PRINCIPAL COMMISSIONER OF INCOME TAX 2 KOLKATA vs. RANISATI HOSIERY PVT LTD

Bench: : The Hon'Ble The Chief Justice T.S Sivagnanam -A N D- Hon'Ble Justice Chaitali Chatterjee (Das) Date : 9Th June, 2025.

ii) Whether the Learned Tribunal has committed substantial error in law by accepting the submission/contention of the assessee and subscriber companies merely based on paper submission and ignoring the inadequacy and lacuna in the investigation process for revealing the actual nature of the transactions? iii) Whether the Learned Tribunal has committed substantial error in law by not considering that

PRINCIPAL COMMISSIONER OF INCOME TAX 1 KOLKATA vs. M/S ITC LTD

Bench: The Learned Tribunal – One By The Assessee & The Other By The Revenue Which Have Been Disposed Of By A Common Order, Impugned In This Appeal. 2. The Revenue Has Raised The Following Substantial Questions Of Law For Consideration :

disallowance under Section 14A read with Rule 8D, deduction under Section 801A, deduction under Section 80IC. The assessment was completed under Section 143(3) of the Act by order dated 29.03.2014. Aggrieved by the same, the assessee preferred appeal before the Commissioner of Income Tax (Appeals) 2, Kolkata. The appeal was partly allowed by order dated 27.03.2017. Challenging the said

PRINCIPAL COMMISSIONER OF INCOME TAX-12, KOLKATA vs. MUKTA AGARWAL

In the result, these appeals are allowed and the substantial

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

ii) Whether on the facts and circumstances of the case and in law the order of the Learned Income Tax Appellate Tribunal suffers from perversity as it ignores the facts brought on record establishing manipulation of share prices Surabhi ITAT NO. 06 OF 2022 AND ETC. BATCH Page 12 of 150 Chemicals and Investment Limited as part of colourable device

PRINCIPAL COMMISSIONER OF INCOME TAX-5, KOLKATA vs. POOJA JHUNJHUNWALA

In the result, these appeals are allowed and the substantial

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

ii) Whether on the facts and circumstances of the case and in law the order of the Learned Income Tax Appellate Tribunal suffers from perversity as it ignores the facts brought on record establishing manipulation of share prices Surabhi ITAT NO. 06 OF 2022 AND ETC. BATCH Page 12 of 150 Chemicals and Investment Limited as part of colourable device

PRINCIPAL COMMISSIONER OF INCOME TAX-5, KOLKATA vs. JEMISH SHAH

In the result, these appeals are allowed and the substantial

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

ii) Whether on the facts and circumstances of the case and in law the order of the Learned Income Tax Appellate Tribunal suffers from perversity as it ignores the facts brought on record establishing manipulation of share prices Surabhi ITAT NO. 06 OF 2022 AND ETC. BATCH Page 12 of 150 Chemicals and Investment Limited as part of colourable device

PRINCIPAL COMMISSIONER OF INCOME TAX-SILIGURI vs. SHEKHAR AGARWAL

In the result, these appeals are allowed and the substantial

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

ii) Whether on the facts and circumstances of the case and in law the order of the Learned Income Tax Appellate Tribunal suffers from perversity as it ignores the facts brought on record establishing manipulation of share prices Surabhi ITAT NO. 06 OF 2022 AND ETC. BATCH Page 12 of 150 Chemicals and Investment Limited as part of colourable device

PRINCIPAL COMMISSIONER OF INCOME TAX vs. MUKESH SARAOGI (HUF)

In the result, these appeals are allowed and the substantial

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

ii) Whether on the facts and circumstances of the case and in law the order of the Learned Income Tax Appellate Tribunal suffers from perversity as it ignores the facts brought on record establishing manipulation of share prices Surabhi ITAT NO. 06 OF 2022 AND ETC. BATCH Page 12 of 150 Chemicals and Investment Limited as part of colourable device

PR CIT 9, KOLKATA vs. MANISHA TIKMANI

In the result, these appeals are allowed and the substantial

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

ii) Whether on the facts and circumstances of the case and in law the order of the Learned Income Tax Appellate Tribunal suffers from perversity as it ignores the facts brought on record establishing manipulation of share prices Surabhi ITAT NO. 06 OF 2022 AND ETC. BATCH Page 12 of 150 Chemicals and Investment Limited as part of colourable device

PRINCIPAL COMMISSIONER OF INCOME TAX-18, KOLKATA vs. SRI VIKASH GOEL

In the result, these appeals are allowed and the substantial

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

ii) Whether on the facts and circumstances of the case and in law the order of the Learned Income Tax Appellate Tribunal suffers from perversity as it ignores the facts brought on record establishing manipulation of share prices Surabhi ITAT NO. 06 OF 2022 AND ETC. BATCH Page 12 of 150 Chemicals and Investment Limited as part of colourable device

PRINCIPAL COMMISSIONER OF INCOME TAX-15, KOLKATA vs. SMT. BABITA AGARWAL

In the result, these appeals are allowed and the substantial

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

ii) Whether on the facts and circumstances of the case and in law the order of the Learned Income Tax Appellate Tribunal suffers from perversity as it ignores the facts brought on record establishing manipulation of share prices Surabhi ITAT NO. 06 OF 2022 AND ETC. BATCH Page 12 of 150 Chemicals and Investment Limited as part of colourable device

PRINCIPAL COMMISSIONER OF INCOME TAX CENTRAL -1, KOLKATA vs. SURAJ SAHANA

In the result, these appeals are allowed and the substantial

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

ii) Whether on the facts and circumstances of the case and in law the order of the Learned Income Tax Appellate Tribunal suffers from perversity as it ignores the facts brought on record establishing manipulation of share prices Surabhi ITAT NO. 06 OF 2022 AND ETC. BATCH Page 12 of 150 Chemicals and Investment Limited as part of colourable device

PRINCIPAL COMMISSIONER OF INCOME TAX-5, KOLKATA vs. AAYUSH JHUNJHUNWALA

In the result, these appeals are allowed and the substantial

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

ii) Whether on the facts and circumstances of the case and in law the order of the Learned Income Tax Appellate Tribunal suffers from perversity as it ignores the facts brought on record establishing manipulation of share prices Surabhi ITAT NO. 06 OF 2022 AND ETC. BATCH Page 12 of 150 Chemicals and Investment Limited as part of colourable device

PRINCIPAL COMMISSIONER OF INCOME TAX, CENTRAL-1, KOLKATA vs. KRISHNA KUMAR PARSURAMKA

In the result, these appeals are allowed and the substantial

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

ii) Whether on the facts and circumstances of the case and in law the order of the Learned Income Tax Appellate Tribunal suffers from perversity as it ignores the facts brought on record establishing manipulation of share prices Surabhi ITAT NO. 06 OF 2022 AND ETC. BATCH Page 12 of 150 Chemicals and Investment Limited as part of colourable device

PRINCIPAL COMMISSIONER OF INCOME TAX 9, KOLKATA vs. PUSPA DEVI TIKMANI

In the result, these appeals are allowed and the substantial

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

ii) Whether on the facts and circumstances of the case and in law the order of the Learned Income Tax Appellate Tribunal suffers from perversity as it ignores the facts brought on record establishing manipulation of share prices Surabhi ITAT NO. 06 OF 2022 AND ETC. BATCH Page 12 of 150 Chemicals and Investment Limited as part of colourable device

PRINCIPAL COMMISSIONER OF INCOME TAX-9, KOLKATA vs. GITESH TIKMANI

In the result, these appeals are allowed and the substantial

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

ii) Whether on the facts and circumstances of the case and in law the order of the Learned Income Tax Appellate Tribunal suffers from perversity as it ignores the facts brought on record establishing manipulation of share prices Surabhi ITAT NO. 06 OF 2022 AND ETC. BATCH Page 12 of 150 Chemicals and Investment Limited as part of colourable device

PRINCIPAL COMMISSIONER OF INCOME TAX, SILIGURI vs. PRAKASHO DEVI SARIA

In the result, these appeals are allowed and the substantial

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

ii) Whether on the facts and circumstances of the case and in law the order of the Learned Income Tax Appellate Tribunal suffers from perversity as it ignores the facts brought on record establishing manipulation of share prices Surabhi ITAT NO. 06 OF 2022 AND ETC. BATCH Page 12 of 150 Chemicals and Investment Limited as part of colourable device

PRINCIPAL COMMISSIONER OF INCOME TAX ,BURDWAN vs. BIJAYA TAH

In the result, these appeals are allowed and the substantial

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

ii) Whether on the facts and circumstances of the case and in law the order of the Learned Income Tax Appellate Tribunal suffers from perversity as it ignores the facts brought on record establishing manipulation of share prices Surabhi ITAT NO. 06 OF 2022 AND ETC. BATCH Page 12 of 150 Chemicals and Investment Limited as part of colourable device

PRINCIPAL COMMISSIONER OF INCOME TAX ASANSOL KOLKATA vs. RAKESH JHUNJHUNWALA

In the result, these appeals are allowed and the substantial

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

ii) Whether on the facts and circumstances of the case and in law the order of the Learned Income Tax Appellate Tribunal suffers from perversity as it ignores the facts brought on record establishing manipulation of share prices Surabhi ITAT NO. 06 OF 2022 AND ETC. BATCH Page 12 of 150 Chemicals and Investment Limited as part of colourable device