M/S. MUKKA PROTEINS LIMITED (FORMERLY KNOW AS MUKKA SEA FOOD INDUSTRIES LTD., ),MANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, MANGALORE

bogus\nentries in books.\n(2)\nSo, when ‘NO PURCHASE” was made, obviously there\nwas “NO SALE”. So, there is no question of any profit\nelement.\n4.6 Regarding ground of appeals No.8 in ITA Nos. 431-\n434/Β/2024(A.Y.2013-14 to A.Y.2016-17) & ground of appeals\nNo.9 in ITA Nos.435/B/2024 (A.Y.2017-18) she submitted that\nSanction u/s 153 D not adjudicated

M/S. EAGLE TRADERS & LOGISTICS,BELLARY vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 2(3), BANGALORE

Accordingly, the appeals filed by the assessee are allowed in above terms

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

bogus entry and it is proved beyond reasonable doubt that it is only an adjustment entry to reduce the profits as per books by inflating expenditure and reducing tax liability thereon. In the light of the above, the assessee was further asked to substantiate why section 40A(3) of the Act should not be invoked in the assessee’s case

M/S. EAGLE TRADERS & LOGISTICS,BELLARY vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 2(3), BANGALORE

Accordingly, the appeals filed by the assessee are allowed in above terms

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

bogus entry and it is proved beyond reasonable doubt that it is only an adjustment entry to reduce the profits as per books by inflating expenditure and reducing tax liability thereon. In the light of the above, the assessee was further asked to substantiate why section 40A(3) of the Act should not be invoked in the assessee’s case

M/S. EAGLE TRADERS & LOGISTICS,BELLARY vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 2(3), BANGALORE

Accordingly, the appeals filed by the assessee are allowed in above terms

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

bogus entry and it is proved beyond reasonable doubt that it is only an adjustment entry to reduce the profits as per books by inflating expenditure and reducing tax liability thereon. In the light of the above, the assessee was further asked to substantiate why section 40A(3) of the Act should not be invoked in the assessee’s case

M/S. HARIS MARINE PRODUCTS,MANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,, MANGALORE

In the result, both the appeals of the assessee are\nallowed

153 of the Act. By virtue of the 2017 Amending\nAct, significant amendments came to be introduced in Section\n153A. These included, inter alia, the search assessment block\nbeing enlarged to ten AYs' consequent to the addition of the\nstipulation of “relevant assessment year” and which was\ndefined to mean those years which would fall beyond the six\nyear block

M/S. HARIS MARINE PRODUCTS,MANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, , MANGALORE

In the result, both the appeals of the assessee are\nallowed

153 of the Act. By virtue of the 2017 Amending\nAct, significant amendments came to be introduced in Section\n153A. These included, inter alia, the search assessment block\nbeing enlarged to ten AYs' consequent to the addition of the\nstipulation of “relevant assessment year” and which was\ndefined to mean those years which would fall beyond the six\nyear block

DCIT, CENTRAL CIRCLE-1(3), BAENGALURU vs. LATE SHRI MAHABIR PRASAD(LEGAL HEIR MS. PARUL KANSARIA), BENGALURU

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

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

purchase amount of ₹ 43,825,000/– as bogus. Accordingly, he confirmed the addition. The assessee is aggrieved and is in appeal before us. ITA Nos.410-412-169-170- CO 6/Bang/2024 Page 13 of 40 23. Firstly, we come to the appeal of the learned assessing officer filed for assessment year 2017 – 18 in ITA number 169/Bengaluru/2024 and for assessment year

LATE SHRI MAHABIR PRASAD(LEGAL HEIR MS. PARUL KANSARIA),BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(3) , BENGALURU

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

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

purchase amount of ₹ 43,825,000/– as bogus. Accordingly, he confirmed the addition. The assessee is aggrieved and is in appeal before us. ITA Nos.410-412-169-170- CO 6/Bang/2024 Page 13 of 40 23. Firstly, we come to the appeal of the learned assessing officer filed for assessment year 2017 – 18 in ITA number 169/Bengaluru/2024 and for assessment year

LATE SHRI MAHABIR PRASAD(LEGAL HEIR MS. PARUL KANSARIA),BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3) , BENGALURU

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

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

purchase amount of ₹ 43,825,000/– as bogus. Accordingly, he confirmed the addition. The assessee is aggrieved and is in appeal before us. ITA Nos.410-412-169-170- CO 6/Bang/2024 Page 13 of 40 23. Firstly, we come to the appeal of the learned assessing officer filed for assessment year 2017 – 18 in ITA number 169/Bengaluru/2024 and for assessment year

LATE SHRI MAHABIR PRASAD(LEGAL HEIR MS. PARUL KANSARIA),BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BENGALURU

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

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

purchase amount of ₹ 43,825,000/– as bogus. Accordingly, he confirmed the addition. The assessee is aggrieved and is in appeal before us. ITA Nos.410-412-169-170- CO 6/Bang/2024 Page 13 of 40 23. Firstly, we come to the appeal of the learned assessing officer filed for assessment year 2017 – 18 in ITA number 169/Bengaluru/2024 and for assessment year

M/S. EAGLE TRADERS & LOGISTICS,BELLARY vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 2(3), BANGALORE

bogus entry and it is proved beyond reasonable doubt\nthat it is only an adjustment entry to reduce the profits as per books by inflating\nexpenditure and reducing tax liability thereon. In the light of the above, the\nassessee was further asked to substantiate why section 40A(3) of the Act should\nnot be invoked in the assessee's case

M/S. HARIS MARINE PRODUCTS,MANGALURU vs. PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL), BENGALURU, BENGALURU

In the result, the appeal by the assessee is allowed

Bench: Shri N.V. Vasudevan, Vice Preseident & Shri Padmavathy S

bogus purchase in assessment year 2018-19. In view of these facts which is clearly coming out of the AO’s order, we see no merit in the conclusion of the PCIT that the AO has not examined the facts and not done proper verification. 27. With regard to the argument that the assessee’s case needs to be considered

DCIT, CENTRAL CIRCLE-1(3), BENGALURU vs. LATE SHRI MAHABIR PRASAD (LEGAL HEIR MS. PARUL KANSARIA), BENGALURU

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

bogus purchases for assessment year 2018 19\nu/s.69C of the Act of ₹ 42,815,000/- the learned CIT – A held that\napart from stating that the relevant bills/invoices/payments details\nand GST returns have been submitted no other details has been\nfurnished by the assessee to show that the purchases are real. Therefore, he upheld the findings of the learned assessing

M/S SPR SPIRITS PVT.LTD. ,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -1 (3) , BENGALURU

In the result, assessee’s appeal in ITA No

Bench: Shri Chandra Poojari & Smt. Beena Pillai

bogus purchase of Rs.27,49,31,180/- from various concerns for which Shri Suresh Gowda, Executive Director of the company agreed and offered additional income of Rs.9.96 crores in the hands of SPR Group Holdings Pvt. Ltd. Vide his statement recorded u/s 132(4) of the Act on 9.2.2011 for the financial year 2008-09 to financial year ITA Nos.1658

DEPUTY COMMISSIONER OF INCOME TAX,CENTRAL CIRCLE- 1(3), BANGALORE vs. SHRI. T. NADAKRISHNA, BANGALORE

In the result, assessee’s appeal in ITA No

Bench: Shri Chandra Poojari & Smt. Beena Pillai

bogus purchase of Rs.27,49,31,180/- from various concerns for which Shri Suresh Gowda, Executive Director of the company agreed and offered additional income of Rs.9.96 crores in the hands of SPR Group Holdings Pvt. Ltd. Vide his statement recorded u/s 132(4) of the Act on 9.2.2011 for the financial year 2008-09 to financial year ITA Nos.1658

M/S SPR SPIRITS PVT. LTD.,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -1 (3) , BENGALURU

In the result, assessee’s appeal in ITA No

Bench: Shri Chandra Poojari & Smt. Beena Pillai

bogus purchase of Rs.27,49,31,180/- from various concerns for which Shri Suresh Gowda, Executive Director of the company agreed and offered additional income of Rs.9.96 crores in the hands of SPR Group Holdings Pvt. Ltd. Vide his statement recorded u/s 132(4) of the Act on 9.2.2011 for the financial year 2008-09 to financial year ITA Nos.1658

M/S SPR SPIRITS PVT. LTD.,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE - 1 (3), BENGALURU

In the result, assessee’s appeal in ITA No

Bench: Shri Chandra Poojari & Smt. Beena Pillai

bogus purchase of Rs.27,49,31,180/- from various concerns for which Shri Suresh Gowda, Executive Director of the company agreed and offered additional income of Rs.9.96 crores in the hands of SPR Group Holdings Pvt. Ltd. Vide his statement recorded u/s 132(4) of the Act on 9.2.2011 for the financial year 2008-09 to financial year ITA Nos.1658

M/S SPR SPIRITS PVT. LTD.,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -1 (3) , BENGALURU

In the result, assessee’s appeal in ITA No

Bench: Shri Chandra Poojari & Smt. Beena Pillai

bogus purchase of Rs.27,49,31,180/- from various concerns for which Shri Suresh Gowda, Executive Director of the company agreed and offered additional income of Rs.9.96 crores in the hands of SPR Group Holdings Pvt. Ltd. Vide his statement recorded u/s 132(4) of the Act on 9.2.2011 for the financial year 2008-09 to financial year ITA Nos.1658