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)

1% on total amount of bogus purchase and sale amounting to Rs. 17,85,59,558/- which comes to Rs. 17,85,596/- should not be treated as unexplained expenditure under section 69C of the Act. 6.3 In response, the assessee submitted that they have paid commission at the rate of 0.25% on total bogus purchase and sale which

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)

1% on total amount of bogus purchase and sale amounting to Rs. 17,85,59,558/- which comes to Rs. 17,85,596/- should not be treated as unexplained expenditure under section 69C of the Act. 6.3 In response, the assessee submitted that they have paid commission at the rate of 0.25% on total bogus purchase and sale which

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)

1% on total amount of bogus purchase and sale amounting to Rs. 17,85,59,558/- which comes to Rs. 17,85,596/- should not be treated as unexplained expenditure under section 69C of the Act. 6.3 In response, the assessee submitted that they have paid commission at the rate of 0.25% on total bogus purchase and sale which

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)

1% on total amount of bogus purchase and sale amounting to Rs. 17,85,59,558/- which comes to Rs. 17,85,596/- should not be treated as unexplained expenditure under section 69C of the Act. 6.3 In response, the assessee submitted that they have paid commission at the rate of 0.25% on total bogus purchase and sale which

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)

1% on total amount of bogus purchase and sale amounting to Rs. 17,85,59,558/- which comes to Rs. 17,85,596/- should not be treated as unexplained expenditure under section 69C of the Act. 6.3 In response, the assessee submitted that they have paid commission at the rate of 0.25% on total bogus purchase and sale which

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)

1% on total amount of bogus purchase and sale amounting to Rs. 17,85,59,558/- which comes to Rs. 17,85,596/- should not be treated as unexplained expenditure under section 69C of the Act. 6.3 In response, the assessee submitted that they have paid commission at the rate of 0.25% on total bogus purchase and sale which

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

WINSOME TEXTILE INDUSTRIES LIMITED,CHANDIGARH vs. ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-4(1), CHANDIGARH, CHANDIGARH

In the result, the appeal of the assessee is partly allowed and the appeal of the Revenue is dismissed

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

bogus purchases was validly done by the AO. Once, the assessment is validly reopened, the AO, in terms of Explanation 3 to section 147 is entitled to examine any issue which might come to his notice subsequently. As such, the argument of the assessee that the issue related to GDR having been already examined would render the reopening invalid

SH. VIBHAV JAIN,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the ground no

Bench: SHRI. SANJAY GARG (Judicial Member), SHRI. VIKRAM SINGH YADAV (Accountant Member)

56 CCH 102 (Del Trib). 9.5 Regarding the findings of the Ld. CIT(A), it was submitted that the purchased documents of the share cannot be considered as incriminating documents, rather these documents would support the stand of the assessee that the share purchase are genuine and are backed by proper documents. And the assessee has already taken the effect

SH. BIPAN JAIN,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the ground no

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

56 CCH 102 (Del Trib). 10.5 Regarding the findings of the Ld. CIT(A), it was submitted that the purchased documents of the share cannot be considered as incriminating documents, rather these documents would support the stand of the assessee that the share purchase are genuine and are backed by proper documents. And the assessee has already taken the effect

SH. ASHISH JAIN,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the ground no

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

56 CCH 102 (Del Trib). 10.5 Regarding the findings of the Ld. CIT(A), it was submitted that the purchased documents of the share cannot be considered as incriminating documents, rather these documents would support the stand of the assessee that the share purchase are genuine and are backed by proper documents. And the assessee has already taken the effect

SH. ASHISH JAIN,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the ground no

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

56 CCH 102 (Del Trib). 10.5 Regarding the findings of the Ld. CIT(A), it was submitted that the purchased documents of the share cannot be considered as incriminating documents, rather these documents would support the stand of the assessee that the share purchase are genuine and are backed by proper documents. And the assessee has already taken the effect

SH. AKHIL JAIN,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the ground no

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

56 CCH 102 (Del Trib). 10.5 Regarding the findings of the Ld. CIT(A), it was submitted that the purchased documents of the share cannot be considered as incriminating documents, rather these documents would support the stand of the assessee that the share purchase are genuine and are backed by proper documents. And the assessee has already taken the effect

M/S JAIN AMAR CLOTHING PVT. LTD.,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the ground no

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

56 CCH 102 (Del Trib). 9.6 Regarding the findings of the Ld. CIT(A), point wise rebuttal was submitted as under: Findings of the CIT(A) Our contentions The CIT(A) in para 5.1 Pg-24 has stated that i)No incriminating material was found in the introduction of bogus share capital and share case of the Assessee

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. 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. 25. We have held in assessment year 2015-16 as well as in this year that evidence possessed by the Revenue is too fragile on the basis of which it cannot be inferred that assessee has received these amounts in cash. It has made payment through Account Payee Cheque and thereafter procured the goods from it. It has submitted