DCIT, CIRCLE - 11(1), KOLKATA, KOLKATA vs. M/S. J. J. EXPORTERS LTD., KOLKATA

Bench: Shri A. T. Varkey, Jm & Dr. A. L. Saini, Am]

depreciation to the tune of Rs.15,392/-. (4).Ground No.3 raised by the Revenue in Assessment Year 2008-09 in ITA No.1371/Kol/2017 relates to addition of Rs.6,43,440/- on account of unexplained investment

DCIT, CIRCLE - 11(1), KOLKATA, KOLKATA vs. M/S. J. J. EXPORTERS LTD., KOLKATA

Bench: Shri A. T. Varkey, Jm & Dr. A. L. Saini, Am]

depreciation to the tune of Rs.15,392/-. (4).Ground No.3 raised by the Revenue in Assessment Year 2008-09 in ITA No.1371/Kol/2017 relates to addition of Rs.6,43,440/- on account of unexplained investment

ACIT, CIR-1, DURGAPUR, DURGAPUR vs. SHRI RAKESH KUMAR CHOWDHURY, DURGAPUR

Bench: Shri S.S.Godara & Dr. A.L. Saini

invested funds in various items. Having no receivable does not justify the conclusion that assessee will not be able to pay, or this liability tantamount to be bogus if there is no corresponding receivable from the same job, is not correct. What was required is that to examine the source of payments in the respective years

SHRI RAKESH KUMAR CHAUDHARY,DURGAPUR vs. ACIT, CIR-DURGAPUR, DURGAPUR

Bench: Shri S.S.Godara & Dr. A.L. Saini

invested funds in various items. Having no receivable does not justify the conclusion that assessee will not be able to pay, or this liability tantamount to be bogus if there is no corresponding receivable from the same job, is not correct. What was required is that to examine the source of payments in the respective years

ACIT, CIRCLE - 5, KOLKATA, KOLKATA vs. M/S. VISHNU WEBTECH (P) LTD., KOLKATA

In the result, appeal of Revenue and CO of the assessee both are dismissed

Bench: Shri P.M.Jagtap & Shri N.V.Vasudevan

unexplained investment in construction for the following reasons given in his impugned order:- “I have gone through the submissions and documents filed by the appellant and also the order of the A.O As seen from the record, the CIT- II, Kolkata in his order u/s. 263 has issued a direction to reconcile the issue of expenditure incurred by the assessee

MANNA BRICKS MANUFACTURING & TRADING PVT. LTD.,MIDNAPORE(W) vs. JCIT, RANGE-2, MIDNAPORE, MIDNAPORE

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

Bench: Shri A. T. Varkey, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita No.389/Kol/2017 ("नधा"रणवष" / Assessment Year: 2010-11) Manna Bricks Manufacturing Vs. Jcit, Range – 2 & Trading Pvt. Ltd. Midnapore Vill: Sheulipur, P.O. Mohar, Dist Midnapore (W), West Bengal, Pin – 721161. "थायीलेखासं./जीआइआरसं./Pan/Gir No. : Aaecm 9769 R (Appellant) .. (Respondent)

investment of the share capital from unexplained source of income of the assessee company, so the said amount was added to the total income. On appeal, the ld. CIT(A) confirmed the order of the Assessing Officer. Aggrieved, the assessee is in before us. 5.2 We have heard both the parties and perused the records. We note that the assessee

ISHTIYAQUE AHMED,KOLKATA vs. DCIT/ACIT, CC - 4(3),, KOLKATA

In the result, all the captioned appeals of the assessee are allowed

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.2066 To 2071/Kol/2025 Assessment Years: 2020-21, 2021-22, 2022-23, 2019-20, 2020-21 & 2022-23 Ishtiyaque Ahmed……...……………..………………….……….……….……Appellant 55, Narkeldanga North Road, Narkeldanga, Kol-11.. [Pan: Ajxpa4337L] Vs. Dcit/Acit, Cc-4(3), Kolkata.……….…………………….....……...…..…..Respondent Appearances By: Shri Manish Tiwari, Ar Appeared On Behalf Of The Appellant. Shri Subrata Aich, Addl. Cit, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 10, 2025 Date Of Pronouncing The Order : December 08, 2025 Order Per Pradip Kumar Choubey: The Captioned Appeals Have Been Preferred By The Assessee Against The Separate Orders Of The Commissioner Of Income Tax (Appeals)-27, Kolkata [Hereinafter Referred To As The “Cit(A)”] Passed U/S 250 Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”]. Ita Nos.2066 To 2068/Kol/2025 Are Pertaining To The Quantum Additions & Ita Nos.2069 To 2071/Kol/2025 Are Pertaining To Levying Of Penalty U/S 272A(1)(D) Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since The Issues Involved In All The Appeals Are Interconnected & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Common Order.

unexplained investment u/s 69 of the Act, the assessee disclosed the property in the balance sheet as on 31.03.2020 at Rs 12,65,850/- and the same figure was mentioned in the balance sheet on 31.03.2019, on 31.03 2021 and also on 31.03.2022 and first three entries of the assets side of balance sheet as on 31.03.2020 of the assessee

ISHTIYAQUE AHMED,KOLKATA vs. DCIT/ACIT, CC-4(3), KOLKATA

In the result, all the captioned appeals of the assessee are allowed

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.2066 To 2071/Kol/2025 Assessment Years: 2020-21, 2021-22, 2022-23, 2019-20, 2020-21 & 2022-23 Ishtiyaque Ahmed……...……………..………………….……….……….……Appellant 55, Narkeldanga North Road, Narkeldanga, Kol-11.. [Pan: Ajxpa4337L] Vs. Dcit/Acit, Cc-4(3), Kolkata.……….…………………….....……...…..…..Respondent Appearances By: Shri Manish Tiwari, Ar Appeared On Behalf Of The Appellant. Shri Subrata Aich, Addl. Cit, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 10, 2025 Date Of Pronouncing The Order : December 08, 2025 Order Per Pradip Kumar Choubey: The Captioned Appeals Have Been Preferred By The Assessee Against The Separate Orders Of The Commissioner Of Income Tax (Appeals)-27, Kolkata [Hereinafter Referred To As The “Cit(A)”] Passed U/S 250 Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”]. Ita Nos.2066 To 2068/Kol/2025 Are Pertaining To The Quantum Additions & Ita Nos.2069 To 2071/Kol/2025 Are Pertaining To Levying Of Penalty U/S 272A(1)(D) Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since The Issues Involved In All The Appeals Are Interconnected & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Common Order.

unexplained investment u/s 69 of the Act, the assessee disclosed the property in the balance sheet as on 31.03.2020 at Rs 12,65,850/- and the same figure was mentioned in the balance sheet on 31.03.2019, on 31.03 2021 and also on 31.03.2022 and first three entries of the assets side of balance sheet as on 31.03.2020 of the assessee

ISHTIYAQUE AHMED,KOLKATA vs. DCIT/ACIT, CC-4(3),, KOLKATA

In the result, all the captioned appeals of the assessee are allowed

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.2066 To 2071/Kol/2025 Assessment Years: 2020-21, 2021-22, 2022-23, 2019-20, 2020-21 & 2022-23 Ishtiyaque Ahmed……...……………..………………….……….……….……Appellant 55, Narkeldanga North Road, Narkeldanga, Kol-11.. [Pan: Ajxpa4337L] Vs. Dcit/Acit, Cc-4(3), Kolkata.……….…………………….....……...…..…..Respondent Appearances By: Shri Manish Tiwari, Ar Appeared On Behalf Of The Appellant. Shri Subrata Aich, Addl. Cit, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 10, 2025 Date Of Pronouncing The Order : December 08, 2025 Order Per Pradip Kumar Choubey: The Captioned Appeals Have Been Preferred By The Assessee Against The Separate Orders Of The Commissioner Of Income Tax (Appeals)-27, Kolkata [Hereinafter Referred To As The “Cit(A)”] Passed U/S 250 Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”]. Ita Nos.2066 To 2068/Kol/2025 Are Pertaining To The Quantum Additions & Ita Nos.2069 To 2071/Kol/2025 Are Pertaining To Levying Of Penalty U/S 272A(1)(D) Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since The Issues Involved In All The Appeals Are Interconnected & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Common Order.

unexplained investment u/s 69 of the Act, the assessee disclosed the property in the balance sheet as on 31.03.2020 at Rs 12,65,850/- and the same figure was mentioned in the balance sheet on 31.03.2019, on 31.03 2021 and also on 31.03.2022 and first three entries of the assets side of balance sheet as on 31.03.2020 of the assessee

ISHTIYAQUE AHMED,KOLKATA vs. DCIT/ACIT, CC-4(3),, KOLKATA

In the result, all the captioned appeals of the assessee are allowed

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.2066 To 2071/Kol/2025 Assessment Years: 2020-21, 2021-22, 2022-23, 2019-20, 2020-21 & 2022-23 Ishtiyaque Ahmed……...……………..………………….……….……….……Appellant 55, Narkeldanga North Road, Narkeldanga, Kol-11.. [Pan: Ajxpa4337L] Vs. Dcit/Acit, Cc-4(3), Kolkata.……….…………………….....……...…..…..Respondent Appearances By: Shri Manish Tiwari, Ar Appeared On Behalf Of The Appellant. Shri Subrata Aich, Addl. Cit, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 10, 2025 Date Of Pronouncing The Order : December 08, 2025 Order Per Pradip Kumar Choubey: The Captioned Appeals Have Been Preferred By The Assessee Against The Separate Orders Of The Commissioner Of Income Tax (Appeals)-27, Kolkata [Hereinafter Referred To As The “Cit(A)”] Passed U/S 250 Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”]. Ita Nos.2066 To 2068/Kol/2025 Are Pertaining To The Quantum Additions & Ita Nos.2069 To 2071/Kol/2025 Are Pertaining To Levying Of Penalty U/S 272A(1)(D) Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since The Issues Involved In All The Appeals Are Interconnected & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Common Order.

unexplained investment u/s 69 of the Act, the assessee disclosed the property in the balance sheet as on 31.03.2020 at Rs 12,65,850/- and the same figure was mentioned in the balance sheet on 31.03.2019, on 31.03 2021 and also on 31.03.2022 and first three entries of the assets side of balance sheet as on 31.03.2020 of the assessee

ISHTIYAQUE AHMED,KOLKATA vs. DCIT/ACIT, CC-4(3),, KOLKATA

In the result, all the captioned appeals of the assessee are allowed

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.2066 To 2071/Kol/2025 Assessment Years: 2020-21, 2021-22, 2022-23, 2019-20, 2020-21 & 2022-23 Ishtiyaque Ahmed……...……………..………………….……….……….……Appellant 55, Narkeldanga North Road, Narkeldanga, Kol-11.. [Pan: Ajxpa4337L] Vs. Dcit/Acit, Cc-4(3), Kolkata.……….…………………….....……...…..…..Respondent Appearances By: Shri Manish Tiwari, Ar Appeared On Behalf Of The Appellant. Shri Subrata Aich, Addl. Cit, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 10, 2025 Date Of Pronouncing The Order : December 08, 2025 Order Per Pradip Kumar Choubey: The Captioned Appeals Have Been Preferred By The Assessee Against The Separate Orders Of The Commissioner Of Income Tax (Appeals)-27, Kolkata [Hereinafter Referred To As The “Cit(A)”] Passed U/S 250 Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”]. Ita Nos.2066 To 2068/Kol/2025 Are Pertaining To The Quantum Additions & Ita Nos.2069 To 2071/Kol/2025 Are Pertaining To Levying Of Penalty U/S 272A(1)(D) Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since The Issues Involved In All The Appeals Are Interconnected & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Common Order.

unexplained investment u/s 69 of the Act, the assessee disclosed the property in the balance sheet as on 31.03.2020 at Rs 12,65,850/- and the same figure was mentioned in the balance sheet on 31.03.2019, on 31.03 2021 and also on 31.03.2022 and first three entries of the assets side of balance sheet as on 31.03.2020 of the assessee

D.C.I.T CIR - 3,KOLKATA, ASANSOL vs. NARENDRA KHARKA, DURGAPUR

Bench: Shri M. Balaganesh, Am & Shri S. S. Viswanethra Ravi, Jm]

depreciation of case are being used for hire. However, no evidence of letting his own car for hire is not placed on record. Accordingly, he rejected the cash book for the Asst year 2009-10 as manipulated. He found that since the source of credits in the bank accounts with ICICI Bank and Axis Bank was not properly explained

DCIT, CIRCLE-1, SILIGURI, SILIGURI vs. M/S COCETRA TRADE LINK P LTD,, SILIGURI

In the result, the appeal of the revenue is dismissed

depreciation schedule is enclosed for your ready reference, which is self explanatory. This office does not find any merit in the audit observation, as such the impugned addition of fixed assets (Building) amounting to Rs.1 ,03,81 ,519/- remains explained and treating it as unexplained investment

SUPER REGRACTORIES,BURDWAN vs. I.T.O, WARD-1(4), ASANSOL, ASANSOL

In the result, the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Shri S.S. Viswanethra Ravi

unexplained investment imposed by the Assessing Officer under section 271(1)(c) of the Act. 2. The appeal was time barred by 11 days and on the basis of Affidavit dated 13.11.2013 filed by Shri Binod Kumar Shaw, Proprietor of M/s. Super Refractories, we condone the delay on merit and the appeal is admitted. I.T.A. No. 2229/KOL./2013 Assessment year

M/S. MATARANI VINTRADE PVT. LTD., ,KOLKATA vs. ITO, WARD - 15(1), KOLKATA , KOLKATA

Bench: Hon’Ble Shri P.M. Jagtap, V.P (Kz) & Hon’Ble Shri A. T. Varkey, Jm Assessment Year: 2012-13

invest in the share capital of the assessee. Moreover, it is noted that PAN Card, Voter' s Id Card of the Directors of the respective share applicant companies are also found enclosed with their replies. (We will discuss later in detail about each share applicant company infra). And it is noted that assessee pursuant to Assessing Officer’s notice

M/S SATYAM SMELTERS PVT. LTD.,KOLKATA vs. D.C.I.T.,CIRCLE-3(1), KOLKATA

Bench: "ी जे. सुधाकर रे"डी, लेखा सद"य एवं/And "ी ऐ. ट". वक", "यायीक सद"य) [Before Shri J. Sudhakar Reddy, Am & Shri A. T. Varkey, Jm]

depreciation and amortization expenses and other expenses total comes to Rs.70,30,38,654/- this year as on 31.03.2012 and in last year it was Rs.71,96,83,183/- and the profit before taxation as on 31.03.2012 with the assessee company is Rs.33,38,76,510/- from earlier year it is Rs.2,78,27,382/-. 7. We note that

D.C.I.T CC - V,KOLKATA, KOLKATA vs. SALSAR STOCK BROKING LTD, KOLKATA

In the result, all the appeals filed by the assesses are allowed

Bench: : Shri N.V.Vasudevan & Shri M. Balaganesh

depreciation of Rs. 22,28,085/-, the assessee furnished a loss return of Rs. 4,71,01,220/-. The assessment was completed u/s 153A / 143(3) of the Act on 11.5.2011 by treating the share trading loss as speculation loss in terms of Explanation to Section 73 of the Act and after making minor disallowances and determining total income

TIRUPATI MARBLES,KOLKATA vs. I.T.O., WARD - 44(2),, KOLKATA

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Shri Rajesh Kumar (Accountant Member), Shri Pradip Kumar Choubey (Judicial Member)

depreciation and finally made an addition of Rs.1,09,00,000/- in respect of unexplained investments. 3. Aggrieved by the said