DY CIT CC 7 (2), MUMBAI vs. M/S MAN GLOBAL LTD., MUMBAI

In the result, all the appeals of the Revenue are dismissed and cross objections of the assessee in CO Nos

Bench: Sri Rajesh Kumar, Am & Sri Amarjit Singh, Jm आयकर आयकर अपील आयकर आयकर अपील अपील संसंसंसं./ Ita No. 7440/Mum/2019 अपील (िनधा"रण वष" / Assessment Year 2011-12) आयकर आयकर अपील आयकर आयकर अपील अपील संसंसंसं./ Ita No. 7533/Mum/2019 अपील (िनधा"रण वष" / Assessment Year 2012-13) आयकर आयकर अपील आयकर आयकर अपील अपील संसंसंसं./ Ita No. 7534/Mum/2019 अपील (िनधा"रण वष" / Assessment Year 2013-14) आयकर अपील आयकर अपील संसंसंसं./ Ita No. 7535/Mum/2019 आयकर आयकर अपील अपील (िनधा"रण वष" / Assessment Year 2014-15) आयकर आयकर अपील आयकर आयकर अपील अपील संसंसंसं./ Ita No. 7536/Mum/2019 अपील (िनधा"रण वष" / Assessment Year 2015-16)

purchases as against the 100% addition made by the AO. Since we have allowed the appeal of the assessee on the legal issue by holding that the jurisdiction of the AO to make addition is invalid. Consequently the appeal of the revenue becomes infructuous and is accordingly dismissed. 40. The issue raised in ground no. 1 in CO 87 & 88/Mum/2021

DCIT CC 8(3)(ERSTWHILE DCIT,CC-46, MUMBAI vs. JSW STEELS LTD, MUMBAI

Appeal of the revenue is partly allowed and appeal of the assessee is dismissed

bogus purchases." 7.8.3. Since the facts in the instant case is identical to that of the assessee’s own case as mentioned above, we do not find any error in findings of the Ld.CIT(A), and M/s. JSW Steels Ltd. hence, we are inclined uphold findings of Ld.CIT(A) and reject ground taken by the revenue. Accordingly the ground No.13

JSW STEELS LTD,MUMBAI vs. DCIT CC 8(3), MUMBAI

Appeal of the revenue is partly allowed and appeal of the assessee is dismissed

bogus purchases." 7.8.3. Since the facts in the instant case is identical to that of the assessee’s own case as mentioned above, we do not find any error in findings of the Ld.CIT(A), and M/s. JSW Steels Ltd. hence, we are inclined uphold findings of Ld.CIT(A) and reject ground taken by the revenue. Accordingly the ground No.13

JSW STEELS LTD,MUMBAI vs. DCIT CC 8(3), MUMBAI

Appeal of the revenue is partly allowed and appeal of the assessee is dismissed

bogus purchases." 7.8.3. Since the facts in the instant case is identical to that of the assessee’s own case as mentioned above, we do not find any error in findings of the Ld.CIT(A), and M/s. JSW Steels Ltd. hence, we are inclined uphold findings of Ld.CIT(A) and reject ground taken by the revenue. Accordingly the ground No.13

DCIT CC 8(3)(ERSTWHILE DCIT,CC-46, MUMBAI vs. JSW STEELS LTD, MUMBAI

Appeal of the revenue is partly allowed and appeal of the assessee is dismissed

bogus purchases." 7.8.3. Since the facts in the instant case is identical to that of the assessee’s own case as mentioned above, we do not find any error in findings of the Ld.CIT(A), and M/s. JSW Steels Ltd. hence, we are inclined uphold findings of Ld.CIT(A) and reject ground taken by the revenue. Accordingly the ground No.13

JSW STEELS LTD,MUMBAI vs. DCIT CC 8(3), MUMBAI

Appeal of the revenue is partly allowed and appeal of the assessee is dismissed

bogus purchases." 7.8.3. Since the facts in the instant case is identical to that of the assessee’s own case as mentioned above, we do not find any error in findings of the Ld.CIT(A), and M/s. JSW Steels Ltd. hence, we are inclined uphold findings of Ld.CIT(A) and reject ground taken by the revenue. Accordingly the ground No.13

JSW STEEL LIMITED,MUMBAI vs. ACIT,CC-46, MUMBAI

Appeal of the revenue is partly allowed and appeal of the assessee is dismissed

bogus purchases." 7.8.3. Since the facts in the instant case is identical to that of the assessee’s own case as mentioned above, we do not find any error in findings of the Ld.CIT(A), and M/s. JSW Steels Ltd. hence, we are inclined uphold findings of Ld.CIT(A) and reject ground taken by the revenue. Accordingly the ground No.13

DCIT CC 8(3), MUMBAI vs. JSW STEELS LTD, MUMBAI

Appeal of the revenue is partly allowed and appeal of the assessee is dismissed

bogus purchases." 7.8.3. Since the facts in the instant case is identical to that of the assessee’s own case as mentioned above, we do not find any error in findings of the Ld.CIT(A), and M/s. JSW Steels Ltd. hence, we are inclined uphold findings of Ld.CIT(A) and reject ground taken by the revenue. Accordingly the ground No.13

DCIT CC 8(3), MUMBAI vs. JSW STEELS LTD, MUMBAI

Appeal of the revenue is partly allowed and appeal of the assessee is dismissed

bogus purchases." 7.8.3. Since the facts in the instant case is identical to that of the assessee’s own case as mentioned above, we do not find any error in findings of the Ld.CIT(A), and M/s. JSW Steels Ltd. hence, we are inclined uphold findings of Ld.CIT(A) and reject ground taken by the revenue. Accordingly the ground No.13

DCIT (LTU)-2, MUMBAI vs. M/S RELIANCE INDUSTRIES LTD., MUMBAI

In the result, the ITA No

115J, does not apply in terms of section 115JB, we cannot be at liberty to be guided by the coordinate bench decision implying otherwise. The very foundation of deviation by the coordinate bench does not, therefore, hold good in law. In any event, this issue is decided on merits in favour of the assessee by Hon‟ble Calcutta High Court

RELIANCE INDUSTRIES LTD,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX LARGE TAXPAYER UNIT-2, MUMBAI

In the result, the ITA No

115J, does not apply in terms of section 115JB, we cannot be at liberty to be guided by the coordinate bench decision implying otherwise. The very foundation of deviation by the coordinate bench does not, therefore, hold good in law. In any event, this issue is decided on merits in favour of the assessee by Hon‟ble Calcutta High Court

RELIANCE INDUSTRIES LIMITED,MUMBAI vs. ACIT , MUMBAI

In the result, the ITA No

115J, does not apply in terms of section 115JB, we cannot be at liberty to be guided by the coordinate bench decision implying otherwise. The very foundation of deviation by the coordinate bench does not, therefore, hold good in law. In any event, this issue is decided on merits in favour of the assessee by Hon‟ble Calcutta High Court

RELIANCE INDUSTRIES LTD.,MUMBAI vs. ACIT CIRCLE 3(4), MUMBAI

In the result, both the appeals of the assessee and both the appeals of the revenue are treated as partly allowed

Bench: Shri B.R. Baskaran (Am) & Shri Pavan Kumar Gadale (Jm)

purchases claimed by the assessee in both the years under consideration. Accordingly, this ground raised by the assessee in both the years are dismissed. 7. Ground Nos. 4 to 6 raised by the assessee in both the years relate to disallowance under section 14A, r.w. Rule 8D of I T Rules. 7.1 The details relating to the disallowance made

DCIT- 3(4) , MUMBAI vs. M/S RELIANCE INDUSTRIES LIMITED, MUMBAI

In the result, both the appeals of the assessee and both the appeals of the revenue are treated as partly allowed

Bench: Shri B.R. Baskaran (Am) & Shri Pavan Kumar Gadale (Jm)

purchases claimed by the assessee in both the years under consideration. Accordingly, this ground raised by the assessee in both the years are dismissed. 7. Ground Nos. 4 to 6 raised by the assessee in both the years relate to disallowance under section 14A, r.w. Rule 8D of I T Rules. 7.1 The details relating to the disallowance made

DCIT-3(4), MUMBAI vs. M/S RELIANCE INDUSTRIES LIMITED, MUMBAI

In the result, both the appeals of the assessee and both the appeals of the revenue are treated as partly allowed

Bench: Shri B.R. Baskaran (Am) & Shri Pavan Kumar Gadale (Jm)

purchases claimed by the assessee in both the years under consideration. Accordingly, this ground raised by the assessee in both the years are dismissed. 7. Ground Nos. 4 to 6 raised by the assessee in both the years relate to disallowance under section 14A, r.w. Rule 8D of I T Rules. 7.1 The details relating to the disallowance made

RELIANCE INDUSTRIES LIMITED,MUMBAI vs. DY COMMISSIONER OF INCOME TAX CIRCLE-3(4), MUMBAI

In the result, both the appeals of the assessee and both the appeals of the revenue are treated as partly allowed

Bench: Shri B.R. Baskaran (Am) & Shri Pavan Kumar Gadale (Jm)

purchases claimed by the assessee in both the years under consideration. Accordingly, this ground raised by the assessee in both the years are dismissed. 7. Ground Nos. 4 to 6 raised by the assessee in both the years relate to disallowance under section 14A, r.w. Rule 8D of I T Rules. 7.1 The details relating to the disallowance made

ACIT -3(4) , MUMBAI vs. RELIANCE INDUSTRIES LTD, MUMBAI

In the result, appeal by the Revenue is dismissed

Bench: Shri Pramod Kumar, Vice Preside & Shri Sandeep Singh Karhail

115J.‖ 23. In view of the above, once assessee’s accounts have been maintained in accordance with Companies Act and the same have also been scrutinised and audited by the statutory auditor, in absence of any material to negate these facts, the AO has limited power under section 115 JB of the Act to make adjustment to book profit only

RELIANCE INDUSTRIES LTD.,MUMBAI vs. ASSTT. CIT-CC-3(4), MUMBAI

In the result, appeal by the Revenue is dismissed

Bench: Shri Pramod Kumar, Vice Preside & Shri Sandeep Singh Karhail

115J.‖ 23. In view of the above, once assessee’s accounts have been maintained in accordance with Companies Act and the same have also been scrutinised and audited by the statutory auditor, in absence of any material to negate these facts, the AO has limited power under section 115 JB of the Act to make adjustment to book profit only

DCIT, CC-7(2), MUMBAI vs. M/S. PATANJALI FOODS LTD.,( FORMERLY KNOWN AS RUCHI SOYA INDUSTRIES LTD,, MUMBAI

In the result, the appeal and cross objections of the assessee are

Bench: Shri Aby T. Varkey, Jm & Shri S Rifaur Rahman, Am आयकर अपील सं/ I.T. A. No. 1172/Mum/2023 (निर्धारण वर्ष / Assessment Year: 2010-11) & आयकर अपील सं/ I.T. A. No. 1175/Mum/2023 (निर्धारण वर्ष / Assessment Year: 2012-13) & आयकर अपील सं/ I.T. A. No. 1176/Mum/2023 (निर्धारण वर्ष / Assessment Year: 2012-13) Dcit, Central Circle-7(2) Room No. 637, 6Th Floor, Aayakar Bhavan, M. K. Road, Mumbai-400020. बनाम / M/S. Patanjali Foods Ltd Vs. (Formerly Known As Ruchi Soya Industries Ltd) 616, Tulsiani Chambers, Nariman Point, Mumbai- 400021. Cross Objection No.51/Mum/2023 (Arising Out Of I.T. A. No. 1172/Mum/2023) (निर्धारण वर्ष / Assessment Year: 2010-11) M/S. Patanjali Foods Ltd (Formerly Known As Ruchi Soya Industries Ltd) 616, Tulsiani Chambers, Nariman Point, Mumbai- 400021. बनाम / Dcit, Central Circle-7(2) Vs. Room No. 637, 6Th Floor, Aayakar Bhavan, M. K. Road, Mumbai-400020. & आयकर अपील सं/ I.T. A. No. 320/Mum/2023 (निर्धारण वर्ष / Assessment Year: 2012-13) M/S. Patanjali Foods Ltd (Formerly Known As Ruchi Soya Industries Ltd) बनाम / Vs. Dcit, Central Circle-7(2) Room No. 637, 6Th Floor, Aayakar Bhavan, M. K. Road, Mumbai-400020. 616, Tulsiani Chambers, Nariman Point, Mumbai- 400021. स्थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaaci1220M 2

bogus. Referring to these observations, the AO held that, the assessee, in the present case, had sold a commodity at a price higher than the original purchase price, and then re-purchased it back at a lower price. This according to him implied that the purchases were inflated. The AO accordingly disallowed the inflated payments for purchases quantified at Rs.139