CENTRAL CIRCLE-1(3), BENGALURU

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

bogus purchases, there must be a rational basis, and it cannot be arbitrary. 5.7 Finally, the AR submitted that at the highest, if there were doubts about the genuineness of certain purchases, only the embedded profit could be brought to tax, not the entire amount. This principle has been upheld by the Bombay High Court in Jakharia Fabrics 118 taxmann.com

M/S. RUKMINI EDUCATIONAL CHARITABLE TRUST ,BENGALURU vs. PRINCIPAL COMMISSIONER OF INCOME TAX, CENTRAL , BANGALORE

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

sections of people without any discrimination of caste, creed race or religion. (c) To assist, promote, establish, run, takeover and or manage orphanage, rescue and/or half-way homes for destitute, aged and the inform and/or senior citizens without discrimination of caste, creed, race, religion, status or standing. (d) To give out grants, scholarships, stipends, rewards, awards, certificates, financial

M/S. PAUL RESORTS & HOTELS PVT LTD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX. CENTRAL CIRCLE-1(1), BANGALORE

115\n33,97,88,690\nNA\nDetails of undisclosed income declared\nbogus expenses\n1,07,76,926\n2,23,19,384\n2,07,19,771\n2,59,74,970\n1,10,65,726\n1,12,08,242\nNA\nand promotion\nexpenses

JOHN DISTILLERIES PVT LTD.,,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), BANGALORE

bogus contractors bills. These cash that is\ngenerated are routed back to Bangalore through our cars. This we will use it for multiple\npurposes such as personal expenses, capital, payouts etc. The entire handling of cash is done\nby me and my assistant Shri. Mathew Joseph.\nPage 47 of 147\n20.8 However, it is noted by the ld. AO that

JOHN DEVELOPERS ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), BANGALORE

bogus purchase and inflated transport expenses (c) The additional ground is that there is no transaction with the said contractors during the assessment year 2013-14 and 2015-16 and hence no addition called for in these assessment years. 18.1 The ld. A.R. submitted that there was no incriminating material found during the course of search action