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. ITA 146,147 & 148/CHD/2021 A.Y. 2011-12, 2015-16 & 2016-17 5 3. The sales have been confirmed meaning thereby you have purchased cotton from the open market in cash. The purchases being made in cash from open market, the applicability of provision of Section 40A(iii) of the Income Tax Act, 1961 should have been examined. Therefore

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 purchase without any base and reason thereof without appreciating that the said amount is very excessive and arbitrary. 3. That the Ld. CIT(A), NFAC, Delhi has failed to appreciate that the Ld. AO has wrongly made an addition of Rs. 19,33,905 u/s. 69C on account of alleged unexplained purchases from one Sumanpreet Singh completely disregarding

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

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

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), CHANDIGARH vs. ALLIED NOVATECH PRIVATE LIMITED, CHANDIGARH

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Rajpal Yadav, Vice Presiden & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 609/Chd/2024 "नधा"रण वष" / Assessment Year : 2017-18 Deputy Allied Novatech Private Commissioner Of बनाम Limited Sco 90, Income Tax, Circle- Sector 44-C, Vs. 1(1), Chandigarh Chandigarh. "थायी लेखा सं./Pan No: Aakca2286M अपीलाथ"/Appellant ""यथ"/Respondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By: Shri Parikshit Aggarwal Ca & Ms. Shruti Khandewal, Advocate राज"व क" ओर से/ Revenue By : Shri Vivek Vardhan, Addl. Cit Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 05-06-2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 12-08-2025 आदेश/Order Per Krinwant Sahay, Am: Appeal In This Case Has Been Filed By The Revenue Against The Order Dated 22-03-2024 Of Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi.

bogus sales for generating cash in its books and subsequent deposits in bank accounts.” 2. That Ld. CIT(A)/NFAC has erred in deleting the addition of Rs. 1,83,95,000/- made by the A.O. u/s 69A in view of the facts and circumstances of the case completely ignoring the principles of Preponderance of Human Probability and circumstantial evidence

SANJEEV KUMAR RANA,ROPAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, CHANDIGARH

The appeal stands allowed in terms of our above order

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकर अपील सं. / Ita No.706/Chandi/2024 (िनधा"रण वष" / Assessment Year: 2015-16) Shri Sanjeev Kumar Rana Pr. Cit बनाम/ Vs. 93-Kiln Area, Nangal Ropar Sector -17E (Punjab) 140124. Chandigarh "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aespk-7126-B (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Parikshit Aggarwal (Ca)(Virtual) –Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit)(Virtual) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 07-10-2025 घोषणाकीतारीख /Date Of Pronouncement : 14/10/2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. By Way Of This Appeal, The Assessee Assails Invocation Of Revisionary Jurisdiction U/S 263 By Ld. Pr. Commissioner Of Income Tax, Chandigarh-1 (Pr. Cit) For The Assessment Year (Ay) 2015-16 Vide Impugned Order Dated 10-05-2023 Proposing Revision Of An Assessment As Framed By Ld. Assessing Officer [Ao] U/S.143(3) Of The Act On 12-10-2017. 2. Briefly Stated, The Assessee Was Assessed U/S 143(3) On 12-10-2017 Wherein The Income Of The Assessee Was Determined At Rs.8.79 Lacs After

2. The Ld. AR advanced various legal arguments and assailed proposed revision on the ground that twin conditions of Sec.263 remained to be fulfilled. Reference has been made to various case laws. The Ld. CIT-DR controverted the arguments of Ld. AR and justified revision of the order. Having heard rival submissions and upon perusal of case records, the appeal