DCIT, CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. BALAJEE MINI STEELS & REROLLING PRIVATE LIMITED , PATNA

In the result, the appeals of the Revenue are dismissed

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm

139(1) of the Act on 22.09.2015 declaring a total income at Rs.2,85,95,540/-. Later, a search and seizure operation u/s 132 of the Act was conducted on 30.11.2022 on the assessee as a part of 'Kanodia Group of cases'. Later, the AO had passed the order u/s 147/143(3) of the Act on 31.03.2024 determining the total

DCIT, CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. BALMUKUND CEMENT & ROOFINGS PRIVATE LIMITED , KOLKATA

The appeal of the revenue is dismissed

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

Section 292C of the Act, the presumption is to be drawn in respect of WhatsApp transactions in the hands of the person from whose possession or control the books of accounts/ documents, etc. are found. Even the presumption u/s 292C of the Act is rebuttable when the assessee proved that he has not done any such transactions even in respect

DCIT, CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. BALMUKUND CEMENT & ROOFINGS PRIVATE LIMITED , KOLKATA

The appeal of the revenue is dismissed

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

Section 292C of the Act, the presumption is to be drawn in respect of WhatsApp transactions in the hands of the person from whose possession or control the books of accounts/ documents, etc. are found. Even the presumption u/s 292C of the Act is rebuttable when the assessee proved that he has not done any such transactions even in respect

DCIT, CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. BALMUKUND CEMENT & ROOFINGS PRIVATE LIMITED , KOLKATA

The appeal of the revenue is dismissed

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

Section 292C of the Act, the presumption is to be drawn in respect of WhatsApp transactions in the hands of the person from whose possession or control the books of accounts/ documents, etc. are found. Even the presumption u/s 292C of the Act is rebuttable when the assessee proved that he has not done any such transactions even in respect

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. BALMUKUND SPONGE AND IRON PRIVATE LIMITED, PATNA

The appeal of the revenue is dismissed

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

Section 292C of the Act, the presumption is to be drawn in respect of WhatsApp transactions in the hands of the person from whose possession or control the books of accounts/ documents, etc. are found. Even the presumption u/s 292C of the Act is rebuttable when the assessee proved that he has not done any such transactions even in respect

GOPAL & SONS HUF,KOLKATA vs. I.T.O., WARD - 32(1), KOLKATA, KOLKATA

The appeal of the revenue is dismissed

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

Section 292C of the Act, the presumption is to be drawn in respect of WhatsApp transactions in the hands of the person from whose possession or control the books of accounts/ documents, etc. are found. Even the presumption u/s 292C of the Act is rebuttable when the assessee proved that he has not done any such transactions even in respect

DCIT, CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. BALAJEE MINI STEELS & REROLLING PRIVATE LIMITED , PATNA

In the result, the appeals of the Revenue are dismissed

Bench: Shri Rajesh Kumar, Am\Nand\Nshripradip Kumar Choubey, Jm\Nita Nos.1688 To 1691/Kol/2025\N(Assessment Years: 2015-16 To 2018-19)\Nita No. 1725/Kol/2025\N(Assessment Year: 2016-17)\Ndcit, Central Circle 4(3)\Nbalajee Mini Steels & Rerolling\Naaykar Bhawan Poorva, 110,\Nprivate Limited\Nshantipally, Kolkata-700107,\N603, Shantikunj Apartment,\Nkolkata\Nphulwanipatna, G.P.O.800001,\N(Appellant)\Nvs.\Npatna\N(Respondent)\Npan No. Aabcb7265J\Nassessee By : Shri Manish Rastogi, Ar\Nrevenue By : S/Shri Praveen Kishore &\Npradeep Dungdung, Drs\Ndate Of Hearing: 01.12.2025\Ndate Of Pronouncement: 15.12.2025\Norder\Nper Rajesh Kumar, Am:\Nthese Are Appeals Preferred By The Revenue Against The Orders Of\Nthe Commissioner Of Income-Tax (Appeals), Kolkata-27 (Hereinafter\Nreferred To As The “Ld. Cit(A)"] Dated 13.04.2025 For The Ays 2015-16\Nto 2018-19.\Nas The Facts & Issues In All The Appeals Of Revenue Are Exactly\Nidentical, Hence, For The Sake Of Brevity, We Take Ita No.\N1688/Kol/2025 For A.Y. 2015-16 & Decide The Issue Accordingly.\Nα.Υ. 2015-16\Npage 2\Nita Nos.1688 To 1691/Kol/2025&1725/Kol/2025\Nbalajee Mini Steels & Rerolling Private Limited; Ays 2015-16 To 2018-19\Nita No. 1688/Kol/2025\N3.\Nthe Only Issue Raised By The Revenue Is Against The Deletion Of\Naddition By The Id. Cit (A) Of ₹1,07,03,817/- As Made By The Id. Ao\Non Account Of Suppression Of Income In Respect Of Bogus Purchases.\N3.

139(1) of the Act\non 22.09.2015 declaring a total income at Rs.2,85,95,540/-. Later, a search\nand seizure operation u/s 132 of the Act was conducted on 30.11.2022 on the\nassessee as a part of 'Kanodia Group of cases'. Later, the AO had passed the\norder u/s 147/143(3) of the Act on 31.03.2024 determining the total

DCIT, CENTRAL CIRCLE- 4(3), KOLKATA, KOLKATA vs. BALAJEE MINI STEELS & REROLLING PRIVATE LIMITED , PATNA

In the result, the appeals of the Revenue are dismissed

Bench: Shri Rajesh Kumar, Am\Nand\Nshripradip Kumar Choubey, Jm\Nita Nos.1688 To 1691/Kol/2025\N(Assessment Years: 2015-16 To 2018-19)\Nita No. 1725/Kol/2025\N(Assessment Year: 2016-17)\Ndcit, Central Circle 4(3)\Nbalajee Mini Steels & Rerolling\Naaykar Bhawan Poorva, 110,\Nprivate Limited\Nshantipally, Kolkata-700107,\N603, Shantikunj Apartment,\Nkolkata\Nphulwanipatna, G.P.O.800001,\Nvs.\N(Appellant)\Npatna\N(Respondent)\Npan No. Aabcb7265J\Nassessee By\N:\Nshri Manish Rastogi, Ar\Nrevenue By\N:\Ns/Shri Praveen Kishore &\Npradeep Dungdung, Drs\Ndate Of Hearing:\N01.12.2025\Ndate Of Pronouncement:\N15.12.2025\Norder\Nper Rajesh Kumar, Am:\Nthese Are Appeals Preferred By The Revenue Against The Orders Of The Commissioner Of Income-Tax (Appeals), Kolkata-27 (Hereinafter Referred To As The “Ld. Cit(A)"] Dated 13.04.2025 For The Ays 2015-16 To 2018-19.\Nas The Facts & Issues In All The Appeals Of Revenue Are Exactly Identical, Hence, For The Sake Of Brevity, We Take Ita No. 1688/Kol/2025 For A.Y. 2015-16 & Decide The Issue Accordingly.\Nα.Υ. 2015-16\Npage 2\Nita Nos.1688 To 1691/Kol/2025&1725/Kol/2025\Nbalajee Mini Steels & Rerolling Private Limited; Ays 2015-16 To 2018-19\Nita No. 1688/Kol/2025\N3.\Nthe Only Issue Raised By The Revenue Is Against The Deletion Of Addition By The Id. Cit (A) Of ₹1,07,03,817/- As Made By The Id. Ao On Account Of Suppression Of Income In Respect Of Bogus Purchases.\N3.

139(1) of the Act\non 22.09.2015 declaring a total income at Rs.2,85,95,540/-. Later, a search\nand seizure operation u/s 132 of the Act was conducted on 30.11.2022 on the\nassessee as a part of 'Kanodia Group of cases'. Later, the AO had passed the\norder u/s 147/143(3) of the Act on 31.03.2024 determining the total

DCIT, CENTRAL CIRCLE-4(3), KOLKATA , KOLKATA vs. BALAJEE MINI STEELS & REROLLING PRIVATE LIMITED , PATNA

In the result, the appeals of the Revenue are dismissed

Bench: Shri Rajesh Kumar, Am\Nand\Nshripradip Kumar Choubey, Jm\Nita Nos.1688 To 1691/Kol/2025\N(Assessment Years: 2015-16 To 2018-19)\Nita No. 1725/Kol/2025\N(Assessment Year: 2016-17)\Ndcit, Central Circle 4(3)\Nbalajee Mini Steels & Rerolling\Naaykar Bhawan Poorva, 110,\Nprivate Limited\Nshantipally, Kolkata-700107,\N603, Shantikunj Apartment,\Nkolkata\Nvs.\Nphulwanipatna, G.P.O.800001,\N(Appellant)\Npatna\N(Respondent)\Npan No. Aabcb7265J\Nassessee By\Nshri Manish Rastogi, Ar\Nrevenue By\Ns/Shri Praveen Kishore &\Npradeep Dungdung, Drs\Ndate Of Hearing: 01.12.2025\Ndate Of Pronouncement: 15.12.2025\Norder\Nper Rajesh Kumar, Am:\Nthese Are Appeals Preferred By The Revenue Against The Orders Of\Nthe Commissioner Of Income-Tax (Appeals), Kolkata-27 (Hereinafter\Nreferred To As The “Ld. Cit(A)"] Dated 13.04.2025 For The Ays 2015-16\Nto 2018-19.\Nas The Facts & Issues In All The Appeals Of Revenue Are Exactly\Nidentical, Hence, For The Sake Of Brevity, We Take Ita No.\N1688/Kol/2025 For A.Y. 2015-16 & Decide The Issue Accordingly.\Nα.Υ. 2015-16\Npage 2\Nita Nos.1688 To 1691/Kol/2025&1725/Kol/2025\Nbalajee Mini Steels & Rerolling Private Limited; Ays 2015-16 To 2018-19\Nita No. 1688/Kol/2025\N3.\Nthe Only Issue Raised By The Revenue Is Against The Deletion Of\Naddition By The Id. Cit (A) Of ₹1,07,03,817/- As Made By The Id. Ao\Non Account Of Suppression Of Income In Respect Of Bogus Purchases.\N3.

139(1) of the Act\non 22.09.2015 declaring a total income at Rs.2,85,95,540/-. Later, a search\nand seizure operation u/s 132 of the Act was conducted on 30.11.2022 on the\nassessee as a part of 'Kanodia Group of cases'. Later, the AO had passed the\norder u/s 147/143(3) of the Act on 31.03.2024 determining the total

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. BALMUKUND SPONGE AND IRON PRIVATE LIMITED, PATNA

The appeal of the Revenue is dismissed

Section 292C of the\nAct, the presumption is to be drawn in respect of WhatsApp\ntransactions in the hands of the person from whose possession or\ncontrol the books of accounts/ documents, etc. are found. Even the\npresumption u/s 292C of the Act is rebuttable when the assessee\nproved that he has not done any such transactions even in respect

BALMUKUND CEMENT & ROOFINGS PVT. LTD.,,KOLKATA vs. DCIT, CENTRAL CIRCLE 4(3),, KOLKATA

The appeal of the Revenue is dismissed

Section 292C of the\nAct, the presumption is to be drawn in respect of WhatsApp\ntransactions in the hands of the person from whose possession or\ncontrol the books of accounts/ documents, etc. are found. Even the\npresumption u/s 292C of the Act is rebuttable when the assessee\nproved that he has not done any such transactions even in respect

BALMUKUND SPONGE & IRON PVT. LTD.,,PATNA vs. DCIT, CENTRAL CIRCLE 4(3),, KOLKATA

The appeal of the Revenue is dismissed

Section 292C of the\nAct, the presumption is to be drawn in respect of WhatsApp\ntransactions in the hands of the person from whose possession or\ncontrol the books of accounts/ documents, etc. are found. Even the\npresumption u/s 292C of the Act is rebuttable when the assessee\nproved that he has not done any such transactions even in respect

BALMUKUND SPONGE & IRON PVT. LTD.,,PATNA vs. DCIT, CENTRAL CIRCLE 4(3),, KOLKATA

The appeal of the Revenue is dismissed

Section 292C of the\nAct, the presumption is to be drawn in respect of WhatsApp\ntransactions in the hands of the person from whose possession or\ncontrol the books of accounts/ documents, etc. are found. Even the\npresumption u/s 292C of the Act is rebuttable when the assessee\nproved that he has not done any such transactions even in respect

DCIT CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. BALMUKUND LEASE FIN PRIVATE LIMITED, PATNA

The appeal of the Revenue is dismissed

Section 292C of the\nAct, the presumption is to be drawn in respect of WhatsApp\ntransactions in the hands of the person from whose possession or\ncontrol the books of accounts/ documents, etc. are found. Even the\npresumption u/s 292C of the Act is rebuttable when the assessee\nproved that he has not done any such transactions even in respect

BALMUKUND SPONGE & IRON PVT. LTD.,,PATNA vs. DCIT, CENTRAL CIRCLE 4(3),, KOLKATA

The appeal of the Revenue is dismissed

Section 292C of the\nAct, the presumption is to be drawn in respect of WhatsApp\ntransactions in the hands of the person from whose possession or\ncontrol the books of accounts/ documents, etc. are found. Even the\npresumption u/s 292C of the Act is rebuttable when the assessee\nproved that he has not done any such transactions even in respect

BALMUKUND SPONGE & IRON PVT. LTD.,,PATNA vs. DCIT, CENTRAL CIRCLE 4(3),, KOLKATA

The appeal of the Revenue is dismissed

Section 292C of the\nAct, the presumption is to be drawn in respect of WhatsApp\ntransactions in the hands of the person from whose possession or\ncontrol the books of accounts/ documents, etc. are found. Even the\npresumption u/s 292C of the Act is rebuttable when the assessee\nproved that he has not done any such transactions even in respect

DCIT, CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. BALMUKUND CEMENT & ROOFINGS PRIVATE LIMITED, KOLKATA

The appeal of the Revenue is dismissed

Section 292C of the\nAct, the presumption is to be drawn in respect of WhatsApp\ntransactions in the hands of the person from whose possession or\ncontrol the books of accounts/ documents, etc. are found. Even the\npresumption u/s 292C of the Act is rebuttable when the assessee\nproved that he has not done any such transactions even in respect

DCIT, CC-2(4), KOLKATA, KOLKATA vs. M/S BALAJI AGRO PVT. LTD., KOLKATA

In the result, the appeal of the Revenue is dismissed

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm Dcit, Central Circle-2(4), M/S Balaji Agro Pvt. Ltd. Aaykar Bhavan Poorva, A5-6 Sarkarpool Maheshtala, 4Th Floor, 110 Shantipally, E.M. New Budge Budge Trunk Rd. Vs. Bypass, Kolkata-700107 Gopalpur 24 Paraganas South West Bengal Kolkata-700143, West Bengal (Appellant) (Respondent) Pan No. Aabcb9078M Assessee By : Shri Miraj D Shah, Ar Revenue By : Shri Raja Sengupta, Dr Date Of Hearing: 16.07.2025 Date Of Pronouncement: 30.07.2025

139(1) of the Act. The ld. AO issued questionnaire along with notice u/s 43A of the Act besides, issuing notice u/s 143(2) of the Act. During the course of assessment proceedings, the ld. AO on the basis of incriminating material and perusal of the submission of the assessee observed that the assessee has taken loan

DCIT, CENTRAL CIRCLE - 1(4), KOLKATA, KOLKATA vs. M/S. HINDUSTHAN ENGINEERING & INDUSTRIES LTD., , KOLKATA

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

Bench: Shri S.S.Godara, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.952/Kol/2018 ("नधा"रणवष" / Assessment Year:2011-12)

bogus since it is common knowledge that sales of goods cannot taken place without purchase of goods in the first place. So, therefore, in the light of the evidences adduced to prove the genuineness of the transactions and when the fact remains that the sales has been accepted by the Assessing Officer in totality, the action of the Assessing Officer