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

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

133(6) of the Act. It was observed that the AO had failed to make any enquiry to establish his suspicion that the purchases were bogus, whereas the assessee had produced on record documentary evidence to establish the genuineness of the purchase transactions; that the AO had brushed aside these evidences, which could not be accepted; that

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

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

133(6) of the Act. It was observed that the AO had failed to make any enquiry to establish his suspicion that the purchases were bogus, whereas the assessee had produced on record documentary evidence to establish the genuineness of the purchase transactions; that the AO had brushed aside these evidences, which could not be accepted; that

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

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

133(6) of the Act. It was observed that the AO had failed to make any enquiry to establish his suspicion that the purchases were bogus, whereas the assessee had produced on record documentary evidence to establish the genuineness of the purchase transactions; that the AO had brushed aside these evidences, which could not be accepted; that

SEO LEHENGA HOUSE,JAGRAON vs. DCIT CENTRAL CIRCLE(3) , LUDHIANA

In the result, ground no. 3,4,5 & 6(a) are dismissed as not pressed and ground no

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

6. In Ground No. 1, the assessee has challenged the sustenance of addition of Rs. 3,32,371/- in respect of commission paid on bogus purchase and sales made by the assessee company. 6.1 In this regard, briefly the facts of the case are that during the course of assessment proceedings, the AO observed that on the perusal

M/S SEO LEHENGA HOUSE,JAGRAON vs. DCIT-CENTRAL CIRCLE-3, LUDHIANA

In the result, ground no. 3,4,5 & 6(a) are dismissed as not pressed and ground no

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

6. In Ground No. 1, the assessee has challenged the sustenance of addition of Rs. 3,32,371/- in respect of commission paid on bogus purchase and sales made by the assessee company. 6.1 In this regard, briefly the facts of the case are that during the course of assessment proceedings, the AO observed that on the perusal

M/S SEO LEHENGA HOUSE,JAGRAON vs. DCIT, CENTRAL CIRCLE-3, LUDHIANA

In the result, ground no. 3,4,5 & 6(a) are dismissed as not pressed and ground no

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

6. In Ground No. 1, the assessee has challenged the sustenance of addition of Rs. 3,32,371/- in respect of commission paid on bogus purchase and sales made by the assessee company. 6.1 In this regard, briefly the facts of the case are that during the course of assessment proceedings, the AO observed that on the perusal

M/S SEO LEHENGA HOUSE,JAGRAON vs. DCIT, CENTRAL CIRCLE -3, LUDHIANA

In the result, ground no. 3,4,5 & 6(a) are dismissed as not pressed and ground no

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

6. In Ground No. 1, the assessee has challenged the sustenance of addition of Rs. 3,32,371/- in respect of commission paid on bogus purchase and sales made by the assessee company. 6.1 In this regard, briefly the facts of the case are that during the course of assessment proceedings, the AO observed that on the perusal

M/S SEO LEHENGA HOUSE,JAGRAON vs. DCIT, CENTRAL CIRCLE-3, LUDHIANA

In the result, ground no. 3,4,5 & 6(a) are dismissed as not pressed and ground no

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

6. In Ground No. 1, the assessee has challenged the sustenance of addition of Rs. 3,32,371/- in respect of commission paid on bogus purchase and sales made by the assessee company. 6.1 In this regard, briefly the facts of the case are that during the course of assessment proceedings, the AO observed that on the perusal

SEO BRIDAL STUDIO PVT LTD,LUDHIANA vs. DCIT CENTRAL CIRCLE(3), LUDHIANA

In the result, ground no. 3,4,5 & 6(a) are dismissed as not pressed and ground no

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

6. In Ground No. 1, the assessee has challenged the sustenance of addition of Rs. 3,32,371/- in respect of commission paid on bogus purchase and sales made by the assessee company. 6.1 In this regard, briefly the facts of the case are that during the course of assessment proceedings, the AO observed that on the perusal

KISSAN FATS LTD.,BATHINDA vs. DCIT, CC-1, LUDHIANA

In the result, the appeal of the assessee is allowed

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

bogus bills of purchase to the beneficiary assessee company. On basis of cogent evidence placed before AO the proceedings were reopened under section 148. The Ld. AO in the aforesaid assessment order dt. 23/03/2022 has made following conclusions: (a) Notices sent under section 133(6

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)

bogus purchases was proposed. The parties have furnished their confirmation letters, ledger account and copies of sales bills. Confirmation letters filed by the parties are exhibited hereunder.” 18. Referring to the above extract, the Ld. AR submitted that the notices under section 133(6

PRIME STEEL INDUSTRIES PRIVATE LIMITED, SEMI INDUSTRY PLOT NO.-27, ANAJ MANDI DIRBA, SANGRUR, PUNJAB,SANGRUR, PUNJAB vs. THE ASSESSING OFFICER NFAC, THE JURISDICTIONAL ASSESSING OFFICER, DCIT CIRCLE PATIALA, PATIALA, PUNJAB

In the result, the appeal of the Assessee is allowed whereas, the appeal filed by the Revenue stands dismissed

Bench: Shri A.D. Jain & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 275/Chd/2024 "नधा"रण वष" / Assessment Year : 2021-22 Prime Steel Industries Private Vs. The Dcit, बनाम Circle, Limited, Semi Industry, Patiala Plot No. 27, Anaj Mandi Dibra, Sangrur "थायी लेखा सं./Pan No: Aagca3988E अपीलाथ"/ Appellant ""यथ"/ Repsondent & आयकर अपील सं./ Ita No. 500/Chd/2024 "नधा"रण वष" / Assessment Year : 2021-22 The Dcit, Vs. Prime Steel Industries Private बनाम Circle, Limited, Semi Industry, Patiala Plot No. 27, Anaj Mandi Dibra, Sangrur "थायी लेखा सं./Pan No: Aagca3988E अपीलाथ"/ Appellant ""यथ"/ Repsondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : Shri Sudhir Sehgal, Advocate & Shri Viboore Garg, Ca राज"व क" ओर से/ Revenue By : Smt. Kusum Bansal, Cit Dr सुनवाई क" तार"ख/Date Of Hearing : 24.07.2024 उदघोषणा क" तार"ख/Date Of Pronouncement : 20.09.2024

Section 69C of the Income-tax Act, 1961 - Unexplained expenditure (Bogus purchases) - Assessing Officer had disallowed some expenditure treating purchases as bogus and made addition - High Court in impugned order noted that purchases made by assessee-trader were duly supported by bills and payments were made by account payee cheque and seller also confirmed transaction and there was no evidence

DCIT, PATIALA vs. PRIME STEEL INDUSTRIES PRIVATE LIMITED, DIRBA

In the result, the appeal of the Assessee is allowed whereas, the appeal filed by the Revenue stands dismissed

Bench: Shri A.D. Jain & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 275/Chd/2024 "नधा"रण वष" / Assessment Year : 2021-22 Prime Steel Industries Private Vs. The Dcit, बनाम Circle, Limited, Semi Industry, Patiala Plot No. 27, Anaj Mandi Dibra, Sangrur "थायी लेखा सं./Pan No: Aagca3988E अपीलाथ"/ Appellant ""यथ"/ Repsondent & आयकर अपील सं./ Ita No. 500/Chd/2024 "नधा"रण वष" / Assessment Year : 2021-22 The Dcit, Vs. Prime Steel Industries Private बनाम Circle, Limited, Semi Industry, Patiala Plot No. 27, Anaj Mandi Dibra, Sangrur "थायी लेखा सं./Pan No: Aagca3988E अपीलाथ"/ Appellant ""यथ"/ Repsondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : Shri Sudhir Sehgal, Advocate & Shri Viboore Garg, Ca राज"व क" ओर से/ Revenue By : Smt. Kusum Bansal, Cit Dr सुनवाई क" तार"ख/Date Of Hearing : 24.07.2024 उदघोषणा क" तार"ख/Date Of Pronouncement : 20.09.2024

Section 69C of the Income-tax Act, 1961 - Unexplained expenditure (Bogus purchases) - Assessing Officer had disallowed some expenditure treating purchases as bogus and made addition - High Court in impugned order noted that purchases made by assessee-trader were duly supported by bills and payments were made by account payee cheque and seller also confirmed transaction and there was no evidence

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

In the result, both the appeals and the Cross Objections are dismissed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 992 & 993/Chd/2024 "नधा"रण वष" / Assessment Years: 2017-18, 2016-17 The Dcit, Vs Malbros International Pvt. Ltd., Central Circle-2, Village – Mansoorwal, Teh-Zira, Ludhiana. Head Offices Old Cantt. Road, Faridkot. "थायी लेखा सं./Pan No: Aadcm7203R अपीलाथ"/Appellant ""यथ"/Respondent & C.O. Nos. 46 & 45/Chd/2024 In आयकर अपील सं./ Ita Nos. 992 & 993/Chd/2024 "नधा"रण वष" / Assessment Year: 2017-18, 2016-17 Malbros International Pvt. Ltd., The Dcit, Village – Mansoorwal, Teh-Zira, Vs Central Circle-2, Head Offices Old Cantt. Road, Ludhiana. Faridkot. "थायी लेखा सं./Pan No: Aadcm7203R अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Sudhir Sehgal, Advocate Revenue By : Smt. Kusum Bansal, Cit Dr Date Of Hearing : 14.05.2025 Date Of Pronouncement : 25.06.2025

section 131 - No enquiry in this regard was made and no evidence generally was made available by Assessing Officer - Whether since entire order of Assessing Officer was based merely on statement of Director of assessee without summoning or adducing additional/supplementary evidence of any other person corroborating allegation regarding bogus payments made by assessee, Tribunal was justified in deleting impugned addition

M/S KUBER ROLLER FLOUR MILLS,CHANDIGARH vs. ITO-WARD-2(1), CHANDIGARH

In the result, appeal of the assessee is allowed

bogus purchases as per well settled law. 6. That the appellant craves leave to add or amend the grounds of appeal before the appeal is finally heard and disposed off. 2. Briefly the facts of the case are that the assessee firm has filed its return of income on 19/08/2011 declaring total income of Rs. 9,37,357/-. Subsequently

DCIT,CIRCLE-I, LUDHIANA, LUDHIANA vs. ADINATH TEXTILES LIMITED, LUDHIANA

In the result both the appeal filed by the Revenue and Cross objection filed by the Assessee are dismissed

Bench: the appeal is finally heard or disposed off.

section 133(6) was not sufficient to hold that purchases made were bogus, thus, impugned additions was to be deleted

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

In the result, both the appeals and the Cross Objections\nare dismissed

section 131 - No enquiry in this regard was made and no\nevidence generally was made available by Assessing Officer - Whether since entire\norder of Assessing Officer was based merely on statement of Director of assessee\nwithout summoning or adducing additional/supplementary evidence of any other\nperson corroborating allegation regarding bogus payments made by assessee,\nTribunal was justified in deleting impugned addition

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, LUDHIANA, LUDHIANA vs. M/S FORTUNE METALS LTD., LUDHIANA

Appeal stand dismissed

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.961/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2022-23) Dcit (Central Cricle -1) M/S Fortune Metals Ltd. बनाम/ Sco 1-6, 2Nd Floor, Opp. Circuit House, Kitchlu Nagar, Ludhiana Ferozepur Road, Ludhiana Vs. (Punjab) - 141001 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aaacf-8508-P (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. Co. No.36/Chandi/2025 [In Ita No.961/Chandi/2025] (िनधा"रण वष" / Assessment Year: 2022-23) M/S Fortune Metals Ltd. Dcit (Central Cricle -1) बनाम/ Opp. Circuit House, Sco 1-6, 2Nd Floor, Ferozepur Road, Ludhiana Kitchlu Nagar, Ludhiana Vs. (Punjab) - 141001 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aaacf-8508-P (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/Appellant By : Sh. Sudhir Sehgal (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Sh. Vivek Vardhan (Addl. Cit) – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 11-03-2026 घोषणाकीतारीख /Date Of Pronouncement 19-03-2026 : आदेश / O R D E R Manoj Kumar Aggarwal ()

6% gross profit of bogus purchases by ignoring the facts of the case and findings arising from search u/s 132 of the Act undertaken in the case of Deepak Sharma? 2. Whether upon facts and circumstances of the case, the Ld. CIT(A) was justified to delete the addition of Rs.12,60,000/- made by the A.O. on account