SHRI GURU RAM DASS EDUCATIONAL SOCIETY,MOHALI vs. PR.CIT(CENTRAL) GURGAON, AT CHANDIGARH

section 13(1) of the Act then the trust could not be said to be carrying out its activities genuinely and solely for the purposes of its objects, even if the part of its receipt / expenses were unaccounted. According to the Ld. Pr CIT the assessee was indulged in siphoning off its funds by booking bogus expenses and diversion

WARYAM STEEL CASTINGS PRIVATE LIMITED,LUDHIANA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-4, LUDHIANA

In the result, appeal of the assessee is allowed and the Cross appeal of the Revenue is dismissed

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

purchases made from said parties were bogus. He, accordingly, added entire amount of purchases to gross profit of assessee. The Commissioner (Appeals) having found that assessee had indeed made purchases, though not from named parties but other parties from grey market, sustained addition to extent of 30 per cent of purchase cost as probable profit of assessee. The Tribunal however

ASTT. COMMISSIONER OF INCOME TAX, CIRCLE-4, LUDHIANA, AAYAKAR BHAWAN vs. WARYAM STEEL CASTING PRIVATE LIMITED, KANGANWAL ROAD

In the result, appeal of the assessee is allowed and the Cross appeal of the Revenue is dismissed

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

purchases made from said parties were bogus. He, accordingly, added entire amount of purchases to gross profit of assessee. The Commissioner (Appeals) having found that assessee had indeed made purchases, though not from named parties but other parties from grey market, sustained addition to extent of 30 per cent of purchase cost as probable profit of assessee. The Tribunal however

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

bogus commission income. No such document has been brought to my notice by the AO or Survey Report that establishes trail of transfer of cash clandestinely to the members of the society. Hence, if there is bogus commission raised by the members of the society, Ld.AO is free to initiate action against the members in their personal capacities as they

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

bogus commission income. No such document has been brought to my notice by the AO or Survey Report that establishes trail of transfer of cash clandestinely to the members of the society. Hence, if there is bogus commission raised by the members of the society, Ld.AO is free to initiate action against the members in their personal capacities as they

M/S MANAV MANGAL SOCIETY,CHANDIGARH vs. DCIT, C-1, (E), CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

bogus commission income. No such document has been brought to my notice by the AO or Survey Report that establishes trail of transfer of cash clandestinely to the members of the society. Hence, if there is bogus commission raised by the members of the society, Ld.AO is free to initiate action against the members in their personal capacities as they

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

bogus commission income. No such document has been brought to my notice by the AO or Survey Report that establishes trail of transfer of cash clandestinely to the members of the society. Hence, if there is bogus commission raised by the members of the society, Ld.AO is free to initiate action against the members in their personal capacities as they

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

bogus commission income. No such document has been brought to my notice by the AO or Survey Report that establishes trail of transfer of cash clandestinely to the members of the society. Hence, if there is bogus commission raised by the members of the society, Ld.AO is free to initiate action against the members in their personal capacities as they

M/S MANAV MANGAL SOCIETY,CHANDIGARH vs. DCIT, C-1, (E), CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

bogus commission income. No such document has been brought to my notice by the AO or Survey Report that establishes trail of transfer of cash clandestinely to the members of the society. Hence, if there is bogus commission raised by the members of the society, Ld.AO is free to initiate action against the members in their personal capacities as they

DCIT,CIRCLE-1(EXEMPTION), CHANDIGARH vs. M/S MANAV MANGAL SCHOOL( MANAV MANGAL SOCIETY), CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

bogus commission income. No such document has been brought to my notice by the AO or Survey Report that establishes trail of transfer of cash clandestinely to the members of the society. Hence, if there is bogus commission raised by the members of the society, Ld.AO is free to initiate action against the members in their personal capacities as they

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

bogus commission income. No such document has been brought to my notice by the AO or Survey Report that establishes trail of transfer of cash clandestinely to the members of the society. Hence, if there is bogus commission raised by the members of the society, Ld.AO is free to initiate action against the members in their personal capacities as they

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

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

bogus purchases, the theory that the transaction defies human probability cannot be applied to purchases in isolation, but has to be applied to the entire transaction in the light of documentary evidences produced by the assessee; and that where the sales are accepted as genuine, the purchases cannot be disallowed. 12.5 The decision of the Delhi Bench of the Tribunal

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

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

bogus purchases, the theory that the transaction defies human probability cannot be applied to purchases in isolation, but has to be applied to the entire transaction in the light of documentary evidences produced by the assessee; and that where the sales are accepted as genuine, the purchases cannot be disallowed. 12.5 The decision of the Delhi Bench of the Tribunal

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

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

bogus purchases, the theory that the transaction defies human probability cannot be applied to purchases in isolation, but has to be applied to the entire transaction in the light of documentary evidences produced by the assessee; and that where the sales are accepted as genuine, the purchases cannot be disallowed. 12.5 The decision of the Delhi Bench of the Tribunal

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, LUDHIANA, LUDHIANA vs. MALBROS INTERNATIONAL PVT LTD, TEHSIL ZIRA, FARIDKOT -151203, LUDHIANA

The appeal of the assessee stand allowed whereas the revenue’s appeal stand dismissed accordingly

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.48/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2022-23) M/S Malbros International Pvt. Ltd. Dcit बनाम/ Village Mansoorwal Central Circle-2 Tehsil Zira Head Office Ludhiana Vs. Old Cantt Road, Faridkot – 151203 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aadcm-7203-R (अपीलाथ"/Appellant) (""थ" / Respondent) : & 2. आयकर अपील सं. / Ita No.463/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2022-23) Dcit M/S Malbros International Pvt. Ltd. बनाम/ Central Circle-2 Village Mansoorwal Ludhiana Tehsil Zira Head Office Vs. Old Cantt Road, Faridkot – 151203 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aadcm-7203-R (अपीलाथ"/Appellant) (""थ" / Respondent) : & 3. आयकर अपील सं. / Ita No.49/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2022-23) M/S Om Sons Marketing Pvt. Ltd. Dcit बनाम/ Quila Chowk, Old Cantt Road, Centre Circle-2 Vs. Faridkot, Punjab-151203 Ludhiana "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaaco-8962-E (अपीलाथ"/Appellant) : (""थ" / Respondent) & 4. आयकर अपील सं. / Ita No.193/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2022-23)

13-01-2026 आदेश / O R D E R Manoj Kumar Aggarwal (Accountant Member) 1.1 Aforesaid cross-appeals with respect to two assessees, admittedly, have identical facts and issues. First, we take up cross-appeals of M/s Malbros International Pvt. Ltd. for Assessment Year (AY) 2022-23 which arises out of an order of learned Commissioner of Income Tax (Appeals

OM SONS MARKETING PRIVATE LIMITED,FARIDKOT vs. DCIT, CENTRE CIRCLE-2, , LUDHIANA

The appeal of the assessee stand allowed whereas the revenue’s appeal stand dismissed accordingly

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.48/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2022-23) M/S Malbros International Pvt. Ltd. Dcit बनाम/ Village Mansoorwal Central Circle-2 Tehsil Zira Head Office Ludhiana Vs. Old Cantt Road, Faridkot – 151203 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aadcm-7203-R (अपीलाथ"/Appellant) (""थ" / Respondent) : & 2. आयकर अपील सं. / Ita No.463/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2022-23) Dcit M/S Malbros International Pvt. Ltd. बनाम/ Central Circle-2 Village Mansoorwal Ludhiana Tehsil Zira Head Office Vs. Old Cantt Road, Faridkot – 151203 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aadcm-7203-R (अपीलाथ"/Appellant) (""थ" / Respondent) : & 3. आयकर अपील सं. / Ita No.49/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2022-23) M/S Om Sons Marketing Pvt. Ltd. Dcit बनाम/ Quila Chowk, Old Cantt Road, Centre Circle-2 Vs. Faridkot, Punjab-151203 Ludhiana "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaaco-8962-E (अपीलाथ"/Appellant) : (""थ" / Respondent) & 4. आयकर अपील सं. / Ita No.193/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2022-23)

13-01-2026 आदेश / O R D E R Manoj Kumar Aggarwal (Accountant Member) 1.1 Aforesaid cross-appeals with respect to two assessees, admittedly, have identical facts and issues. First, we take up cross-appeals of M/s Malbros International Pvt. Ltd. for Assessment Year (AY) 2022-23 which arises out of an order of learned Commissioner of Income Tax (Appeals

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, LUDHIANA, LUDHIANA vs. OM SONS MARKETING PRIVATE LIMITED, QUILA CHOWK

The appeal of the assessee stand allowed whereas the revenue’s appeal stand dismissed accordingly

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.48/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2022-23) M/S Malbros International Pvt. Ltd. Dcit बनाम/ Village Mansoorwal Central Circle-2 Tehsil Zira Head Office Ludhiana Vs. Old Cantt Road, Faridkot – 151203 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aadcm-7203-R (अपीलाथ"/Appellant) (""थ" / Respondent) : & 2. आयकर अपील सं. / Ita No.463/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2022-23) Dcit M/S Malbros International Pvt. Ltd. बनाम/ Central Circle-2 Village Mansoorwal Ludhiana Tehsil Zira Head Office Vs. Old Cantt Road, Faridkot – 151203 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aadcm-7203-R (अपीलाथ"/Appellant) (""थ" / Respondent) : & 3. आयकर अपील सं. / Ita No.49/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2022-23) M/S Om Sons Marketing Pvt. Ltd. Dcit बनाम/ Quila Chowk, Old Cantt Road, Centre Circle-2 Vs. Faridkot, Punjab-151203 Ludhiana "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaaco-8962-E (अपीलाथ"/Appellant) : (""थ" / Respondent) & 4. आयकर अपील सं. / Ita No.193/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2022-23)

13-01-2026 आदेश / O R D E R Manoj Kumar Aggarwal (Accountant Member) 1.1 Aforesaid cross-appeals with respect to two assessees, admittedly, have identical facts and issues. First, we take up cross-appeals of M/s Malbros International Pvt. Ltd. for Assessment Year (AY) 2022-23 which arises out of an order of learned Commissioner of Income Tax (Appeals

MALBROS INTERNATIONAL PVT LTD, VILLAGE MANSOORWAL, TEHSIL ZIRA HEAD OFFICE, OLD CANTT ROAD, FARIDKOT,FARIDKOT vs. DCIT, CENTRAL CIRCLE-2, , LUDHIANA

The appeal of the assessee stand allowed whereas the revenue’s appeal stand dismissed accordingly

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.48/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2022-23) M/S Malbros International Pvt. Ltd. Dcit बनाम/ Village Mansoorwal Central Circle-2 Tehsil Zira Head Office Ludhiana Vs. Old Cantt Road, Faridkot – 151203 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aadcm-7203-R (अपीलाथ"/Appellant) (""थ" / Respondent) : & 2. आयकर अपील सं. / Ita No.463/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2022-23) Dcit M/S Malbros International Pvt. Ltd. बनाम/ Central Circle-2 Village Mansoorwal Ludhiana Tehsil Zira Head Office Vs. Old Cantt Road, Faridkot – 151203 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aadcm-7203-R (अपीलाथ"/Appellant) (""थ" / Respondent) : & 3. आयकर अपील सं. / Ita No.49/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2022-23) M/S Om Sons Marketing Pvt. Ltd. Dcit बनाम/ Quila Chowk, Old Cantt Road, Centre Circle-2 Vs. Faridkot, Punjab-151203 Ludhiana "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaaco-8962-E (अपीलाथ"/Appellant) : (""थ" / Respondent) & 4. आयकर अपील सं. / Ita No.193/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2022-23)

13-01-2026 आदेश / O R D E R Manoj Kumar Aggarwal (Accountant Member) 1.1 Aforesaid cross-appeals with respect to two assessees, admittedly, have identical facts and issues. First, we take up cross-appeals of M/s Malbros International Pvt. Ltd. for Assessment Year (AY) 2022-23 which arises out of an order of learned Commissioner of Income Tax (Appeals