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 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

x) The stock stated to be purchased from these parties, has been subjected to lab test used for production and also there is evidence of transportation. Since there is al on record, which suggests these documents as non-genuine. (xi) Under the facts & circumstances of the case, assessment order and considering the submissions of the appellant, and legal position

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

x) The stock stated to be purchased from these parties, has been subjected to lab test\nused for production and also there is evidence of transportation. Since there is al on\nrecord, which suggests these documents as non-genuine.\n(xi) Under the facts & circumstances of the case, assessment order and considering\nthe submissions of the appellant, and legal position

SH. KASHMIR SINGH SANDHA,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

x) ITA No. 2406/D/2024 dated 10.12.2024 Mulkh Raj Mehta vs. PCIT. (Page 391-400 of JPB). xi) ITA No. 2741/D/2024 dated 8.1.2025 Babu Lal vs. ITO. (Page 401-419 of JPB). 10 That further in the impugned order passed u/s 263 of the Act it is noted as under: “5.1. I have carefully examined the facts of the case

SURJEET SINGH,SIRSA vs. PCIT, ROHTAK, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

x) ITA No. 2406/D/2024 dated 10.12.2024 Mulkh Raj Mehta vs. PCIT. (Page 391-400 of JPB). xi) ITA No. 2741/D/2024 dated 8.1.2025 Babu Lal vs. ITO. (Page 401-419 of JPB). 10 That further in the impugned order passed u/s 263 of the Act it is noted as under: “5.1. I have carefully examined the facts of the case

SH. PARAMJEET SINGH,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

x) ITA No. 2406/D/2024 dated 10.12.2024 Mulkh Raj Mehta vs. PCIT. (Page 391-400 of JPB). xi) ITA No. 2741/D/2024 dated 8.1.2025 Babu Lal vs. ITO. (Page 401-419 of JPB). 10 That further in the impugned order passed u/s 263 of the Act it is noted as under: “5.1. I have carefully examined the facts of the case

M/S GANESH DASS HUF,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

x) ITA No. 2406/D/2024 dated 10.12.2024 Mulkh Raj Mehta vs. PCIT. (Page 391-400 of JPB). xi) ITA No. 2741/D/2024 dated 8.1.2025 Babu Lal vs. ITO. (Page 401-419 of JPB). 10 That further in the impugned order passed u/s 263 of the Act it is noted as under: “5.1. I have carefully examined the facts of the case

SH. ARVAIL SINGH,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

x) ITA No. 2406/D/2024 dated 10.12.2024 Mulkh Raj Mehta vs. PCIT. (Page 391-400 of JPB). xi) ITA No. 2741/D/2024 dated 8.1.2025 Babu Lal vs. ITO. (Page 401-419 of JPB). 10 That further in the impugned order passed u/s 263 of the Act it is noted as under: “5.1. I have carefully examined the facts of the case

DHUNI CHAND HUF,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

x) ITA No. 2406/D/2024 dated 10.12.2024 Mulkh Raj Mehta vs. PCIT. (Page 391-400 of JPB). xi) ITA No. 2741/D/2024 dated 8.1.2025 Babu Lal vs. ITO. (Page 401-419 of JPB). 10 That further in the impugned order passed u/s 263 of the Act it is noted as under: “5.1. I have carefully examined the facts of the case

SH. RANDHIR SINGH,SIRSA vs. PCIT ROHTAK, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

x) ITA No. 2406/D/2024 dated 10.12.2024 Mulkh Raj Mehta vs. PCIT. (Page 391-400 of JPB). xi) ITA No. 2741/D/2024 dated 8.1.2025 Babu Lal vs. ITO. (Page 401-419 of JPB). 10 That further in the impugned order passed u/s 263 of the Act it is noted as under: “5.1. I have carefully examined the facts of the case

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)

purchase of chillies. The chillies purchased by the assessee are sorted, graded as per Agmark specifications. Better quality chillies are picked up and sorted out for export and before export they are clipped and stemmed and subjected to fumigation under expert technical hands in order to prevent deterioration and with a view to give better polish and appearance and during

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)

purchase of chillies. The chillies purchased by the assessee are sorted, graded as per Agmark specifications. Better quality chillies are picked up and sorted out for export and before export they are clipped and stemmed and subjected to fumigation under expert technical hands in order to prevent deterioration and with a view to give better polish and appearance and during

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

purchases from parties treated as bogus.\nIssue 14: Extended period of Limitation.\nIssue 15: Transfer order u/s 127 dtd. 30.03.2018 was without sanction of law,\nhence bad in law.\nIssue 16: Carry forward of MAT credit against the demand raised consequent to\nimpugned addition made in assessment.\nIssue 17: Disallowance of 80IC on subsidy claimed in ITR.\nIssue 18 : Jewellery

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

2) TMI 459 - |TAT KOLKATA] From the\nperusal of panchnama and the assessment orders, it can be safely inferred that the\nreference made by DDIT (Inv.) for valuation of the properties was without any\nincriminating materials found during search [oral or documentary which could have\nsuggested that the assessee has shown less investment in its books for building\nconstruction] Therefore

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

2) TMI 459 - |TAT KOLKATA] From the\nperusal of panchnama and the assessment orders, it can be safely inferred that the\nreference made by DDIT (Inv.) for valuation of the properties was without any\nincriminating materials found during search [oral or documentary which could have\nsuggested that the assessee has shown less investment in its books for building\nconstruction] Therefore

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-I, CHANDIGARH , CHANDIGARH vs. MS SCOTT EDIL ADVANCE RESEARCH LABORATOTRIES AND EDUCATION LTD., , CHANDIGARH

2) TMI 459 - |TAT KOLKATA] From the\nperusal of panchnama and the assessment orders, it can be safely inferred that the\nreference made by DDIT (Inv.) for valuation of the properties was without any\nincriminating materials found during search [oral or documentary which could have\nsuggested that the assessee has shown less investment in its books for building\nconstruction] Therefore