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)

bogus purchases and sales, which were never made and, thus, the addition of Rs. 3,32,371/- is liable to be set off against such gross profit already offered to tax. 2. a). That the Ld. CIT(A) has erred in confirming the addition of Rs. 58,58,524/- on account of unexplained investment

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)

bogus purchases and sales, which were never made and, thus, the addition of Rs. 3,32,371/- is liable to be set off against such gross profit already offered to tax. 2. a). That the Ld. CIT(A) has erred in confirming the addition of Rs. 58,58,524/- on account of unexplained investment

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)

bogus purchases and sales, which were never made and, thus, the addition of Rs. 3,32,371/- is liable to be set off against such gross profit already offered to tax. 2. a). That the Ld. CIT(A) has erred in confirming the addition of Rs. 58,58,524/- on account of unexplained investment

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)

bogus purchases and sales, which were never made and, thus, the addition of Rs. 3,32,371/- is liable to be set off against such gross profit already offered to tax. 2. a). That the Ld. CIT(A) has erred in confirming the addition of Rs. 58,58,524/- on account of unexplained investment

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)

bogus purchases and sales, which were never made and, thus, the addition of Rs. 3,32,371/- is liable to be set off against such gross profit already offered to tax. 2. a). That the Ld. CIT(A) has erred in confirming the addition of Rs. 58,58,524/- on account of unexplained investment

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

bogus purchases to be deleted (vii) Also, it is submitted that assessee has filed quantitative stock tally in form stock inventory, yield chart showing consumptions, purchases, goods returned, sales made by the assessee and no defect has been pointed out by the AO as well as CIT(A) during the course of assessment proceedings and appellate proceedings and reliance

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)

bogus purchases as made by Ld. AO for AYs 2016-17 & 2017-18 stood deleted in first appeal. Similar arguments were made for addition of unaccounted expenditure of Rs.940.75 Lacs. The Ld. AR also referred to the findings of Ld. CIT(A) on the issue of deletion of addition of alleged out-of-books 24 sales

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)

bogus purchases as made by Ld. AO for AYs 2016-17 & 2017-18 stood deleted in first appeal. Similar arguments were made for addition of unaccounted expenditure of Rs.940.75 Lacs. The Ld. AR also referred to the findings of Ld. CIT(A) on the issue of deletion of addition of alleged out-of-books 24 sales

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)

bogus purchases as made by Ld. AO for AYs 2016-17 & 2017-18 stood deleted in first appeal. Similar arguments were made for addition of unaccounted expenditure of Rs.940.75 Lacs. The Ld. AR also referred to the findings of Ld. CIT(A) on the issue of deletion of addition of alleged out-of-books 24 sales

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)

bogus purchases as made by Ld. AO for AYs 2016-17 & 2017-18 stood deleted in first appeal. Similar arguments were made for addition of unaccounted expenditure of Rs.940.75 Lacs. The Ld. AR also referred to the findings of Ld. CIT(A) on the issue of deletion of addition of alleged out-of-books 24 sales

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

bogus purchases to be deleted\n(vii) Also, it is submitted that assessee has filed quantitative stock tally in form\nstock inventory, yield chart showing consumptions, purchases, goods returned,\nsales made by the assessee and no defect has been pointed out by the AO as well as\nCIT(A) during the course of assessment proceedings and appellate proceedings and\nreliance

M/S SATWANT AGRO ENGINEERS,BHAWANIGARH vs. DCIT, CENTRAL CIRCLE, PATIALA

In the result, the appeal of the assessee is partly allowed for statistical purposes

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

133A 1,24,60,160.00 ii. Stock as per books of account 1,14,60,160.00 Difference 10,00,000.00 That during the course of assessment the assessee firm contended that, "It is admitted fact that the said inventory was got signed from partner of firm which is purely based on estimate in number of goods, estimated value adopted

TARLOCHAN SINGH ,BHAWANIGARH vs. DCIT, CENTRAL CIRCLE, PATIALA

In the result, the appeal of the assessee is partly allowed

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

133A of Income Tax Act 1961 the appellant surrendered the amount on following grounds. 1. Rs. 14,70,000.00 on account of capital introduced in capital account which was noticed at the time of survey. 2. Rs. 17,07,029.00 on account of excess stock found during the course of survey. 3. Rs.2,16,341.00 on account of difference

SHRI BALBIR SINGH VERMA,SHIMLA vs. PR.CIT, SHIMLA

In the result, appeal of the Assessee is allowed

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

133A of the IT Act was conducted in the case of the assessee on 04.03.2015 and additional income of Rs. 1,25,00,000/- was declared over and above regular income for AY 2015-16.” 8.2 The Pr CIT has not even objected the declaration of surrender and its disclosure in the P&L. His only objection is that

SHRI KRISHAN KUMAR JALAN,BANGALORE vs. ITO, W-1, SIRSA

In the result appeal of the assessee is dismissed

section 10(38) of the Income Tax Act, 1961.\n2.17 That the Directorate of Investigation, Kolkata investigated the\ntransactions in 84 such penny stock shares quoted on BSE and during the\ncourse of investigation examined on oath a large number of brokers,\nDirectors of Companies that finally purchased the shares, the promoters of\npenny stock companies, the entry operators

M/S ASHA TECHNOLOGIES,SIRMOUR vs. ADDL. CIT, SOLAN

In the result, both the above appeals of the Assessee are partly allowed as aforesaid in respect of impugned orders dt

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

133A of the IT Act to find out the true facts of the case when there was no compliance and cooperation on the part of the assessee to prove its primary onus. And on the basis of survey only true facts of the case were ascertained which helped in ascertaining the factual reality. The assessing office collected information

M/S ASHA TECHNOLOGIES,KALA AMB vs. ITO, SIRMOUR

In the result, both the above appeals of the Assessee are partly allowed as aforesaid in respect of impugned orders dt

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

133A of the IT Act to find out the true facts of the case when there was no compliance and cooperation on the part of the assessee to prove its primary onus. And on the basis of survey only true facts of the case were ascertained which helped in ascertaining the factual reality. The assessing office collected information

DY. COMMISSIONER OF INCOME TAX, KITCHLU NAGAR vs. ABIR KNITS PVT. LTD., FOCAL POINT

In the result, appeal of the Revenue is dismissed

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

133A of the Income Tax Act, 1961 was conducted at its premises on 23.01.2018, during which various documents were found and impounded. Based on this, the case was selected for compulsory scrutiny. Thereafter, Notices under sections 143(2) and 142(1) were issued along with detailed questionnaires. Although partial replies were filed electronically, the assessee failed to produce complete books

SWARN GANGA JEWELLERS,CHANDIGARH vs. DCIT, CIRCLE 4(1) NOW DCIT, CIRCLE 1(1), CHANDIGARH

In the result, the appeal of the assessee stands allowed

Bench: This Tribunal Being Aggrieved By An Order No. Itba/Nfac/S/250/2022-23/1045180258(1) For A.Y. 2017-18 Dt. 05/09/2022 Which Is Hereinafter Referred To As The “Impugned Order”. The Impugned Order Is Passed By Cit(A) In Terms Of Section 250 Of The Income Tax Act, 1961. Factual Matrix 2. That Survey U/S 133A Of The Income Tax Act, 1961 Was Conducted On The Business Premises Of The Assessee On 06/09/2016. The Assessee Surrendered A Sum Of Rs. 50,00,000/- During The Survey & Paid Tax Thereon. The Return Of Income Was Filed On 01/11/2017 Declaring A Total Income Of Rs. 89,48,260/-. Thereafter The Case Of The Assessee Was Selected For Scrutiny Under Compulsory Scrutiny Guidelines & Notice Under Section 143(2) Of The Act Was Issued On 11/09/2018. The Assessment Was Finalised Vide Order Dt. 23/12/2019 Whereby Addition Of Rs. 95,70,882/- Was Made U/S 68 R.W..S 115Bbe Of The Act.

133A is concerned he has no comments to make. He further stated that as far as amount of Rs. 50,00,000/- is concerned which was surrendered on 06/09/2016 the Department has no grievance on it. He fairly conceded that on 06/09/2016 nothing adversial was found in survey and that he accepts stock upto 01/10/2016 as undisputed even by Department