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)

section 36(1)(iii). 4. That the Ld. CIT(A) has erred in confirming the addition of Rs.6,73,458/- as per Annexure-VI a, page 11 of the order of Assessing Officer. 5. That the Ld. CIT(A) has erred in confirming the addition of Rs.4158/- on account of unexplained investment, as per Annexure-VI, page

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)

section 36(1)(iii). 4. That the Ld. CIT(A) has erred in confirming the addition of Rs.6,73,458/- as per Annexure-VI a, page 11 of the order of Assessing Officer. 5. That the Ld. CIT(A) has erred in confirming the addition of Rs.4158/- on account of unexplained investment, as per Annexure-VI, page

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)

section 36(1)(iii). 4. That the Ld. CIT(A) has erred in confirming the addition of Rs.6,73,458/- as per Annexure-VI a, page 11 of the order of Assessing Officer. 5. That the Ld. CIT(A) has erred in confirming the addition of Rs.4158/- on account of unexplained investment, as per Annexure-VI, page

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)

section 36(1)(iii). 4. That the Ld. CIT(A) has erred in confirming the addition of Rs.6,73,458/- as per Annexure-VI a, page 11 of the order of Assessing Officer. 5. That the Ld. CIT(A) has erred in confirming the addition of Rs.4158/- on account of unexplained investment, as per Annexure-VI, page

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)

section 36(1)(iii). 4. That the Ld. CIT(A) has erred in confirming the addition of Rs.6,73,458/- as per Annexure-VI a, page 11 of the order of Assessing Officer. 5. That the Ld. CIT(A) has erred in confirming the addition of Rs.4158/- on account of unexplained investment, as per Annexure-VI, page

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

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

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

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

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1 , 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

KISSAN FATS LTD.,BATHINDA vs. DCIT, CC-1, LUDHIANA

In the result, the appeal of the assessee is allowed

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

bogus and deemed income u / s 69C of the Income Tax Act without appreciating that these purchases are already accounted for in the return filed. Therefore, provisions of section 69C are not applicable. 5. On the facts and the circumstances of the case and in law, the Ld. Commissioner of Income Tax (Appeals) has erred by confirming addition

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 purchases of Rs.1,92,51,910/-for which,\nit was argued that the same was not in order as the rates of the\npurchases from the doubtful parties were same or less than the parties,\nwhose purchases have not been doubted by the Department. Thus,\nthere was no justification for making the addition of Rs.7,70,048/- as\nsustained

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 of Rs.1,92,51,910/-for which,\nit was argued that the same was not in order as the rates of the\npurchases from the doubtful parties were same or less than the parties,\nwhose purchases have not been doubted by the Department. Thus,\nthere was no justification for making the addition of Rs.7,70,048/- as\nsustained