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

bogus purchases are to be taxed? 3. Whether upon facts and circumstances of the case, the Ld. CIT (A) was justified in reducing G.P. rate of 10.9% calculated by AO based on well reasoned findings and seized material to 8.25% without any basis and reasoning? 4. Whether upon facts and circumstances of the case, the Ld. CIT(A) has justified

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

bogus purchases are to be taxed? 3. Whether upon facts and circumstances of the case, the Ld. CIT (A) was justified in reducing G.P. rate of 10.9% calculated by AO based on well reasoned findings and seized material to 8.25% without any basis and reasoning? 4. Whether upon facts and circumstances of the case, the Ld. CIT(A) has justified

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

bogus purchases are to be taxed? 3. Whether upon facts and circumstances of the case, the Ld. CIT (A) was justified in reducing G.P. rate of 10.9% calculated by AO based on well reasoned findings and seized material to 8.25% without any basis and reasoning? 4. Whether upon facts and circumstances of the case, the Ld. CIT(A) has justified

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

bogus purchases are to be taxed? 3. Whether upon facts and circumstances of the case, the Ld. CIT (A) was justified in reducing G.P. rate of 10.9% calculated by AO based on well reasoned findings and seized material to 8.25% without any basis and reasoning? 4. Whether upon facts and circumstances of the case, the Ld. CIT(A) has justified

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

bogus purchases are to be taxed? 3. Whether upon facts and circumstances of the case, the Ld. CIT (A) was justified in reducing G.P. rate of 10.9% calculated by AO based on well reasoned findings and seized material to 8.25% without any basis and reasoning? 4. Whether upon facts and circumstances of the case, the Ld. CIT(A) has justified

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

bogus purchases are to be taxed? 3. Whether upon facts and circumstances of the case, the Ld. CIT (A) was justified in reducing G.P. rate of 10.9% calculated by AO based on well reasoned findings and seized material to 8.25% without any basis and reasoning? 4. Whether upon facts and circumstances of the case, the Ld. CIT(A) has justified

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, LUDHIANA , LUDHIANA vs. ROSHA ALLOYS PVT. LTD., MANDI GOBINDGARH

In the result, the appeals filed by the Revenue are dismissed,\nwhereas the appeals of the assessee are allowed

bogus purchases could be\nused to decrease the profit element?\n7.\nWhether on facts and circumstances of the case and in law, the Ld. CIT (A)\nwas justified in deleting the addition of Rs.1,92,51,910/- on account of\nbogus purchases and directing the AO to apply the G.P. rate @ 4% on the\nbogus purchases of Rs.1

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, LUDHIANA , LUDHIANA vs. ROSHA ALLOYS PVT. LTD., MANDI GOBINDGARH

In the result, the appeals filed by the Revenue are dismissed,\nwhereas the appeals of the assessee are allowed

bogus\npurchases of Rs.1,92,51,910/- by incorrectly relying on the judgment in the\ncase of M/s Pooja Paper Trading Co (P.) Ltd. [264 Taxman 260] - High Court of\nBombay and Geolife Organics Vs. ACIT [58 ITR(T) 297)-ITAT Mumbai.\n8. The appellant craves leave to add, amend, modify, vary, omit or substitute\nany of the aforesaid grounds

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, LUDHIANA , LUDHIANA vs. ROSHA ALLOYS PVT. LTD., MANDI GOBINDGARH

In the result, the appeals filed by the Revenue are dismissed,\nwhereas the appeals of the assessee are allowed

bogus\npurchases of Rs.1,92,51,910/- by incorrectly relying on the judgment in the\ncase of M/s Pooja Paper Trading Co (P.) Ltd. [264 Taxman 260] - High Court of\nBombay and Geolife Organics Vs. ACIT [58 ITR(T) 297)-ITAT Mumbai.\n8.\nThe appellant craves leave to add, amend, modify, vary, omit or substitute\nany of the aforesaid grounds

ROSHA ALLOYS P LIMITED, AMLOH ROAD, VILLAGE TURAN, MANDI GOBINDGARH,PUNJAB vs. DCIT CENTRAL CIRCLE 1, LUDHIANA, PUNJAB

In the result, the appeals filed by the Revenue are dismissed,\nwhereas the appeals of the assessee are allowed

bogus purchases could be\nused to decrease the profit element?\n7.\nWhether on facts and circumstances of the case and in law, the Ld. CIT (A)\nwas justified in deleting the addition of Rs.1,92,51,910/- on account of\nbogus purchases and directing the AO to apply the G.P. rate @ 4% on the\nbogus purchases of Rs.1

RITU DHINGRA, LUDHIANA,LUDHIANA vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, LUDHIANA, LUDHIANA

In the result, the appeal of the Assessee and cross appeal of the Department are allowed for statistical purposes

Bench: him:-

bogus foreign remittances. Relying upon the statement of Shri Avtar Singh Kochar recorded under section 131(1A) and the seized digital evidence, the Assessing Officer held that the assessee was a beneficiary of ingenuine foreign remittances routed through M/s Dhanya General Trading FZE and M/s Tirupati Diam FZE. According to the Assessing Officer, the transaction details appearing in the seized

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, LUDHIANA vs. RITU DHINGRA, SHAKTI VIHAR, HAIBOWAL KALAN, LUDHIANA

In the result, the appeal of the Assessee and cross appeal of the Department are allowed for statistical purposes

Bench: him:- (a) That the assessment order dated 31.03.2023 passed u/s 143(3) r.w.s.153C is bad in law in as much no incriminating material was found suggesting any escapement of income at premises of Sh. Avtar Singh Kochhar. (b) That the assessment order passed is non-est and bad in law in as much the proceedings have not been conducted in the manner prescribed by the Department instructions from time to time which are mandatory for compliance by the Learned Authorities particularly with respect

bogus foreign remittances. Relying upon the statement of Shri Avtar Singh Kochar recorded under section 131(1A) and the seized digital evidence, the Assessing Officer held that the assessee was a beneficiary of ingenuine foreign remittances routed through M/s Dhanya General Trading FZE and M/s Tirupati Diam FZE. According to the Assessing Officer, the transaction details appearing in the seized

SHRI BALRAM KRISHAN,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH, CHANDIGARH

bogus\ntransaction. . The said statements are not incriminating in nature. Even no reliance can\nbe legally placed on such statements of employees of a third-party during course of\nseparate search action in case of a third party. As per the provisions of section 153C of\nthe Act, in case of any incriminating material is found during the course

SCOTT EDIL ADVANCE RESEARCH LABORATORIES AND EDUCATION LIMITED,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

bogus\ntransaction. . The said statements are not incriminating in nature. Even no reliance can\nbe legally placed on such statements of employees of a third-party during course of\nseparate search action in case of a third party. As per the provisions of section 153C of\nthe Act, in case of any incriminating material is found during the course

SCOTT EDIL PHARMACIA LTD.,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

bogus\ntransaction. . The said statements are not incriminating in nature. Even no reliance can\nbe legally placed on such statements of employees of a third-party during course of\nseparate search action in case of a third party. As per the provisions of section 153C of\nthe Act, in case of any incriminating material is found during the course

SCOTT EDIL ADVANCE RESEARCH LABORATORIES AND EDUCATION LIMITED,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

bogus\ntransaction. . The said statements are not incriminating in nature. Even no reliance can\nbe legally placed on such statements of employees of a third-party during course of\nseparate search action in case of a third party. As per the provisions of section 153C of\nthe Act, in case of any incriminating material is found during the course

SHRI BALRAM KRISHAN,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH, CHANDIGARH

bogus\ntransaction. . The said statements are not incriminating in nature. Even no reliance can\nbe legally placed on such statements of employees of a third-party during course of\nseparate search action in case of a third party. As per the provisions of section 153C of\nthe Act, in case of any incriminating material is found during the course

SCOTT EDIL PHARMACIA LTD.,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

bogus\ntransaction. . The said statements are not incriminating in nature. Even no reliance can\nbe legally placed on such statements of employees of a third-party during course of\nseparate search action in case of a third party. As per the provisions of section 153C of\nthe Act, in case of any incriminating material is found during the course

SCOTT EDIL ADVANCE RESEARCH LABORATORIES AND EDUCATION LIMITED,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

bogus\ntransaction. . The said statements are not incriminating in nature. Even no reliance can\nbe legally placed on such statements of employees of a third-party during course of\nseparate search action in case of a third party. As per the provisions of section 153C of\nthe Act, in case of any incriminating material is found during the course