M/S DIN DAYAL PURSOTAM LAL,SIRSA vs. PR.CIT, ROHTAK

Bench: SHRI A.D.JAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)

100% addition on account of bogus purchases was upheld; that on the other hand, in the case of the assessee in “Raj Lakshmi B”, no such facts were involved; that rather, when the assessee was able to link the purchases with corresponding sales, the logical conclusion which could be arrived at was that the assessee might not have purchased goods

M/S DIN DAYAL PURSOTAM LAL,SIRSA vs. PR.CIT, ROHTAK

Bench: SHRI A.D.JAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)

100% addition on account of bogus purchases was upheld; that on the other hand, in the case of the assessee in “Raj Lakshmi B”, no such facts were involved; that rather, when the assessee was able to link the purchases with corresponding sales, the logical conclusion which could be arrived at was that the assessee might not have purchased goods

M/S DIN DAYAL PURSOTAM LAL,SIRSA vs. PR.CIT, ROHTAK

Bench: SHRI A.D.JAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)

100% addition on account of bogus purchases was upheld; that on the other hand, in the case of the assessee in “Raj Lakshmi B”, no such facts were involved; that rather, when the assessee was able to link the purchases with corresponding sales, the logical conclusion which could be arrived at was that the assessee might not have purchased goods

DY. COMMISSIONER OF INCOME TAX, CC-1, , LUDHIANA vs. M/S AMAN FEED INDUSTRIES, KHANNA

In the result, appeals of the assessee for A

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 1252, 1253,1254,1255/Chd/2024 "नधा"रण वष" / A.Y.: 2015-16, 2017-18, 2018-19,2019-20 M/S Aman Feed Industries, The Dcit, E-2, Focal Point, Vs Central Circle-1, Khanna. Ludhiana. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent आयकर अपील सं./ Ita Nos. 116,181,457/Chd/2025 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 The Dcit, Vs M/S Aman Feed Industries, Central Circle-1, E-2, Focal Point, Ludhiana. Khanna. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ashwani Kumar, Shri Kulbhushan Goyal & Ms, Deepali Aggarwal, Cas Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 28.07.2025 Date Of Pronouncement : 16.10.2025

100 could not be achieved. Therefore, these purchases must have been made out of books from ‘B’ or ‘C’. In this modus-operandi, whatever extra profit earned by the assessee, is to be estimated. In this way, ld.CIT (Appeals) has restricted the addition to the extent of Rs.37,20,822/- on the alleged bogus purchases of Rs.4

AMAN FEED INDUSTRIES,KHANNA vs. DEPUTY COMMISSIONER OF INCOME TAX, CC-1, , LUDHIANA

In the result, appeals of the assessee for A

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 1252, 1253,1254,1255/Chd/2024 "नधा"रण वष" / A.Y.: 2015-16, 2017-18, 2018-19,2019-20 M/S Aman Feed Industries, The Dcit, E-2, Focal Point, Vs Central Circle-1, Khanna. Ludhiana. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent आयकर अपील सं./ Ita Nos. 116,181,457/Chd/2025 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 The Dcit, Vs M/S Aman Feed Industries, Central Circle-1, E-2, Focal Point, Ludhiana. Khanna. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ashwani Kumar, Shri Kulbhushan Goyal & Ms, Deepali Aggarwal, Cas Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 28.07.2025 Date Of Pronouncement : 16.10.2025

100 could not be achieved. Therefore, these purchases must have been made out of books from ‘B’ or ‘C’. In this modus-operandi, whatever extra profit earned by the assessee, is to be estimated. In this way, ld.CIT (Appeals) has restricted the addition to the extent of Rs.37,20,822/- on the alleged bogus purchases of Rs.4

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, LUDHIANA, LUDHIANA vs. AMAN FEED INDUSTRIES, KHANNA

In the result, appeals of the assessee for A

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 1252, 1253,1254,1255/Chd/2024 "नधा"रण वष" / A.Y.: 2015-16, 2017-18, 2018-19,2019-20 M/S Aman Feed Industries, The Dcit, E-2, Focal Point, Vs Central Circle-1, Khanna. Ludhiana. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent आयकर अपील सं./ Ita Nos. 116,181,457/Chd/2025 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 The Dcit, Vs M/S Aman Feed Industries, Central Circle-1, E-2, Focal Point, Ludhiana. Khanna. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ashwani Kumar, Shri Kulbhushan Goyal & Ms, Deepali Aggarwal, Cas Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 28.07.2025 Date Of Pronouncement : 16.10.2025

100 could not be achieved. Therefore, these purchases must have been made out of books from ‘B’ or ‘C’. In this modus-operandi, whatever extra profit earned by the assessee, is to be estimated. In this way, ld.CIT (Appeals) has restricted the addition to the extent of Rs.37,20,822/- on the alleged bogus purchases of Rs.4

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1 , LUDHIANA vs. AMAN FEED INDUSTRIES, KHANNA

In the result, appeals of the assessee for A

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 1252, 1253,1254,1255/Chd/2024 "नधा"रण वष" / A.Y.: 2015-16, 2017-18, 2018-19,2019-20 M/S Aman Feed Industries, The Dcit, E-2, Focal Point, Vs Central Circle-1, Khanna. Ludhiana. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent आयकर अपील सं./ Ita Nos. 116,181,457/Chd/2025 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 The Dcit, Vs M/S Aman Feed Industries, Central Circle-1, E-2, Focal Point, Ludhiana. Khanna. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ashwani Kumar, Shri Kulbhushan Goyal & Ms, Deepali Aggarwal, Cas Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 28.07.2025 Date Of Pronouncement : 16.10.2025

100 could not be achieved. Therefore, these purchases must have been made out of books from ‘B’ or ‘C’. In this modus-operandi, whatever extra profit earned by the assessee, is to be estimated. In this way, ld.CIT (Appeals) has restricted the addition to the extent of Rs.37,20,822/- on the alleged bogus purchases of Rs.4

AMAN FEED INDUSTRIES,KHANNA vs. DEPUTY COMMISSIONER OF INCOME TAX, CC-1, LUDHIANA, LUDHIANA

In the result, appeals of the assessee for A

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 1252, 1253,1254,1255/Chd/2024 "नधा"रण वष" / A.Y.: 2015-16, 2017-18, 2018-19,2019-20 M/S Aman Feed Industries, The Dcit, E-2, Focal Point, Vs Central Circle-1, Khanna. Ludhiana. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent आयकर अपील सं./ Ita Nos. 116,181,457/Chd/2025 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 The Dcit, Vs M/S Aman Feed Industries, Central Circle-1, E-2, Focal Point, Ludhiana. Khanna. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ashwani Kumar, Shri Kulbhushan Goyal & Ms, Deepali Aggarwal, Cas Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 28.07.2025 Date Of Pronouncement : 16.10.2025

100 could not be achieved. Therefore, these purchases must have been made out of books from ‘B’ or ‘C’. In this modus-operandi, whatever extra profit earned by the assessee, is to be estimated. In this way, ld.CIT (Appeals) has restricted the addition to the extent of Rs.37,20,822/- on the alleged bogus purchases of Rs.4

AMAN FEED INDUSTRIES,KHANNA vs. DEPUTY COMMISSIONER OF INCOME TAX, CC-1, , LUDHIANA

In the result, appeals of the assessee for A

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 1252, 1253,1254,1255/Chd/2024 "नधा"रण वष" / A.Y.: 2015-16, 2017-18, 2018-19,2019-20 M/S Aman Feed Industries, The Dcit, E-2, Focal Point, Vs Central Circle-1, Khanna. Ludhiana. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent आयकर अपील सं./ Ita Nos. 116,181,457/Chd/2025 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 The Dcit, Vs M/S Aman Feed Industries, Central Circle-1, E-2, Focal Point, Ludhiana. Khanna. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ashwani Kumar, Shri Kulbhushan Goyal & Ms, Deepali Aggarwal, Cas Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 28.07.2025 Date Of Pronouncement : 16.10.2025

100 could not be achieved. Therefore, these purchases must have been made out of books from ‘B’ or ‘C’. In this modus-operandi, whatever extra profit earned by the assessee, is to be estimated. In this way, ld.CIT (Appeals) has restricted the addition to the extent of Rs.37,20,822/- on the alleged bogus purchases of Rs.4

AMAN FEED INDUSTRIES,KHANNA vs. DEPUTY COMMISSIONER OF INCOME TAX, CC-1, , LUDHIANA

In the result, appeals of the assessee for A

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 1252, 1253,1254,1255/Chd/2024 "नधा"रण वष" / A.Y.: 2015-16, 2017-18, 2018-19,2019-20 M/S Aman Feed Industries, The Dcit, E-2, Focal Point, Vs Central Circle-1, Khanna. Ludhiana. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent आयकर अपील सं./ Ita Nos. 116,181,457/Chd/2025 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 The Dcit, Vs M/S Aman Feed Industries, Central Circle-1, E-2, Focal Point, Ludhiana. Khanna. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ashwani Kumar, Shri Kulbhushan Goyal & Ms, Deepali Aggarwal, Cas Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 28.07.2025 Date Of Pronouncement : 16.10.2025

100 could not be achieved. Therefore, these purchases must have been made out of books from ‘B’ or ‘C’. In this modus-operandi, whatever extra profit earned by the assessee, is to be estimated. In this way, ld.CIT (Appeals) has restricted the addition to the extent of Rs.37,20,822/- on the alleged bogus purchases of Rs.4

INCOME TAX OFFICE, WARD-I MANDI GOBINDGARH HQ SIRHIND vs. GOPAL KRISHAN BANSAL, AGGARWAL STEEL TUBES

In the result, appeal of the Assessee is allowed and cross appeal filed by the Revenue is dismissed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

bogus purchase under section 69A made by the AO and directed to restrict the addition to the extent of 12.5% of non genuine / suspicious/bogus purchases instead of disallowing 100

GOPAL KRISHAN BANSAL, MANDI GOBINDGARH,PUNJAB vs. ITO WARD -1, MANDI GOBINDGARH, SIRHIND

In the result, appeal of the Assessee is allowed and cross appeal filed by the Revenue is dismissed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

bogus purchase under section 69A made by the AO and directed to restrict the addition to the extent of 12.5% of non genuine / suspicious/bogus purchases instead of disallowing 100

AMAN THUKRAL,LUDHIANA vs. INCOME TAX OFFICER WARD 2(1), LUDHIANA , LUDHIANA

Accordingly, Additional Ground No. 1 is allowed for statistical

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

100, and the case was selected for scrutiny under CASS for the reason “Business Purchases.” C. The Assessing Officer completed the assessment u/s 143(3) r.w.s. 144B and made various additions including ₹3,60,17,756 on account of alleged bogus purchases, along with other disallowances. D. The assessee submitted that all purchases were genuine and supported by documentary evidence

DCIT, CENTRAL CIRCLE-1, LUDHIANA vs. M/S RITISH AGRO PRIVATE LIMITED, LUDHIANA

Appeal stand dismissed

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am Physical Hearing 1. आयकरअपीलसं./ Ita No. 633/Chandi/2022 (िनधा"रण वष" / Assessment Year: 2019-20) M/S Ritish Agro Private Ltd. Dcit-Central Circle-1 बनाम/ Vs. Malerkotla Road, Rasulra Ludhiana Khanna – 141 401 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaccr-7743-J (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकरअपीलसं./ Ita No.638/Chandi/2022 (िनधा"रण वष" / Assessment Year: 2019-20) Dcit-Central Circle-1 M/S Ritish Agro Private Ltd. बनाम/ Vs. Ludhiana Malerkotla Road, Rasulra Khanna – 141 401 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaccr-7743-J (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Ashwani Kumar (Ca) & Ms. Muskan Garg (Ca) – Ld. Ars ""थ"कीओरसे/Respondent By : Ms. Tarundeep Kaur (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 24-06-2025 घोषणाकीतारीख /Date Of Pronouncement : 04-08-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1.1 Aforesaid Cross-Appeals Arises Out Of The Order Of Learned Commissioner Of Income Tax (Appeals)-5, Ludhiana Dated 26-07-2022

section 145(3) of the Act and applying GP on total turnover declared by the assessee ignoring the facts involved in this case based on forensic report, accepting the reply of the assessee and its purported findings in this behalf have been arrived at by ignoring the relevant material and/ or by taking into consideration irrelevant and/or extraneous material

M/S RITISH AGRO PRIVATE LIMITED,KHANNA vs. DCIT, CENTRAL CIRCLE-1, LUDHIANA

Appeal stand dismissed

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am Physical Hearing 1. आयकरअपीलसं./ Ita No. 633/Chandi/2022 (िनधा"रण वष" / Assessment Year: 2019-20) M/S Ritish Agro Private Ltd. Dcit-Central Circle-1 बनाम/ Vs. Malerkotla Road, Rasulra Ludhiana Khanna – 141 401 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaccr-7743-J (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकरअपीलसं./ Ita No.638/Chandi/2022 (िनधा"रण वष" / Assessment Year: 2019-20) Dcit-Central Circle-1 M/S Ritish Agro Private Ltd. बनाम/ Vs. Ludhiana Malerkotla Road, Rasulra Khanna – 141 401 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaccr-7743-J (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Ashwani Kumar (Ca) & Ms. Muskan Garg (Ca) – Ld. Ars ""थ"कीओरसे/Respondent By : Ms. Tarundeep Kaur (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 24-06-2025 घोषणाकीतारीख /Date Of Pronouncement : 04-08-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1.1 Aforesaid Cross-Appeals Arises Out Of The Order Of Learned Commissioner Of Income Tax (Appeals)-5, Ludhiana Dated 26-07-2022

section 145(3) of the Act and applying GP on total turnover declared by the assessee ignoring the facts involved in this case based on forensic report, accepting the reply of the assessee and its purported findings in this behalf have been arrived at by ignoring the relevant material and/ or by taking into consideration irrelevant and/or extraneous material

DCIT (EXEMPTIONS), CHANDIGARH vs. APEEJAY EDUCATION SOCIETY, LUDHIANA

In the result, the appeal filed by the Revenue and Cross objection

Bench: Shri N.K. Saini & Shrir.L Negi

bogus purchase and disallowance of depreciation apart from addition u/s 11(5) of the Act, holding the software purchase from WSL as sham transactions. In the first appeal, the Ld. CIT(A) set aside the assessment order holding that matter relating to purchase of software from WSL has already been considered by the Amritsar Bench of the Tribunal in assessee

MANPREET SINGH BHULLAR,PARWANOO vs. ITO, PARWANOO

In the result, appeal of the assessee is allowed

bogus purchase by mentioning categorically that there is nothing to prove the entry pass evidences are baseless and sustained the addition at the GP rate arrived at by the assessee. Consequently, the addition of 2,52,917/- was sustained. As against the addition o f 3 1 , 790/- made by disallowing 20% of some of the expenses, the same

MITHU RAM,DIRBA vs. INCOME TAX OFFICER, SUNAM

In the result, ground no. 4 & 5 are allowed for statistical purposes

Bench: Cit(A) Proves This Fact. 2. That The Assessee Was Prevented By Sufficient & Reasonable Cause In Not Attending To The Proceedings Before The Cit(A) Due Oversight/ Skip Of Mail Regarding The Date Of Hearing Because Busy In Filling The Income Tax Returns.

100 km, it is hard to believe such transaction and it was held to be bogus purchases and addition was made. It was submitted that AO failed to appreciate that in copy of a/c, there were voucher number and there was no continuity of voucher number. Secondly, appellant had filed one certificate downloaded from website of Punjab Excise and Taxation