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74 results for “bogus purchases”+ Section 153(2)clear

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Key Topics

Section 153A62Section 153C57Addition to Income56Section 13239Disallowance34Section 14831Section 132(4)29Section 69B25Section 153D24

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

In the result, appeals of the assessee in ITA Nos

ITA 431/BANG/2024[2013-14]Status: DisposedITAT Bangalore03 Jul 2024AY 2013-14

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Sri Narendra Sharma, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 132Section 132(4)Section 153ASection 153DSection 234A

bogus entries in books. (2) So, when ‘NO PURCHASE” was made, obviously there was “NO SALE”. So, there is no question of any profit element. 4.6 Regarding ground of appeals No.8 in ITA Nos. 431- 434/B/2024(A.Y.2013-14 to A.Y.2016-17) & ground of appeals No.9 in ITA Nos.435/B/2024 (A.Y.2017-18) she submitted that Sanction u/s 153 D not adjudicated

Showing 1–20 of 74 · Page 1 of 4

Section 14419
Natural Justice13
Reassessment11

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

ITA 434/BANG/2024[2016-17]Status: DisposedITAT Bangalore03 Jul 2024AY 2016-17

Bench: Shri Chandra Poojari & Shri Keshav Dubey

Section 132Section 132(4)Section 153ASection 153DSection 234A

bogus entries in books. (2) So, when ‘NO PURCHASE” was made, obviously there was “NO SALE”. So, there is no question of any profit element. 4.6 Regarding ground of appeals No.8 in ITA Nos. 431- 434/Β/2024(A.Y.2013-14 to A.Y.2016-17) & ground of appeals No.9 in ITA Nos.435/B/2024 (A.Y.2017-18) she submitted that Sanction u/s 153 D not adjudicated

INTACT DEVELOPERS PRIVATE LIMITED,BANGALORE vs. DCIT, CENTRAL CIRCLE-1(2), BANGALORE

ITA 824/BANG/2025[2016-17]Status: DisposedITAT Bangalore24 Nov 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Sri Zain Ahmed Khan, A.RFor Respondent: Sri Balusamy N, D.R
Section 143(2)Section 144Section 148Section 234ASection 250

purchase of Rs. 29,39,002, contract charges of Rs. 2,61,33,838/-. By adding these amounts into opening WIP of Rs.3,18,87,396/-, a part of the amount of Rs.1,98,43,933/- was transferred into construction account. For this one engineer certificate was submitted. The verification carried out during the survey had revealed a finding that

INTACT DEVELOPERS PRIVATE LIMITED ,BANGALORE vs. DCIT, CENTRAL CIRCLE-1(2), BANGALORE

ITA 823/BANG/2025[2015-16]Status: DisposedITAT Bangalore24 Nov 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Sri Zain Ahmed Khan, A.RFor Respondent: Sri Balusamy N, D.R
Section 143(2)Section 144Section 148Section 234ASection 250

purchase of Rs. 29,39,002, contract charges of Rs. 2,61,33,838/-. By adding these amounts into opening WIP of Rs.3,18,87,396/-, a part of the amount of Rs.1,98,43,933/- was transferred into construction account. For this one engineer certificate was submitted. The verification carried out during the survey had revealed a finding that

INTACT DEVELOPERS PRIVATE LIMITED,BANGALORE vs. DCIT, CENTRAL CIRCLE-1(2), BANGALORE

ITA 825/BANG/2025[2017-18]Status: DisposedITAT Bangalore24 Nov 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

Section 143(2)Section 144Section 148Section 234ASection 250

purchase of Rs.29,39,002, contract charges of Rs.2,61,33,838/-. By adding these amounts into opening WIP of Rs.3,18,87,396/-, a part of the amount of Rs.1,98,43,933/- was transferred into construction account. For this one engineer certificate was submitted. The verification carried out during the survey had revealed a finding that the assessee

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

ITA 237/BANG/2020[2011-12]Status: DisposedITAT Bangalore29 May 2025AY 2011-12

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

For Appellant: Shri. Prashanth G S, CAFor Respondent: Ms. Neha Sahay, JCIT(DR)(ITAT), Bangalore
Section 132(1)(a)Section 132(2)Section 153ASection 153CSection 153DSection 292B

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

ITA 236/BANG/2020[2010-11]Status: DisposedITAT Bangalore29 May 2025AY 2010-11

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

For Appellant: Shri. Prashanth G S, CAFor Respondent: Ms. Neha Sahay, JCIT(DR)(ITAT), Bangalore
Section 132(1)(a)Section 132(2)Section 153ASection 153CSection 153DSection 292B

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

ITA 234/BANG/2020[2008-09]Status: DisposedITAT Bangalore29 May 2025AY 2008-09

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

For Appellant: Shri. Prashanth G S, CAFor Respondent: Ms. Neha Sahay, JCIT(DR)(ITAT), Bangalore
Section 132(1)(a)Section 132(2)Section 153ASection 153CSection 153DSection 292B

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

ITA 435/BANG/2024[2017-18]Status: DisposedITAT Bangalore03 Jul 2024AY 2017-18
Section 132Section 132(4)Section 153ASection 153DSection 234A

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

ITA 235/BANG/2020[2009-10]Status: DisposedITAT Bangalore29 May 2025AY 2009-10

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

For Appellant: Shri. Prashanth G S, CAFor Respondent: Ms. Neha Sahay, JCIT(DR)(ITAT), Bangalore
Section 132(1)(a)Section 132(2)Section 153ASection 153CSection 153DSection 292B

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

AKSHAY KUMAR RUNGTA,BANGALORE vs. INCOME TAX OFFICER, WARD 2(1), INTERNATIONAL TAXATION

In the result, appeal filed by the assessee is allowed as per above terms

ITA 66/BANG/2024[2015-16]Status: DisposedITAT Bangalore07 May 2025AY 2015-16

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubeyit(It)A No.66/Bang/2024 Assessment Year :2015-16

For Appellant: Shri. Ravishankar S. V, AdvocateFor Respondent: Ms. Neha Sahay, JCIT(DR)(ITAT), Bangalore
Section 10(38)Section 143(3)Section 144CSection 147Section 147rSection 148Section 151Section 153Section 153CSection 250

153/- made on the scrip sale of Pearl Electric Limited on the facts and circumstances of the case. b. The authorities below were not justified in invoking the provisions of section 69A of the Act with respect to the purchase of shares of Mahaveer Advanced Rem for Rs.10,60,000/- on the facts and circumstances of the 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

ITA 383/BANG/2022[2017-18]Status: DisposedITAT Bangalore29 Jul 2022AY 2017-18

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

For Appellant: Shri V. Srinivasan, AdvocateFor Respondent: Smt. Susan Dolores George, CIT(OSD)
Section 143Section 153DSection 263

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

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

ITA 410/BANG/2024[2018-19]Status: DisposedITAT Bangalore26 Sept 2025AY 2018-19

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

Section 132Section 143(3)Section 144Section 153CSection 153D

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

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

ITA 169/BANG/2024[2017-18]Status: DisposedITAT Bangalore26 Sept 2025AY 2017-18

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

Section 132Section 143(3)Section 144Section 153CSection 153D

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

ITA 412/BANG/2024[2020-21]Status: DisposedITAT Bangalore26 Sept 2025AY 2020-21

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

Section 132Section 143(3)Section 144Section 153CSection 153D

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

ITA 411/BANG/2024[2019-20]Status: DisposedITAT Bangalore26 Sept 2025AY 2019-20

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

Section 132Section 143(3)Section 144Section 153CSection 153D

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 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

ITA 1659/BANG/2018[2009-10]Status: DisposedITAT Bangalore27 May 2022AY 2009-10

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Bharath L., A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 132Section 153ASection 37(1)Section 40A(3)

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

ITA 575/BANG/2020[2007-08]Status: DisposedITAT Bangalore27 May 2022AY 2007-08

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Bharath L., A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 132Section 153ASection 37(1)Section 40A(3)

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

ITA 1658/BANG/2018[2008-09]Status: DisposedITAT Bangalore27 May 2022AY 2008-09

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Bharath L., A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 132Section 153ASection 37(1)Section 40A(3)

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

ITA 1660/BANG/2018[2010-11]Status: DisposedITAT Bangalore27 May 2022AY 2010-11

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Bharath L., A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 132Section 153ASection 37(1)Section 40A(3)

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