DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-15, DELHI, NEW DELHI vs. ENRICH AGRO FOOD PRODUCTS PVT. LTD., NEW DELHI

Accordingly, the appeal filed by the Revenue for AY 2019-20 is dismissed

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.

127/- and reduction of gross profit margin from 25% to 6% of bogus purchases, the relevant facts are, assessee company is a contract manufacturer of M/s. Coca Cola India for manufacturing/bottling of aerated water / juices / packed drinking water under the brand "Coca Cola”, "Fanta", "Thums Up". Maaza. The reassessment proceeding was initiated on the basis of information received from Investigation

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-15, DELHI, NEW DELHI vs. ENRICH AGRO FOOD PRODUCTS PVT. LTD., NEW DELHI

Accordingly, the appeal filed by the Revenue for AY 2019-20 is dismissed

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.

127/- and reduction of gross profit margin from 25% to 6% of bogus purchases, the relevant facts are, assessee company is a contract manufacturer of M/s. Coca Cola India for manufacturing/bottling of aerated water / juices / packed drinking water under the brand "Coca Cola”, "Fanta", "Thums Up". Maaza. The reassessment proceeding was initiated on the basis of information received from Investigation

SURENDER GUPTA,DELHI vs. DCIT,CENTRAL CIRCLE-30, DELHI

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

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalita Nos.1670 To 1672/Del/2025 (Assessment Years 2018-19, 2019-20 & 2020-21) Surender Gupta, Dy. Cit, A-27, Phase-1, Ashok Vihar, Central Circle-30, H.O. North West Delhi-110052. Vs. Delhi. Pan-Aaopg2234J (Appellant) (Respondent) Ita Nos.2871 To 2873/Del/2025 (Assessment Years 2018-19, 2019-20 & 2020-21) Dy. Cit, Surender Gupta, Central Circle-1, A-27, Phase-1, Ashok Vihar, Noida. Vs. H.O. North West Delhi-110052. Pan-Aaopg2234J (Appellant) (Respondent) Assessee By Shri Mayank Patwari, Adv. & Shri Aakash Ojha, Adv. Department By Ms. Rajinder Kaur, Cit-Dr Date Of Hearing 20.11.2025 Date Of Pronouncement 24.12.2025 O R D E R Per Manish Agarwal, Am: The Captioned Cross Appeals Are Filed By The Assessee & Revenue Against Three Separate Orders Of Ld. Commissioner Of Income Tax (Appeals)-30, New Delhi [“Ld. Cit(A) In Short”] U/S 250 Of The Income Tax Act, 1961 [“The Act In Short”], All Are Dated 24.02.2025 Against The Orders Of The Assessing Officer U/S 153A R.W.S Ita Nos.2871 To 2873/Del/2025 Surender Gupta Vs. Dcit 143(3) Of The Income Tax Act, 1961 (“The Act” For Short) For Assessment Years 2018-19, 2019-20 & 2020-21 Respectively.

127 of the Act dated 01.09.2021. Thereafter notice u/s 153A was issued on 18.11.2021, in response to which return of income was filed by the assessee on 01.04.2022 declaring the same income as were declared in the return filed u/s 139(1) of the Act. Thereafter, various notices were issued from time to time and after considering the notices

DY COMMISSIONER OF INCOME TAX, NOIDA, NOIDA vs. SURENDER GUPTA, DELHI

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

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalita Nos.1670 To 1672/Del/2025 (Assessment Years 2018-19, 2019-20 & 2020-21) Surender Gupta, Dy. Cit, A-27, Phase-1, Ashok Vihar, Central Circle-30, H.O. North West Delhi-110052. Vs. Delhi. Pan-Aaopg2234J (Appellant) (Respondent) Ita Nos.2871 To 2873/Del/2025 (Assessment Years 2018-19, 2019-20 & 2020-21) Dy. Cit, Surender Gupta, Central Circle-1, A-27, Phase-1, Ashok Vihar, Noida. Vs. H.O. North West Delhi-110052. Pan-Aaopg2234J (Appellant) (Respondent) Assessee By Shri Mayank Patwari, Adv. & Shri Aakash Ojha, Adv. Department By Ms. Rajinder Kaur, Cit-Dr Date Of Hearing 20.11.2025 Date Of Pronouncement 24.12.2025 O R D E R Per Manish Agarwal, Am: The Captioned Cross Appeals Are Filed By The Assessee & Revenue Against Three Separate Orders Of Ld. Commissioner Of Income Tax (Appeals)-30, New Delhi [“Ld. Cit(A) In Short”] U/S 250 Of The Income Tax Act, 1961 [“The Act In Short”], All Are Dated 24.02.2025 Against The Orders Of The Assessing Officer U/S 153A R.W.S Ita Nos.2871 To 2873/Del/2025 Surender Gupta Vs. Dcit 143(3) Of The Income Tax Act, 1961 (“The Act” For Short) For Assessment Years 2018-19, 2019-20 & 2020-21 Respectively.

127 of the Act dated 01.09.2021. Thereafter notice u/s 153A was issued on 18.11.2021, in response to which return of income was filed by the assessee on 01.04.2022 declaring the same income as were declared in the return filed u/s 139(1) of the Act. Thereafter, various notices were issued from time to time and after considering the notices

SURENDER GUPTA,DELHI vs. DCIT,CENTRAL CIRCLE-30, DELHI

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

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalita Nos.1670 To 1672/Del/2025 (Assessment Years 2018-19, 2019-20 & 2020-21) Surender Gupta, Dy. Cit, A-27, Phase-1, Ashok Vihar, Central Circle-30, H.O. North West Delhi-110052. Vs. Delhi. Pan-Aaopg2234J (Appellant) (Respondent) Ita Nos.2871 To 2873/Del/2025 (Assessment Years 2018-19, 2019-20 & 2020-21) Dy. Cit, Surender Gupta, Central Circle-1, A-27, Phase-1, Ashok Vihar, Noida. Vs. H.O. North West Delhi-110052. Pan-Aaopg2234J (Appellant) (Respondent) Assessee By Shri Mayank Patwari, Adv. & Shri Aakash Ojha, Adv. Department By Ms. Rajinder Kaur, Cit-Dr Date Of Hearing 20.11.2025 Date Of Pronouncement 24.12.2025 O R D E R Per Manish Agarwal, Am: The Captioned Cross Appeals Are Filed By The Assessee & Revenue Against Three Separate Orders Of Ld. Commissioner Of Income Tax (Appeals)-30, New Delhi [“Ld. Cit(A) In Short”] U/S 250 Of The Income Tax Act, 1961 [“The Act In Short”], All Are Dated 24.02.2025 Against The Orders Of The Assessing Officer U/S 153A R.W.S Ita Nos.2871 To 2873/Del/2025 Surender Gupta Vs. Dcit 143(3) Of The Income Tax Act, 1961 (“The Act” For Short) For Assessment Years 2018-19, 2019-20 & 2020-21 Respectively.

127 of the Act dated 01.09.2021. Thereafter notice u/s 153A was issued on 18.11.2021, in response to which return of income was filed by the assessee on 01.04.2022 declaring the same income as were declared in the return filed u/s 139(1) of the Act. Thereafter, various notices were issued from time to time and after considering the notices

SURENDER GUPTA,DELHI vs. DCIT,CENTRAL CIRCLE-30, DELHI

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

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalita Nos.1670 To 1672/Del/2025 (Assessment Years 2018-19, 2019-20 & 2020-21) Surender Gupta, Dy. Cit, A-27, Phase-1, Ashok Vihar, Central Circle-30, H.O. North West Delhi-110052. Vs. Delhi. Pan-Aaopg2234J (Appellant) (Respondent) Ita Nos.2871 To 2873/Del/2025 (Assessment Years 2018-19, 2019-20 & 2020-21) Dy. Cit, Surender Gupta, Central Circle-1, A-27, Phase-1, Ashok Vihar, Noida. Vs. H.O. North West Delhi-110052. Pan-Aaopg2234J (Appellant) (Respondent) Assessee By Shri Mayank Patwari, Adv. & Shri Aakash Ojha, Adv. Department By Ms. Rajinder Kaur, Cit-Dr Date Of Hearing 20.11.2025 Date Of Pronouncement 24.12.2025 O R D E R Per Manish Agarwal, Am: The Captioned Cross Appeals Are Filed By The Assessee & Revenue Against Three Separate Orders Of Ld. Commissioner Of Income Tax (Appeals)-30, New Delhi [“Ld. Cit(A) In Short”] U/S 250 Of The Income Tax Act, 1961 [“The Act In Short”], All Are Dated 24.02.2025 Against The Orders Of The Assessing Officer U/S 153A R.W.S Ita Nos.2871 To 2873/Del/2025 Surender Gupta Vs. Dcit 143(3) Of The Income Tax Act, 1961 (“The Act” For Short) For Assessment Years 2018-19, 2019-20 & 2020-21 Respectively.

127 of the Act dated 01.09.2021. Thereafter notice u/s 153A was issued on 18.11.2021, in response to which return of income was filed by the assessee on 01.04.2022 declaring the same income as were declared in the return filed u/s 139(1) of the Act. Thereafter, various notices were issued from time to time and after considering the notices

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-I, NOIDA, NOIDA vs. SURENDER GUPTA, DELHI

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

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalita Nos.1670 To 1672/Del/2025 (Assessment Years 2018-19, 2019-20 & 2020-21) Surender Gupta, Dy. Cit, A-27, Phase-1, Ashok Vihar, Central Circle-30, H.O. North West Delhi-110052. Vs. Delhi. Pan-Aaopg2234J (Appellant) (Respondent) Ita Nos.2871 To 2873/Del/2025 (Assessment Years 2018-19, 2019-20 & 2020-21) Dy. Cit, Surender Gupta, Central Circle-1, A-27, Phase-1, Ashok Vihar, Noida. Vs. H.O. North West Delhi-110052. Pan-Aaopg2234J (Appellant) (Respondent) Assessee By Shri Mayank Patwari, Adv. & Shri Aakash Ojha, Adv. Department By Ms. Rajinder Kaur, Cit-Dr Date Of Hearing 20.11.2025 Date Of Pronouncement 24.12.2025 O R D E R Per Manish Agarwal, Am: The Captioned Cross Appeals Are Filed By The Assessee & Revenue Against Three Separate Orders Of Ld. Commissioner Of Income Tax (Appeals)-30, New Delhi [“Ld. Cit(A) In Short”] U/S 250 Of The Income Tax Act, 1961 [“The Act In Short”], All Are Dated 24.02.2025 Against The Orders Of The Assessing Officer U/S 153A R.W.S Ita Nos.2871 To 2873/Del/2025 Surender Gupta Vs. Dcit 143(3) Of The Income Tax Act, 1961 (“The Act” For Short) For Assessment Years 2018-19, 2019-20 & 2020-21 Respectively.

127 of the Act dated 01.09.2021. Thereafter notice u/s 153A was issued on 18.11.2021, in response to which return of income was filed by the assessee on 01.04.2022 declaring the same income as were declared in the return filed u/s 139(1) of the Act. Thereafter, various notices were issued from time to time and after considering the notices

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE I NOIDA, NOIDA vs. SURENDER GUPTA, DELHI

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

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalita Nos.1670 To 1672/Del/2025 (Assessment Years 2018-19, 2019-20 & 2020-21) Surender Gupta, Dy. Cit, A-27, Phase-1, Ashok Vihar, Central Circle-30, H.O. North West Delhi-110052. Vs. Delhi. Pan-Aaopg2234J (Appellant) (Respondent) Ita Nos.2871 To 2873/Del/2025 (Assessment Years 2018-19, 2019-20 & 2020-21) Dy. Cit, Surender Gupta, Central Circle-1, A-27, Phase-1, Ashok Vihar, Noida. Vs. H.O. North West Delhi-110052. Pan-Aaopg2234J (Appellant) (Respondent) Assessee By Shri Mayank Patwari, Adv. & Shri Aakash Ojha, Adv. Department By Ms. Rajinder Kaur, Cit-Dr Date Of Hearing 20.11.2025 Date Of Pronouncement 24.12.2025 O R D E R Per Manish Agarwal, Am: The Captioned Cross Appeals Are Filed By The Assessee & Revenue Against Three Separate Orders Of Ld. Commissioner Of Income Tax (Appeals)-30, New Delhi [“Ld. Cit(A) In Short”] U/S 250 Of The Income Tax Act, 1961 [“The Act In Short”], All Are Dated 24.02.2025 Against The Orders Of The Assessing Officer U/S 153A R.W.S Ita Nos.2871 To 2873/Del/2025 Surender Gupta Vs. Dcit 143(3) Of The Income Tax Act, 1961 (“The Act” For Short) For Assessment Years 2018-19, 2019-20 & 2020-21 Respectively.

127 of the Act dated 01.09.2021. Thereafter notice u/s 153A was issued on 18.11.2021, in response to which return of income was filed by the assessee on 01.04.2022 declaring the same income as were declared in the return filed u/s 139(1) of the Act. Thereafter, various notices were issued from time to time and after considering the notices

INCOME TAX OFFICER, DELHI vs. AKASH DEEP SETHI, DELHI

In the result, the appeal filed by the Revenue is dismissed and at the same time, the cross objections filed by the assessee are also dismissed

Bench: Shri Challa Nagendra Prasad & Shri S. Rifaur Rahmanincome Tax Officer, Vs. Akash Deep Sethi, Delhi. B-236, Derawal Nagar, Model Town, Delhi – 110 009. (Pan : Abyps8933P) Co No.26/Del/2025 (In Ita No.4973/Del/2024) (Assessment Year: 2021-22) Akash Deep Sethi, Vs. Income Tax Officer, B-236, Derawal Nagar, Delhi. Model Town, Delhi – 110 009. (Pan : Abyps8933P) (Appellant) (Respondent) Assessee By : Shri Ved Jain, Advocate Shri Aman Garg, Ca Ms. Kirti, Ca Revenue By : Shri Ajay Kumar Arora, Sr. Dr Date Of Hearing : 27.05.2025 Date Of Order : 16.07.2025 O R D E R Per S.Rifaur Rahman: 1. This Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income-Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi

section 131 at the instance of the assessee, did not pursue the matter further. The Revenue did not examine the source of income of the said alleged creditors to find out whether they were creditworthy or were such who could advance the alleged loans. There was no effort made to pursue the so-called alleged creditors. In those circumstances

LAKHMI CHAND CHARITABLE SOCIETY,NEW DELHI vs. PCIT CENTRAL 3, NEW DELHI

Bench: Shri S. Rifaur Rahman & Ms.Madhumita Roylakhmi Chand Vs. Principal Commissioner Charitable Society, Of Income Tax, Central-3 Elephanta Lane, Behind Room No. 325, 3Rd Floor, Sector-10/6 Market, New Income Tax Building, E-3 Golak Dham, Sector-10, Ara Centre, Jhandewalan Dwarka, Extension, New Delhi - 110075 New Delhi - 110055

127 with DCIT, Central Circle 28, Delhi who is sub-ordinate to PCIT (Central) 3, Delhi Thus, in view of para 2.3 and para 3 of CBDT letter dt. 19.01 2024, prescribed authority for cancellation of registration in this case is PCIT (Central)-3. Gr. 2.1. Reliance on ex parte internal communication dt. 19.01.2024 issued by CBDT 10 assume jurisdiction

DCIT, CIRCLE- 1(2), NEW DELHI vs. ADVENTURE RESORTS AND CRUISES PVT. LTD., NEW DELHI

In the result, the revenue’s appeal as well Assessee’s cross objection both are dismissed in the aforesaid manner

Bench: Shri Mahavir Singh & Shri Brajesh Kumar Singhdcit, Circle 1(2), Vs.Adventure Resorts Room No. 368, C.R. Building & Cruises Pvt. Ltd. I.P. Estate, New Delhi 611, Surya Kiran Building, Kg Marg, Connaught Place, New Delhi – 110 001 (Pan:Aaacf6111G) (Appellant) (Respondent) C.O. No.198/Del/2022 (Asstt. Year : 2014-15) Adventure Resorts Vs. Dcit, Circle 1(2) & Cruises Pvt. Ltd. New Delhi 611, Surya Kiran Building, Kg Marg, Connaught Place, New Delhi – 110 001 (Pan: Aaacf6111G) (Appellant) (Respondent Appellant By : None Respondent By :Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing 22.09.2025 Date Of Pronouncement 30.09.2025

bogus. Once the AO has accepted the books of accounts and he has not resorted to section 145 of the Act , there is no reason that AO will disallow the purchases. In the given facts and circumstances of the case, we are of the view that the CIT(A) has rightly deleted the addition and we confirm the same

M/S LS CONTRACTORS PRIVATE LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 30, DELHI, DELHI

In the result, both the appeals of the Assessee are partly

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishraआ.अ.सं/.I.T.A Nos.2207 & 2208/Del/2025 िनधा"रणवष"/Assessment Years:2019-20 & 2020-21 बनाम M/S Ls Contractors Dcit, Private Limited Vs. Central Circle-30, H-12, Tropical Building, E-2, Ground Floor, Connaught Place, New Delhi. Ara Centre, Pan No.Aabcl8541R Jhandewalan Extension Karol Bagh, New Delhi. अपीलाथ" Appellant ""यथ"/Respondent

bogus purchases to the extent of Rs.5,57,07,002/- in assessment year 2019-20 and M/S LS CONTRACTORS PVT. LTD. Rs.99,12,000/- in assessment year 2020-21 totaling to Rs.6,55,19,002/-. In the satisfaction note, though the assessing officer referred to ‘Annexure R-l’ and ‘Annexure A-31’ but the copy thereof was not supplied

M/S LS CONTRACTORS PRIVATE LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 30, DELHI, DELHI

In the result, both the appeals of the Assessee are partly

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishraआ.अ.सं/.I.T.A Nos.2207 & 2208/Del/2025 िनधा"रणवष"/Assessment Years:2019-20 & 2020-21 बनाम M/S Ls Contractors Dcit, Private Limited Vs. Central Circle-30, H-12, Tropical Building, E-2, Ground Floor, Connaught Place, New Delhi. Ara Centre, Pan No.Aabcl8541R Jhandewalan Extension Karol Bagh, New Delhi. अपीलाथ" Appellant ""यथ"/Respondent

bogus purchases to the extent of Rs.5,57,07,002/- in assessment year 2019-20 and M/S LS CONTRACTORS PVT. LTD. Rs.99,12,000/- in assessment year 2020-21 totaling to Rs.6,55,19,002/-. In the satisfaction note, though the assessing officer referred to ‘Annexure R-l’ and ‘Annexure A-31’ but the copy thereof was not supplied

IMRAN AHMAD,MORADABAD, UTTAR PRADESH vs. INCOME TAX OFFICER, MORADABAD

Appeal is partly allowed

127 taxmann.com 806 wherein it has been held that where Assessing Officer after receiving information from Investigation Wing that assessee had booked bogus expenses in names of certain entities, verified return of assessee and observed that expenses were inflated by assessee by booking bogus expenses without receiving any actual goods/services, reopening of assessment was justified. Further Reliance is also placed

P S METAL STORE,NEW DELHI vs. ITO WARD- 63(3), NEW DELHI

In the result, appeal of the assessee is allowed in the aforesaid manner

Bench: Shri Shamim Yahya & Shri Narinder Kumara.Yr. : 2007-08 P S Metal Store, Ito Ward 63(3), 5837, Basti Harphool Singh, Vs. New Delhi – 110 002 Sadar Bazar, Delhi – 110 006 (Pan: Adbpj5099C) (Appellant) (Respondent)

127/- vide order dated 20.03.2015 passed u/s. 143(3)/147 of the Act. 3. Aggrieved with the above order of the AO, the assessee preferred appeal before Ld.CIT(A), who after considering the submissions of the assessee, restricted the disallowance to 10% of the purchases vide order dated 24.12.2019. 4. Now, the assessee is in appeal before

DCIT CENTRAL CIRCLE, UTTAR PRADESH vs. MIRHA EXPORTS PRIVATE LTD. , DELHI

In the result, both appeals of the assessee are allowed and both appeals of the Revenue are dismissed

Bench: Shri Sudhir Kumar & Shri Manish Agarwalsl. Ita No(S) Asst. Appeal(S) By No Year(S) Appellant Vs. Respondent Appellant Respondent 1. 873/Del/2022 2012-13 Dcit M/S. Mirha Exports Pvt.Ltd. (Revenue’S Appeal) Central Circle 30, Bazar Lane, Bengali Ghaziabad Market, Central Delhi-110001 Pan-Aaacm8612P 2. 655/Del/2022 2012-13 M/S. Mirha Exports Dcit (Assessee’S Appeal) Pvt.Ltd. Central Circle 30, Bazar Lane, Ghaziabad Bengali Market, Central Delhi-110001 Pan-Aaacm8612P 3. 1233/Del/2022 2013-14 Dcit M/S. Mirha Exports Pvt. Ltd. (Revenue’S Appeal) Central Circle 30, Bazar Lane, Bengali Ghaziabad Market, Central Delhi-110001 Pan-Aaacm8612P 4. 656/Del/2022 2013-14 M/S. Mirha Exports Dcit (Assessee’S Appeal) Pvt. Ltd. Central Circle Ghaziabad 30, Bazar Lane, Bengali Market, Central Delhi-110001 Pan-Aaacm8612P 5. 1234/Del/2022 2015-16 Dcit M/S. Mirha Exports Pvt. Ltd. (Revenue’S Appeal) Central Circle 30, Bazar Lane, Bengali Ghaziabad Market, Central Delhi-110001 Pan-Aaacm8612P 6. 657/Del/2022 2015-16 M/S. Mirha Exports Dcit Pvt. Ltd. (Assessee’S Appeal) Central Circle 30, Bazar Lane, Ghaziabad Bengali Market, Central Delhi-110001 Pan-Aaacm8612P M/S. Mirha Exports Pvt. Ltd. 7. 874/Del/2022 2016-17 Dcit (Revenue’S Appeal) Central Circle 30, Bazar Lane, Bengali Ghaziabad Market, Central Delhi-110001 Pan-Aaacm8612P 8. 658/Del/2022 2016-17 M/S. Mirha Exports Dcit Pvt. Ltd. (Assessee’S Appeal) Central Circle Ghaziabad 30, Bazar Lane, Bengali Market, Central Delhi-110001 Pan-Aaacm8612P M/S. Mirha Exports Pvt. Ltd. 9. 875/Del/2022 2017-18 Dcit (Revenue’S Appeal) Central Circle 30, Bazar Lane, Bengali Ghaziabad Market, Central Delhi-110001 Pan-Aaacm8612P

bogus expenses claimed. Expenses were not fully verifiable due to nature of payments made and as observed above the trading results were accepted. 23. It is further seen that no incriminating paper was found as a result of search with respect to the cash purchases made nor any satisfaction of escapement of income of such cash purchases was reached

DCIT CENTRAL CIRCLE GZBD, HAPUR vs. MIRHA EXPORTS PRIVATE LTD. , DELHI

In the result, both appeals of the assessee are allowed and both appeals of the Revenue are dismissed

Bench: Shri Sudhir Kumar & Shri Manish Agarwalsl. Ita No(S) Asst. Appeal(S) By No Year(S) Appellant Vs. Respondent Appellant Respondent 1. 873/Del/2022 2012-13 Dcit M/S. Mirha Exports Pvt.Ltd. (Revenue’S Appeal) Central Circle 30, Bazar Lane, Bengali Ghaziabad Market, Central Delhi-110001 Pan-Aaacm8612P 2. 655/Del/2022 2012-13 M/S. Mirha Exports Dcit (Assessee’S Appeal) Pvt.Ltd. Central Circle 30, Bazar Lane, Ghaziabad Bengali Market, Central Delhi-110001 Pan-Aaacm8612P 3. 1233/Del/2022 2013-14 Dcit M/S. Mirha Exports Pvt. Ltd. (Revenue’S Appeal) Central Circle 30, Bazar Lane, Bengali Ghaziabad Market, Central Delhi-110001 Pan-Aaacm8612P 4. 656/Del/2022 2013-14 M/S. Mirha Exports Dcit (Assessee’S Appeal) Pvt. Ltd. Central Circle Ghaziabad 30, Bazar Lane, Bengali Market, Central Delhi-110001 Pan-Aaacm8612P 5. 1234/Del/2022 2015-16 Dcit M/S. Mirha Exports Pvt. Ltd. (Revenue’S Appeal) Central Circle 30, Bazar Lane, Bengali Ghaziabad Market, Central Delhi-110001 Pan-Aaacm8612P 6. 657/Del/2022 2015-16 M/S. Mirha Exports Dcit Pvt. Ltd. (Assessee’S Appeal) Central Circle 30, Bazar Lane, Ghaziabad Bengali Market, Central Delhi-110001 Pan-Aaacm8612P M/S. Mirha Exports Pvt. Ltd. 7. 874/Del/2022 2016-17 Dcit (Revenue’S Appeal) Central Circle 30, Bazar Lane, Bengali Ghaziabad Market, Central Delhi-110001 Pan-Aaacm8612P 8. 658/Del/2022 2016-17 M/S. Mirha Exports Dcit Pvt. Ltd. (Assessee’S Appeal) Central Circle Ghaziabad 30, Bazar Lane, Bengali Market, Central Delhi-110001 Pan-Aaacm8612P M/S. Mirha Exports Pvt. Ltd. 9. 875/Del/2022 2017-18 Dcit (Revenue’S Appeal) Central Circle 30, Bazar Lane, Bengali Ghaziabad Market, Central Delhi-110001 Pan-Aaacm8612P

bogus expenses claimed. Expenses were not fully verifiable due to nature of payments made and as observed above the trading results were accepted. 23. It is further seen that no incriminating paper was found as a result of search with respect to the cash purchases made nor any satisfaction of escapement of income of such cash purchases was reached

DCIT CENTRAL CIRCLE GZBD, HAPUR vs. MIRHA EXPORTS PRIVATE LTD. , DELHI

In the result, both appeals of the assessee are allowed and both appeals of the Revenue are dismissed

Bench: Shri Sudhir Kumar & Shri Manish Agarwalsl. Ita No(S) Asst. Appeal(S) By No Year(S) Appellant Vs. Respondent Appellant Respondent 1. 873/Del/2022 2012-13 Dcit M/S. Mirha Exports Pvt.Ltd. (Revenue’S Appeal) Central Circle 30, Bazar Lane, Bengali Ghaziabad Market, Central Delhi-110001 Pan-Aaacm8612P 2. 655/Del/2022 2012-13 M/S. Mirha Exports Dcit (Assessee’S Appeal) Pvt.Ltd. Central Circle 30, Bazar Lane, Ghaziabad Bengali Market, Central Delhi-110001 Pan-Aaacm8612P 3. 1233/Del/2022 2013-14 Dcit M/S. Mirha Exports Pvt. Ltd. (Revenue’S Appeal) Central Circle 30, Bazar Lane, Bengali Ghaziabad Market, Central Delhi-110001 Pan-Aaacm8612P 4. 656/Del/2022 2013-14 M/S. Mirha Exports Dcit (Assessee’S Appeal) Pvt. Ltd. Central Circle Ghaziabad 30, Bazar Lane, Bengali Market, Central Delhi-110001 Pan-Aaacm8612P 5. 1234/Del/2022 2015-16 Dcit M/S. Mirha Exports Pvt. Ltd. (Revenue’S Appeal) Central Circle 30, Bazar Lane, Bengali Ghaziabad Market, Central Delhi-110001 Pan-Aaacm8612P 6. 657/Del/2022 2015-16 M/S. Mirha Exports Dcit Pvt. Ltd. (Assessee’S Appeal) Central Circle 30, Bazar Lane, Ghaziabad Bengali Market, Central Delhi-110001 Pan-Aaacm8612P M/S. Mirha Exports Pvt. Ltd. 7. 874/Del/2022 2016-17 Dcit (Revenue’S Appeal) Central Circle 30, Bazar Lane, Bengali Ghaziabad Market, Central Delhi-110001 Pan-Aaacm8612P 8. 658/Del/2022 2016-17 M/S. Mirha Exports Dcit Pvt. Ltd. (Assessee’S Appeal) Central Circle Ghaziabad 30, Bazar Lane, Bengali Market, Central Delhi-110001 Pan-Aaacm8612P M/S. Mirha Exports Pvt. Ltd. 9. 875/Del/2022 2017-18 Dcit (Revenue’S Appeal) Central Circle 30, Bazar Lane, Bengali Ghaziabad Market, Central Delhi-110001 Pan-Aaacm8612P

bogus expenses claimed. Expenses were not fully verifiable due to nature of payments made and as observed above the trading results were accepted. 23. It is further seen that no incriminating paper was found as a result of search with respect to the cash purchases made nor any satisfaction of escapement of income of such cash purchases was reached