DCIT, CENTRAL CIRCLE- 19, NEW DELHI vs. AMQ AGRO INDIA PVT. LTD., NEW DELHI

In the result, the appeals filed by the Revenue for A

Bench: Shri R.K. Panda & Shri K.Narasimha

10A of the Act amounting to Rs.3,63,42,299/-. A search and seizure operation u/s 132(1) of the Act was conducted on 15th February, 2014 in the case of the assessee along with other cases of the AMQ group at various residential and business premises. A notice u/s 153A was issued to the assessee on 14th October

NKG INFRASTRUCTURE LIMITED,NEW DELHI vs. DCIT, CENTRAL CIRCLE-27, DELHI

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

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI ANUBHAV SHARMA (Judicial Member)

bogus purchases without conducting independent enquiry regarding escapement of income. 6. AO has made addition on the basis that notice u/s 133(6) was issued to Giriraj Global Ltd. and Multiblizz Traders Private Limited which was duly served but no response was received from said parties. It is well settled law that merely because some of the persons

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-27, DELHI, DELHI vs. NKG INFRASTRUCTURE LIMITED, DELHI

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

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI ANUBHAV SHARMA (Judicial Member)

bogus purchases without conducting independent enquiry regarding escapement of income. 6. AO has made addition on the basis that notice u/s 133(6) was issued to Giriraj Global Ltd. and Multiblizz Traders Private Limited which was duly served but no response was received from said parties. It is well settled law that merely because some of the persons

SRF LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, the appeal being ITA No

Bench: Shris.Rifaur Rahman & Shri Sudhir Pareek

10A(1A) of the Act. 60. In the result, the ground raised by the assessee is allowed for statistical purposes with the direction that the Assessing Officer shall recompute the deduction as per law. 61. With regard to Ground No. 17 (b) and Additional Ground No.25 are interconnected therefore considered together. 62. Ground no.17(d) relates to the exclusion

SRF LIMITED,NEW DELHI vs. DCIT, CIRCLE- 1, LTU, NEW DELHI

In the result, the appeal being ITA No

Bench: Shris.Rifaur Rahman & Shri Sudhir Pareek

10A(1A) of the Act. 60. In the result, the ground raised by the assessee is allowed for statistical purposes with the direction that the Assessing Officer shall recompute the deduction as per law. 61. With regard to Ground No. 17 (b) and Additional Ground No.25 are interconnected therefore considered together. 62. Ground no.17(d) relates to the exclusion

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-19, NEW DELHI vs. KOYA AND COMPANY CONSTRUCTION LIMITED, HYDERABAD

In the result, the appeal filed by the Revenue is dismissed

Bench: Shris.Rifaur Rahman & Shri Sudhir Pareekdcit, Vs. M/S. Koya & Company Construction Ltd. Central Circle 19, 12-2-831/38/1, 72 Migh, New Delhi. Mehdipatnam, Hyderabad – 500 028 (Telangana). (Pan :Aacck3240R) (Appellant) (Respondent) Assessee By : Shri K.C. Devdas, Ar Revenue By : Shri Shankar Gupta, Sr. Dr Date Of Hearing : 13.10.2025 Date Of Order : 26.11.2025 Order Per S. Rifaur Rahman:

Purchase of goods 62,39,894 4. The assessee has maintained the TP documentation as prescribed under the Section 92D of the Income Tax Act, 1961 (‘the Act’) and considered Transactional Net Margin Method as the "most appropriate method" under Section 92C(l) of the Act and has filed the accountants report in Form 3CEB as prescribed under

INS FINANCE & INVESTMENT P LTD.,,NEW DELHI vs. ITO WARD - 12(3), NEW DELHI

In the result, the appeal of the assessee is partly allowed

Bench: Shri Amit Shukla & Dr. B.R.R. Kumar

bogus share capital even though the same is neither part of reasons nor in respect of which any evidence or material is on record in support of allegation of any undisclosed income. (ii) That the reasons having been recorded only in respect of issue of share capital to the extent of Rs. 2,50,00,000/- received from M/s. Pranneta

SAHASRA ELECTRONICS PVT. LTD.,NEW DELHI vs. ITO, NEW DELHI

In the result, the appeal of the assessee in ITA No

Bench: Shri Anil Chaturvedi & Ms. Astha Chandraassessment Year: 2006-07

section 143(3) of the Act as under:- “14. After discussions, in view of the oral and written submissions made on behalf of the assessee company and on perusal of the documents on record, the returned income of the assessee company is being re-computed as under: (Rs.) (Rs.) Net Profit as per Profit & Loss Account

ITO, NEW DELHI vs. SAHASRA ELECTRONICS (P) LTD., NEW DELHI

In the result, the appeal of the assessee in ITA No

Bench: Shri Anil Chaturvedi & Ms. Astha Chandraassessment Year: 2006-07

section 143(3) of the Act as under:- “14. After discussions, in view of the oral and written submissions made on behalf of the assessee company and on perusal of the documents on record, the returned income of the assessee company is being re-computed as under: (Rs.) (Rs.) Net Profit as per Profit & Loss Account

ROHAN TOOLING SOLUTIONS INDIA PVT. LTD.,GURGOAN vs. ITO, WARD- 21(3), NEW DELHI

In the result, the appeal is partly allowed

Bench: Shri Saktijit Deyassessment Year: 2010-11

10A, Nr. Meenakshi Public School, Gurgaon- 122001 (Hr.) PAN :AACCR7221B (Appellant) (Respondent) Appellant by Shri M.R. Sahu, CA Respondent by Shri Om Parkash, Sr. DR Date of hearing 10.04.2023 Date of pronouncement 19.04.2023 ORDER This is an appeal by the assessee against order dated 23.08.2018 of learned Commissioner of Income-Tax (Appeals)-7, New Delhi pertaining to assessment year

RAJESH KUMAR,SONEPAT vs. ACIT, CENTRAL CIRCLE-2, GURGAON

In the result, cross-appeal filed by the Revenue is dismissed

Bench: Shri Kul Bharat & Shri Avdhesh Kumar Mishra[Assessment Year : 2018-19] Rajesh Kumar, Vs Acit, C/O-Shiva Constructions Co., Central Circle-2, Plot No.69, Sidharth Enclave, Gurgaon. Delhi Road Sonipat, Sonipat, Haryana-131001. Pan-Bkspk2518K Appellant Respondent [Assessment Year : 2018-19] Dcit, Vs Rajesh Kumar, Gurgaon. C/O-Shiva Constructions Co., Plot No.69, Sidharth Enclave, Delhi Road,Sonipat, Haryana-131001. Pan-Bkspk2518K Appellant Respondent Appellant By Shri Umesh Takkar, Ca & Shri Saurabh Nagpal, Ca Respondent By Shri P N Barnwal, Sr.Dr Date Of Hearing 03.07.2024 Date Of Pronouncement 07.08.2024 Order Per Kul Bharat, Jm : These Two Cross-Appeals Filed By The Assessee & The Revenue, Are Directed Against The Order Passed By Ld. Commissioner Of Income Tax(Appeals) [“Ld.Cit(A)”]-3, Gurgaon Dated 31.10.2022 For The Assessment Year 2018-19. Both Appeals Of The Assessee & The Revenue Are Heard Together & Are Being Disposed Off By Way Of Common Order For The Sake Of Brevity.

purchase Para 7 3,40,55,423/- Addition u/s 41(1) Para 8 40,00,000/- Addition disallowance of bogus expenses Para 9 1,03,80,925/- Addition u/s 40(a)(ia) Para 10 8,56,214/- Addition u/s 40(a)(ia) Para 11 6,46,805/- Addition u/s 43B Para 12 1,32,19,450/- Addition

DCIT, GURUGRAM vs. RAJESH KUMAR, SONEPAT

In the result, cross-appeal filed by the Revenue is dismissed

Bench: Shri Kul Bharat & Shri Avdhesh Kumar Mishra[Assessment Year : 2018-19] Rajesh Kumar, Vs Acit, C/O-Shiva Constructions Co., Central Circle-2, Plot No.69, Sidharth Enclave, Gurgaon. Delhi Road Sonipat, Sonipat, Haryana-131001. Pan-Bkspk2518K Appellant Respondent [Assessment Year : 2018-19] Dcit, Vs Rajesh Kumar, Gurgaon. C/O-Shiva Constructions Co., Plot No.69, Sidharth Enclave, Delhi Road,Sonipat, Haryana-131001. Pan-Bkspk2518K Appellant Respondent Appellant By Shri Umesh Takkar, Ca & Shri Saurabh Nagpal, Ca Respondent By Shri P N Barnwal, Sr.Dr Date Of Hearing 03.07.2024 Date Of Pronouncement 07.08.2024 Order Per Kul Bharat, Jm : These Two Cross-Appeals Filed By The Assessee & The Revenue, Are Directed Against The Order Passed By Ld. Commissioner Of Income Tax(Appeals) [“Ld.Cit(A)”]-3, Gurgaon Dated 31.10.2022 For The Assessment Year 2018-19. Both Appeals Of The Assessee & The Revenue Are Heard Together & Are Being Disposed Off By Way Of Common Order For The Sake Of Brevity.

purchase Para 7 3,40,55,423/- Addition u/s 41(1) Para 8 40,00,000/- Addition disallowance of bogus expenses Para 9 1,03,80,925/- Addition u/s 40(a)(ia) Para 10 8,56,214/- Addition u/s 40(a)(ia) Para 11 6,46,805/- Addition u/s 43B Para 12 1,32,19,450/- Addition

M/S. BRIDAL JEWELLERY MFG. CO.,NOIDA vs. ITO, NOIDA

In the result, the appeal of the assessee is partly allowed

Bench: Sh. N. K. Saini, Am & Sh. C. M. Garg, Jm Ita No. 4954/Del/2011 : Asstt. Year : 2007-08 M/S Bridal Jewellery Mfg. Co. Vs Income Tax Officer, 196, Nsez, Phase-Ii, Ward-I, Noida Noida (Appellant) (Respondent) Pan No. Aadfb0557C Assessee By : Sh. Salil Kapoor & Shubham Rastogi, Advs. Revenue By : Sh. K. K. Jaiswal, Dr Date Of Hearing : 22.09.2015 Date Of Pronouncement : 18.12.2015 Order Per N. K. Saini, Am:

bogus or sham transactions. 15 Bridal Jewellery Mfg. Co. 7. The deduction under section 10A is accepted by the department in all years (including A.Y 2007-08) starting from A.Y 2004-05 till today and every year there is a detailed scrutiny by the AO. 8. We have also attached a certificate from the CA of the assessee firm that

PR. COMMISSIONER OF INCOME TAX vs. ARUN MALHOTRA

Bench: HON'BLE MR. JUSTICE YASHWANT VARMA,HON'BLE MR. JUSTICE RAVINDER DUDEJA

bogus. No evidence has also been found during the course of search that assessee made purchases in cash from other concerns. It was merely an inference of the Ld. CIT(A) that assessee made purchases in cash from other parties. The Bank Accounts of these two concerns have been operated by Shri Chander Prakash Sachdeva only. Therefore, on the basis

ACIT, CENTRAL CIRCLE-19, NEW DELHI vs. M/S K.R. PULP & PAPERS LTD,, NEW DELHI

In the result, the appeal of the Revenue is

Bench: Shri R.K. Panda & Shri N.K. Choudhry

section 147 of the I.T. Act, 1961 after recording the following reasons : 3 ITA.No.5064/Del./2017 M/s. K.R. Pulp and Papers Ltd., New Delhi. “A search and seizure operation u/s 132 of the I.T. Act, 1961 was carried out in the case of Shri. Raj Gopal Agarwal, Sh Madho Gopal Agarwal, Sh. Gopal Agarwal and M/S. K R Pulp & Papers

RICHMOND EDUCATIONAL SOCIETY,NOIDA vs. DCIT/ACIT CENTRAL CIRCLE, GHAZIABAD, GHAZIABAD

In the result, the appeal of the Assessee is allowed

section 10 of the Act that where a reference,\nunder the first proviso to sub-section (3) of section 143, has been made on or before\nthe 31st March, 2022 by the Assessing Officer for the contravention of certain\nprovisions of clause (23C) of section 10 of the Act, such references shall be dealt with\nin the manner provided under

MAHARISHI MARKANDESHWAR UNIVERSITY TRUST ,AMBALA CANTT vs. PR.CIT, CENTRAL , GURGAON

Bench: Sh. H. S. Sidhudr. B. R. R. Kumarita No. 2475/Del/2019 : Asstt. Year : 2012-13 Ita No. 2476/Del/2019 : Asstt. Year : 2013-14 Ita No. 2477/Del/2019 : Asstt. Year : 2014-15 Ita No. 2478/Del/2019 : Asstt. Year : 2015-16 Smt. Santosh Garg, Vs Pr. Cit, W/O Sh. Tarsem Garg, Central, Gurugram, C/O Rajiv Goel & Associates, Haryana-122016 179, Bank Road, Ambala Cantt. Haryana-133001 (Appellant) (Respondent) Pan No. Aawpg9894J Ita No. 2479/Del/2019 : Asstt. Year : 2011-12 Ita No. 2480/Del/2019 : Asstt. Year : 2012-13 Ita No. 2481/Del/2019 : Asstt. Year : 2013-14 Ita No. 2482/Del/2019 : Asstt. Year : 2014-15 Ita No. 2483/Del/2019 : Asstt. Year : 2015-16 Sh. Tarsem Garg, Vs Pr. Cit, S/O Sh. Inder Pal Garg, Central, Gurugram, C/O Rajiv Goel & Associates, Haryana-122016 179, Bank Road, Ambala Cantt. Haryana-133001 (Appellant) (Respondent) Pan No. Adepg1240P Ita No. 1594/Del/2019 : Asstt. Year : 2009-10 Ita No. 1595/Del/2019 : Asstt. Year : 2010-11 Ita No. 1596/Del/2019 : Asstt. Year : 2011-12 Ita No. 1597/Del/2019 : Asstt. Year : 2012-13 Ita No. 1598/Del/2019 : Asstt. Year : 2013-14 Ita No. 1599/Del/2019 : Asstt. Year : 2014-15 Ita No. 1600/Del/2019 : Asstt. Year : 2015-16

section 13 of the Act. On perusal of records and the bank statement of Sh. Tarsem Garg for OBC a/c no. 51822010000350 for the period 01.04.2014 to 31.03.2015, the ld. PCIT held that another Innova car bearing the same registration no. HR09F0006 has been purchased by Sh. Tarsem Garg on 18.06.2014 from M/s Global Automobile Pvt. Ltd. for which payment

MAHARISHI MARKANDESHWAR UNIVERSITY TRUST ,AMBALA CANTT vs. PR.CIT, CENTRAL , GURGAON

Bench: Sh. H. S. Sidhudr. B. R. R. Kumarita No. 2475/Del/2019 : Asstt. Year : 2012-13 Ita No. 2476/Del/2019 : Asstt. Year : 2013-14 Ita No. 2477/Del/2019 : Asstt. Year : 2014-15 Ita No. 2478/Del/2019 : Asstt. Year : 2015-16 Smt. Santosh Garg, Vs Pr. Cit, W/O Sh. Tarsem Garg, Central, Gurugram, C/O Rajiv Goel & Associates, Haryana-122016 179, Bank Road, Ambala Cantt. Haryana-133001 (Appellant) (Respondent) Pan No. Aawpg9894J Ita No. 2479/Del/2019 : Asstt. Year : 2011-12 Ita No. 2480/Del/2019 : Asstt. Year : 2012-13 Ita No. 2481/Del/2019 : Asstt. Year : 2013-14 Ita No. 2482/Del/2019 : Asstt. Year : 2014-15 Ita No. 2483/Del/2019 : Asstt. Year : 2015-16 Sh. Tarsem Garg, Vs Pr. Cit, S/O Sh. Inder Pal Garg, Central, Gurugram, C/O Rajiv Goel & Associates, Haryana-122016 179, Bank Road, Ambala Cantt. Haryana-133001 (Appellant) (Respondent) Pan No. Adepg1240P Ita No. 1594/Del/2019 : Asstt. Year : 2009-10 Ita No. 1595/Del/2019 : Asstt. Year : 2010-11 Ita No. 1596/Del/2019 : Asstt. Year : 2011-12 Ita No. 1597/Del/2019 : Asstt. Year : 2012-13 Ita No. 1598/Del/2019 : Asstt. Year : 2013-14 Ita No. 1599/Del/2019 : Asstt. Year : 2014-15 Ita No. 1600/Del/2019 : Asstt. Year : 2015-16

section 13 of the Act. On perusal of records and the bank statement of Sh. Tarsem Garg for OBC a/c no. 51822010000350 for the period 01.04.2014 to 31.03.2015, the ld. PCIT held that another Innova car bearing the same registration no. HR09F0006 has been purchased by Sh. Tarsem Garg on 18.06.2014 from M/s Global Automobile Pvt. Ltd. for which payment