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86 results for “bogus purchases”+ Transfer Pricingclear

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Key Topics

Addition to Income74Section 153A65Section 132(4)50Section 13246Disallowance39Section 143(3)38Section 153C35Section 14828Section 133A

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

purchase price being inflated cannot be ruled out and there is no material to dislodge such finding. The issue is not whether the purchase price reflected in the books of account matches the purchase price stated to have been paid to other persons. The issue is whether the purchase price paid by the assessee is reflected as receipts

Showing 1–20 of 86 · Page 1 of 5

26
Section 13126
Survey u/s 133A20
Bogus Purchases13

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

In the result, appeals of the assessee in ITA Nos

ITA 434/BANG/2024[2016-17]Status: DisposedITAT Bangalore03 Jul 2024AY 2016-17
Section 132Section 132(4)Section 153ASection 153DSection 234A

bogus. The\nassessee had moved a miscellaneous application, which was\nrejected inter-alia on the ground that no specific plea with\nregard to assessee did purchases, rice bran from M/s. R.K.R.K.\nor some other person or as did go into the process of\nmanufacturing the oil. It was held that the cost of such\npurchases may be worked

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

ITA 64/BANG/2023[2014-15]Status: DisposedITAT Bangalore01 Sept 2023AY 2014-15

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shi V. Srinivasan, A.RFor Respondent: Shri D.K. Mishra, D.R
Section 131Section 132(4)Section 133ASection 143Section 143(1)Section 143(3)Section 147Section 148

purchases recorded in the computer of the assessee firm containing date wise purchases made by the assessee from Malpe were found. When confronted, the partner present during the course of the survey proceedings, clarified that the purchases under the column "MalpePur Actual" represented the actual purchases for which payments had been made by NEFT/RTGS and ITA Nos.62 to 66/Bang/2023

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

ITA 63/BANG/2023[2013-14]Status: DisposedITAT Bangalore01 Sept 2023AY 2013-14

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shi V. Srinivasan, A.RFor Respondent: Shri D.K. Mishra, D.R
Section 131Section 132(4)Section 133ASection 143Section 143(1)Section 143(3)Section 147Section 148

purchases recorded in the computer of the assessee firm containing date wise purchases made by the assessee from Malpe were found. When confronted, the partner present during the course of the survey proceedings, clarified that the purchases under the column "MalpePur Actual" represented the actual purchases for which payments had been made by NEFT/RTGS and ITA Nos.62 to 66/Bang/2023

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

ITA 62/BANG/2023[2012-13]Status: DisposedITAT Bangalore01 Sept 2023AY 2012-13

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shi V. Srinivasan, A.RFor Respondent: Shri D.K. Mishra, D.R
Section 131Section 132(4)Section 133ASection 143Section 143(1)Section 143(3)Section 147Section 148

purchases recorded in the computer of the assessee firm containing date wise purchases made by the assessee from Malpe were found. When confronted, the partner present during the course of the survey proceedings, clarified that the purchases under the column "MalpePur Actual" represented the actual purchases for which payments had been made by NEFT/RTGS and ITA Nos.62 to 66/Bang/2023

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

ITA 66/BANG/2023[2017-18]Status: DisposedITAT Bangalore01 Sept 2023AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shi V. Srinivasan, A.RFor Respondent: Shri D.K. Mishra, D.R
Section 131Section 132(4)Section 133ASection 143Section 143(1)Section 143(3)Section 147Section 148

purchases recorded in the computer of the assessee firm containing date wise purchases made by the assessee from Malpe were found. When confronted, the partner present during the course of the survey proceedings, clarified that the purchases under the column "MalpePur Actual" represented the actual purchases for which payments had been made by NEFT/RTGS and ITA Nos.62 to 66/Bang/2023

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

ITA 65/BANG/2023[2015-16]Status: DisposedITAT Bangalore01 Sept 2023AY 2015-16

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shi V. Srinivasan, A.RFor Respondent: Shri D.K. Mishra, D.R
Section 131Section 132(4)Section 133ASection 143Section 143(1)Section 143(3)Section 147Section 148

purchases recorded in the computer of the assessee firm containing date wise purchases made by the assessee from Malpe were found. When confronted, the partner present during the course of the survey proceedings, clarified that the purchases under the column "MalpePur Actual" represented the actual purchases for which payments had been made by NEFT/RTGS and ITA Nos.62 to 66/Bang/2023

M/S. SPR SPIRITS PRIVATE LIMITED (FORMERLY KNOWN AS SPR GROUP HOLDINGS PRIVATE LIMITED),BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(3), BANGALORE

In the result, the appeals of the assessee are partly allowed for statistical purposes

ITA 131/BANG/2023[2008-2009]Status: DisposedITAT Bangalore24 Jul 2023AY 2008-2009

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Bharath L., A.RFor Respondent: Ms. Neera Malhotra, D.R

bogus. 6.2 Later, the statement of Janardan V., was confronted to Suresh Gowda, Executive Director of the assessee company. In his statement recorded u/s 132(4) of the Act on 9.12.2011, he has stated that these 3 parties are suppliers of bottles and grapes. They have the goods receipt for supply of the goods. However, he submitted that he wishes

M/S. SPR SPIRITS PRIVATE LIMITED (FORMERLY KNOWN AS SPR GROUP HOLDINGS PRIVATE LIMITED),BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(3), BANGALORE

In the result, the appeals of the assessee are partly allowed for statistical purposes

ITA 132/BANG/2023[2009-2010]Status: DisposedITAT Bangalore24 Jul 2023AY 2009-2010

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Bharath L., A.RFor Respondent: Ms. Neera Malhotra, D.R

bogus. 6.2 Later, the statement of Janardan V., was confronted to Suresh Gowda, Executive Director of the assessee company. In his statement recorded u/s 132(4) of the Act on 9.12.2011, he has stated that these 3 parties are suppliers of bottles and grapes. They have the goods receipt for supply of the goods. However, he submitted that he wishes

M/S. SPR SPIRITS PRIVATE LIMITED (FORMERLY KNOWN AS SPR GROUP HOLDINGS PRIVATE LIMITED),BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(3), BANGALORE

In the result, the appeals of the assessee are partly allowed for statistical purposes

ITA 133/BANG/2023[2010-11]Status: DisposedITAT Bangalore24 Jul 2023AY 2010-11

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Bharath L., A.RFor Respondent: Ms. Neera Malhotra, D.R

bogus. 6.2 Later, the statement of Janardan V., was confronted to Suresh Gowda, Executive Director of the assessee company. In his statement recorded u/s 132(4) of the Act on 9.12.2011, he has stated that these 3 parties are suppliers of bottles and grapes. They have the goods receipt for supply of the goods. However, he submitted that he wishes

M/S. SPR SPIRITS PRIVATE LIMITED (FORMERLY KNOWN AS SPR GROUP HOLDINGS PRIVATE LIMITED),BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(3), BANGALORE

In the result, the appeals of the assessee are partly allowed for statistical purposes

ITA 134/BANG/2023[2011-12]Status: DisposedITAT Bangalore24 Jul 2023AY 2011-12

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Bharath L., A.RFor Respondent: Ms. Neera Malhotra, D.R

bogus. 6.2 Later, the statement of Janardan V., was confronted to Suresh Gowda, Executive Director of the assessee company. In his statement recorded u/s 132(4) of the Act on 9.12.2011, he has stated that these 3 parties are suppliers of bottles and grapes. They have the goods receipt for supply of the goods. However, he submitted that he wishes

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

ITA 610/BANG/2024[2016-17]Status: DisposedITAT Bangalore03 Jul 2024AY 2016-17
Section 132Section 133ASection 153C

bogus so as to disallow the same and brought to tax as\nundisclosed income of the assessee.\n5.7 Further, there was a CBDT circular file no.286/98/2013-IT\n(Inv.II) dated 18.12.2014 which states as under:\n“Instances/complaints of undue influence/coercion have come to notice of\nthe CBDT that some assessees were coerced to admit undisclosed income\nduring Searches/Surveys conducted

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,MANGALORE, MANGALORE vs. RAJ DIAMONDS, MUMBAI

In the result the appeal of the Revenue is dismissed &

ITA 1361/BANG/2025[2018-19]Status: DisposedITAT Bangalore05 Mar 2026AY 2018-19

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2018-19

For Appellant: Sri V. Srinivasan, A.RFor Respondent: Sri Subramanian, D.R
Section 132Section 143(1)Section 143(2)Section 144(3)Section 148Section 153CSection 250

bogus purchase made without appreciating that the entire purchases made were genuine & accordingly prayed that the entire addition may be deleted. 10. We have heard the rival submissions & perused the materials available on record. It is an undisputed fact that the assessee firm filed its return of income for the Asst. year 2018-19 on 05/10/2018 by declaring the total

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

ITA 407/BANG/2025[2015-16]Status: DisposedITAT Bangalore09 Oct 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Bharadwaj Sheshadri, CA &For Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 131Section 132Section 132(4)Section 153A

transfer. Cash sales form only a small percentage of total sales (about 5% in ATC and 12% in STC), . ITA No.399-410/Bang/2025 Page 10 of 33 which means most cash purchases are matched against bank/cheque sales. 3.4 It is further argued that no defect has been pointed out in the stock records, and in fact, purchases are fully reconciled with sales

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

ITA 402/BANG/2025[2016-17]Status: DisposedITAT Bangalore09 Oct 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Bharadwaj Sheshadri, CA &For Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 131Section 132Section 132(4)Section 153A

transfer. Cash sales form only a small percentage of total sales (about 5% in ATC and 12% in STC), . ITA No.399-410/Bang/2025 Page 10 of 33 which means most cash purchases are matched against bank/cheque sales. 3.4 It is further argued that no defect has been pointed out in the stock records, and in fact, purchases are fully reconciled with sales

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

In the result, all the appeals of the assessee for A

ITA 404/BANG/2025[2018-19]Status: DisposedITAT Bangalore09 Oct 2025AY 2018-19
Section 131Section 132Section 132(4)Section 153A

transfer. Cash sales form only a\nsmall percentage of total sales (about 5% in ATC and 12% in STC),\nwhich means most cash purchases are matched against bank/cheque\nsales.\n3.4 It is further argued that no defect has been pointed out in the\nstock records, and in fact, purchases are fully reconciled with sales. All\nthe purchases made

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

In the result, all the appeals of the assessee for A

ITA 406/BANG/2025[2014-15]Status: DisposedITAT Bangalore09 Oct 2025AY 2014-15
Section 131Section 132Section 132(4)Section 153A

transfer. Cash sales form only a\nsmall percentage of total sales (about 5% in ATC and 12% in STC),\nwhich means most cash purchases are matched against bank/cheque\nsales.\n3.4 It is further argued that no defect has been pointed out in the\nstock records, and in fact, purchases are fully reconciled with sales. All\nthe purchases made

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

In the result, all the appeals of the assessee for A

ITA 405/BANG/2025[2013-14]Status: DisposedITAT Bangalore09 Oct 2025AY 2013-14
Section 131Section 132Section 132(4)Section 153A

transfer. Cash sales form only a\nsmall percentage of total sales (about 5% in ATC and 12% in STC),\nwhich means most cash purchases are matched against bank/cheque\nsales.\n\n3.4 It is further argued that no defect has been pointed out in the\nstock records, and in fact, purchases are fully reconciled with sales. All\nthe purchases made

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

In the result, all the appeals of the assessee for A

ITA 401/BANG/2025[2015-16]Status: DisposedITAT Bangalore09 Oct 2025AY 2015-16
Section 131Section 132Section 132(4)Section 153A

transfer. Cash sales form only a\nsmall percentage of total sales (about 5% in ATC and 12% in STC),\nwhich means most cash purchases are matched against bank/cheque\nsales.\n3.4 It is further argued that no defect has been pointed out in the\nstock records, and in fact, purchases are fully reconciled with sales. All\nthe purchases made

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

In the result, all the appeals of the assessee for A

ITA 410/BANG/2025[2018-19]Status: DisposedITAT Bangalore09 Oct 2025AY 2018-19
For Appellant: Shri Bharadwaj Sheshadri, CA &For Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 131Section 132Section 132(4)Section 153A

transfer. Cash sales form only a\nsmall percentage of total sales (about 5% in ATC and 12% in STC),\nwhich means most cash purchases are matched against bank/cheque\nsales.\n3.4 It is further argued that no defect has been pointed out in the\nstock records, and in fact, purchases are fully reconciled with sales. All\nthe purchases made