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)

340/- and Rs. 1,34,530/- against the addition of Rs. 1,34,530/ of unexplained expenditure.” 25. In Ground No. 1, the assessee has challenged the sustenance of addition of Rs.2,08,116/- on account of unexplained expenditure under section 69 being the commission paid on bogus purchase

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)

340/- and Rs. 1,34,530/- against the addition of Rs. 1,34,530/ of unexplained expenditure.” 25. In Ground No. 1, the assessee has challenged the sustenance of addition of Rs.2,08,116/- on account of unexplained expenditure under section 69 being the commission paid on bogus purchase

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)

340/- and Rs. 1,34,530/- against the addition of Rs. 1,34,530/ of unexplained expenditure.” 25. In Ground No. 1, the assessee has challenged the sustenance of addition of Rs.2,08,116/- on account of unexplained expenditure under section 69 being the commission paid on bogus purchase

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)

340/- and Rs. 1,34,530/- against the addition of Rs. 1,34,530/ of unexplained expenditure.” 25. In Ground No. 1, the assessee has challenged the sustenance of addition of Rs.2,08,116/- on account of unexplained expenditure under section 69 being the commission paid on bogus purchase

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)

340/- and Rs. 1,34,530/- against the addition of Rs. 1,34,530/ of unexplained expenditure.” 25. In Ground No. 1, the assessee has challenged the sustenance of addition of Rs.2,08,116/- on account of unexplained expenditure under section 69 being the commission paid on bogus purchase

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 - Held, yes [Paras 5.1 and 5.7] [In favour of assessee]”  Judgment of ITAT, DELHIBENCHin the case ofASSISTANT COMMISSIONER OF INCOME TAX v/s KARAMCHAND RUBBER INDUSTRIES (P) LTD.as reported inITA No. 6599/Del/2014  Judgment of SUPREME COURT OF INDIAin the case ofCOMMISSIONER

GOPAL KRISHAN BANSAL, MANDI GOBINDGARH,PUNJAB vs. ITO WARD -1, MANDI GOBINDGARH, SIRHIND

In the result, appeal of the Assessee is allowed and cross appeal filed by the Revenue is dismissed

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

bogus purchases, instead of disallowing 100% of the purchases as per the assessment order and partly allowed the appeal of the assessee. 7. Against the order of the CIT(A) the assessee preferred an appeal before the Tribunal. 8. Before us since the additional ground of appeal goes to the root of the assumption of jurisdiction by the Assessing Officer

INCOME TAX OFFICE, WARD-I MANDI GOBINDGARH HQ SIRHIND vs. GOPAL KRISHAN BANSAL, AGGARWAL STEEL TUBES

In the result, appeal of the Assessee is allowed and cross appeal filed by the Revenue is dismissed

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

bogus purchases, instead of disallowing 100% of the purchases as per the assessment order and partly allowed the appeal of the assessee. 7. Against the order of the CIT(A) the assessee preferred an appeal before the Tribunal. 8. Before us since the additional ground of appeal goes to the root of the assumption of jurisdiction by the Assessing Officer

SH. ABHIMANYU SOIN,LUDHIANA vs. ACIT, LUDHIANA

In the result, appeal of the Assessee is dismissed

Bench: Shri. Sanjay Garg, Judicial, Member & Dr. B.R.R. Kumarassessment Year: 2011-12

bogus. The addition has been made by the AO. on the basis of the surmises and conjectures ignoring the evidence produced before him. Thus, the addition made on the doubt, surmises and conjectures have no legs to stand. 9. On the other hand Ld. DR vehemently argued that the assessee has grossly failed to prove the very fact of purchase

BANSAL RICE TRADERS,SANGRUR vs. ITO-WARD, SANGRUR

In the result, appeal of the assessee is allowed

340 the Hon'ble Supreme Court • Avan Gidwani Vs. ACIT in ITA No. 5138/Mum/2015 (Mum Trib) • Khemabhai Patel, Vs. ITO in ITA No. 2131/Mum/2009(Mum Trib) • Abhay Kumar Shroff Vs. ITO 63 ITR 144 (Pat) • Smt. Prabhavati S. Shah Vs. CIT, 231 ITR 278 • Collector Land Katji, 167 ITR 471 (SC) 5.4 The Ld.CIT(A) after considering the submissions

SHRI ADISH OSWAL,LUDHIANA vs. DCIT, C-7, LUDHIANA

In the result, appeals of the Assessees are allowed for statistical purposes

purchased and sold the shares of M/s Jackson Investments Limited in a very thoughtful and planned manner and that the assessee avoided revealing any details of how such strategic decisions were made by quoting general friends and business associates, whose whereabouts were not known to the assessee. 9.1 The submissions of the assessee before the A.O. was that

SH. ASHOK KUMAR OSWAL (DECEASED) THROUGH MRS. MANJU OSWAL (LEGAL HEIR),LUDHIANA vs. DCIT, C-7, LUDHIANA

In the result, appeals of the Assessees are allowed for statistical purposes

purchased and sold the shares of M/s Jackson Investments Limited in a very thoughtful and planned manner and that the assessee avoided revealing any details of how such strategic decisions were made by quoting general friends and business associates, whose whereabouts were not known to the assessee. 9.1 The submissions of the assessee before the A.O. was that

ANIKET SINGAL,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

In the result, all the above appeals are allowed

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 939/Chd/2025 निर्धारण वर्ष / Assessment Year : 2016-17 Shri Aniket Singal बनाम The DCIT 4, Amritashergil Marg, New Delhi- 110003 Central Circle-1 Chandigarh स्थायी लेखा सं./ PAN NO: CZCPS6126E अपीलार्थी/Appellant प्रत्यर्थी / Respondent आयकर अपील सं. / ITA No. 1145/Chd/2025 निर्धारण वर्ष / Assessment Year : 2017-18 Smt. Aarti Singal बनाम The DCIT 53, Jor Bagh, New Delhi-110003 Central Circle-1 Chandigarh स

bogus. 9.12. It is observed that the Department has not brought on record any fresh facts for the year under appeal and has simply relied upon the findings and arguments of the earlier years. Each year being an independent year of assessment, specific evidence or facts have to be brought on record to sustain any adverse action against an assessee

AARTI SINGAL,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

In the result, all the above appeals are allowed

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 939/Chd/2025 निर्धारण वर्ष / Assessment Year : 2016-17 Shri Aniket Singal बनाम The DCIT Central Circle-1 Chandigarh 4, Amritashergil Marg, New Delhi- 110003 स्थायी लेखा सं./ PAN NO: CZCPS6126E अपीलार्थी/Appellant प्रत्यर्थी / Respondent आयकर अपील सं. / ITA No. 1145/Chd/2025 निर्धारण वर्ष / Assessment Year : 2017-18 Smt. Aarti Singal बनाम The DCIT Central Circle-1 Chandigarh 53, Jor Bagh, New Delhi-110003 स

bogus. 9.12. It is observed that the Department has not brought on record any fresh facts for the year under appeal and has simply relied upon the findings and arguments of the earlier years. Each year being an independent year of assessment, specific evidence or facts have to be brought on record to sustain any adverse action against an assessee

ACIT, SANGRUR vs. M/S AGGARSAIN FIBRES LTD., SAMANA

In the result, appeal of the Department is allowed for statistical purposes

bogus billing. The assessee's GP in value terms kept nearly constant but, in percentage term it has sharply declined from 20.37% to 12.10%. The assessee has not been able to adduce any documentary evidence to substantiate that :- i) Why its wastage increased? ii) Why the bad quality of cotton was only sold in the month of March

GAURAV GOEL,CHANDIGARH vs. ITO, WARD 4(3), CHANDIGARH

In the result, the appeal of the assessee stands allowed

Bench: Shri Vikram Singh Yadav & Shri Paresh M. Joshiआयकर अपील सं./ Ita No. 132/Chd/2024 "नधा"रण वष" / Assessment Year: 2017-18 Gaurav Goel, Vs. The Ito, बनाम H. No. 1676, Sector 33-D, Ward 4(3), Chandigarh Chandigarh "थायी लेखा सं./Pan No: Ahgpg3162Q अपीलाथ"/ Assessee ""यथ"/ Repsondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : Shri Jaspal Sharma, Advocate राज"व क" ओर से/ Revenue By : Shri Vivek Vardhan, Jcit, Sr. Dr सुनवाई क" तार"ख/Date Of Hearing : 17.12.2024 उदघोषणा क" तार"ख/Date Of Pronouncement : 24.02.2025 आदेश/Order Per Paresh M. Joshi, Jm :

bogus or fictitious. Upon sales the sales Tax / VAT returns are filed. All these material documents have not been just considered and addition has been made erroneously. The addition has been made on the basis of assumption and presumption. It is well settled that no addition can be made on basis of assumption and presumption conjectures, surmise

M/S ANAND ENGINEERS & CONTRACTORS,SANGURUR vs. PR.CIT, PATIALA

In the result, all the appeals of the respective assessees stands allowed

340/- from business u/s 44AD of the Act. The assessee also filed objections against issuance of notice u/s 148 of the Act. 2.2 During the course of assessment proceedings, the AO observed that a perusal of material available on record revealed that a search action had been undertaken on M/s S.P. Singla Group of cases on 09.08.2018 and that post

M/S HIND CONSTRUCTION ENGINEERS CONTRCTORS,SANGRUR vs. PR.CIT, PATIALA

In the result, all the appeals of the respective assessees stands allowed

340/- from business u/s 44AD of the Act. The assessee also filed objections against issuance of notice u/s 148 of the Act. 2.2 During the course of assessment proceedings, the AO observed that a perusal of material available on record revealed that a search action had been undertaken on M/s S.P. Singla Group of cases on 09.08.2018 and that post

M/S AMAR CONTRUCTION AND ENGINEER ,SANGRUR vs. PCTI, PATIALA

In the result, all the appeals of the respective assessees stands allowed

340/- from business u/s 44AD of the Act. The assessee also filed objections against issuance of notice u/s 148 of the Act. 2.2 During the course of assessment proceedings, the AO observed that a perusal of material available on record revealed that a search action had been undertaken on M/s S.P. Singla Group of cases on 09.08.2018 and that post