ITO-28(3)(1), MUMBAI, MUMBAI vs. SATYA PRAKASH SINGH, MUMBAI

In the result, the ground so taken by the assessee so far as it relates to challenging the order of the AO as passed beyond the period of limitation is hereby allowed

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadav

bogus purchases from three other parties, namely, Greenfield Overseas, Arihant International and Marque Global was brought to tax as unexplained expenditure u/s 69C of the Act and assessed income was determined at Rs. 4,32,95,82,203/- and assessment order u/s. 143(3) r.w.s. 147 of the Act was passed vide order dt. 23-06-2022. 7. The assessee

MR. SATYA PRAKASH SINGH,MUMBAI vs. ITO, WARD-28(3)(1), VASHI

In the result, the ground so taken by the assessee so far as it relates to challenging the order of the AO as passed beyond the period of limitation is hereby allowed

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadav

bogus purchases from three other parties, namely, Greenfield Overseas, Arihant International and Marque Global was brought to tax as unexplained expenditure u/s 69C of the Act and assessed income was determined at Rs. 4,32,95,82,203/- and assessment order u/s. 143(3) r.w.s. 147 of the Act was passed vide order dt. 23-06-2022. 7. The assessee

MANISH KANTILAL KAPADIA ,MUMBAI vs. ACIT CC 8(2), MUMBAI

In the result, all the appeals

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

bogus purchases and sales. Invoking section 145(3) of the Act, he rejected the books of account and, treating the e rejected the books of account and, treating the e rejected the books of account and, treating the Manish Kantilal Kapadia & Rekha Manish Kapadia Manish Kantilal Kapadia 5 ITA Nos. 264

MANISH KANTILAL KAPADIA,MUMBAI vs. DCIT CC -8(2), MUMBAI

In the result, all the appeals

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

bogus purchases and sales. Invoking section 145(3) of the Act, he rejected the books of account and, treating the e rejected the books of account and, treating the e rejected the books of account and, treating the Manish Kantilal Kapadia & Rekha Manish Kapadia Manish Kantilal Kapadia 5 ITA Nos. 264

IPCA LABORATORIES LTD.,MUMBAI vs. DY CIT -CC-5(2), MUMBAI

In the result, both the appeals of the assessee as well as the revenue for AYs 2009-10, 2010-11, 2011-12, 2012-13 & 2014-15 are partly allowed

Bench: Shri Aby T. Varkey, Jm & Shri Amarjit Singh, Am आयकर अपील सं/ I.T. A. No. 880/Mum/2021 (निर्धारण वर्ा / Assessment Year: 2009-10) & आयकर अपील सं/ I.T. A. No. 879/Mum/2021 (निर्धारण वर्ा / Assessment Year: 2010-11) & आयकर अपील सं/ I.T. A. No. 882/Mum/2021 (निर्धारण वर्ा / Assessment Year: 2011-12) & आयकर अपील सं/ I.T. A. No. 881/Mum/2021 (निर्धारण वर्ा / Assessment Year: 2012-13) & आयकर अपील सं/ I.T. A. No. 883/Mum/2021 (निर्धारण वर्ा / Assessment Year: 2014-15)

bogus long-term capital gains and share capital etc. According to the Revenue, ACIAL was being managed and controlled by Shri Shah and thus in light of his statement given in the course of his search, the & Others (Assessee & Revenue) A.Y Nos. 2009-10 to AY. 14-15 IPCA Laboratories Ltd professional fees paid to ACIAL was treated

CIT -CC5(2) CENTRAL RG., -5,, MUMBAI vs. M/S. IPCA LABORATORIES LTD, MUMBAI

Section 37(1) of the Act was unjustified.\n68\nITA No.879 to 883/M/2021\n& Others (Assessee & Revenue)\nA.Y Nos. 2009-10 to AY. 14-15\nIPCA Laboratories Ltd\nThus, the entire disallowance is held to be unsustainable and is\ndirected to be deleted.\n11.13 Now coming to AY 2010-11, as noted above, the CBDT\nCircular No. 5/2012 read with

IPCA LABORATORIES LTD.,MUMBAI vs. DY CIT -CC-5(2), MUMBAI

bogus purchases to 8% of the value of supplies\nacross all AYs 2009-10, 2010-11, 2011-12 & 2012-13. With these\ndirections, the grounds of the assessee are partly allowed and the\ngrounds raised by the Revenue are dismissed.\n10. Issue 7: Disallowance of professional fees paid\nGround Nos. 8-11 of the Revenue’s appeal

CIT -CC5(2) CENTRAL RG., -5,, MUMBAI vs. M/S. IPCA LABORATORIES LTD, MUMBAI

bogus purchases to 8% of the value of supplies\nacross all AYs 2009-10, 2010-11, 2011-12 & 2012-13. With these\ndirections, the grounds of the assessee are partly allowed and the\ngrounds raised by the Revenue are dismissed.\n10. Issue 7: Disallowance of professional fees paid\nGround Nos. 8-11 of the Revenue’s appeal

IPCA LABORATORIES LTD.,MUMBAI vs. DY CIT CC-5(2), MUMBAI

Section 37(1)\nof the Act. On facts, qua each of the sub-head of sales & promotion\nexpenses, the AO is noted to have examined the same and made\ndisallowance in the following manner, which is noted to be\nindependent and different from the amounts admitted to be\ndisallowable by Mr. Beli.\nNature of Expenses Quantum Disallowed\n- Expenses

DCIT- CC5(2), MUMBAI vs. IPCA LABORATORIES LTD., MUMBAI

bogus purchases to 8% of the value of supplies \nacross all AYs 2009-10, 2010-11, 2011-12 & 2012-13. With these \ndirections, the grounds of the assessee are partly allowed and the \ngrounds raised by the Revenue are dismissed.\n10. Issue 7: Disallowance of professional fees paid\nGround Nos. 8-11 of the Revenue’s appeal

IPCA LABORATORIES LTD.,MUMBAI vs. DY CIT CC-5(2), MUMBAI

Section 37(1)\nof the Act. On facts, qua each of the sub-head of sales & promotion\nexpenses, the AO is noted to have examined the same and made\ndisallowance in the following manner, which is noted to be\nindependent and different from the amounts admitted to be\ndisallowable by Mr. Beli.\nNature of Expenses\nQuantum Disallowed\n- Expenses

DY.CIT CC -5(2) CENT. RG. -5, MUMBAI vs. M/S. IPCA LABORATORIES LTD, MUMBAI

bogus purchases to 8% of the value of supplies\nacross all AYs 2009-10, 2010-11, 2011-12 & 2012-13. With these\ndirections, the grounds of the assessee are partly allowed and the\ngrounds raised by the Revenue are dismissed.\n10. Issue 7: Disallowance of professional fees paid\nGround Nos. 8-11 of the Revenue’s appeal

DCIT -CC5(2) CENTRAL RG., -5,, MUMBAI vs. M/S. IPCA LABORATORIES LTD, MUMBAI

Section 37(1) \nof the Act. On facts, qua each of the sub-head of sales & promotion \nexpenses, the AO is noted to have examined the same and made \ndisallowance in the following manner, which is noted to be \nindependent and different from the amounts admitted to be \ndisallowable by Mr. Beli.\nNature of Expenses\nQuantum Disallowed\n- Expenses

MILES STONE,GUJARAT vs. ACIT CC-1(3) , MUMBAI

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

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Prime Star 3-M, Ambika Darshan The Acit Moti Kadiya Sheri Central Circle-1(3) Sayedpura, Vs. Pratishtha Bhavan Surat, Gujarat-395003 Mumbai

purchases of ₹ 16.17 crores and on bogus sales of ₹1.51 crores amounting to ₹11,394/-. The learned Assessing Officer has categorically held that the total undisclosed commission income of ₹18,95,851/- is added in the hands of Mr. Bhanwarlal Jain on substantive basis for A.Y. 2015-16. This addition is also made in the hands of the assessee

MADHUR GEMS PVT. LTD,MUMBAI vs. ACIT CC-1(3), MUMBAI

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

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Prime Star 3-M, Ambika Darshan The Acit Moti Kadiya Sheri Central Circle-1(3) Sayedpura, Vs. Pratishtha Bhavan Surat, Gujarat-395003 Mumbai

purchases of ₹ 16.17 crores and on bogus sales of ₹1.51 crores amounting to ₹11,394/-. The learned Assessing Officer has categorically held that the total undisclosed commission income of ₹18,95,851/- is added in the hands of Mr. Bhanwarlal Jain on substantive basis for A.Y. 2015-16. This addition is also made in the hands of the assessee

ROSE GEMS PVT. LTD,MUMBAI vs. ACIT CC 1(3) , MUMBAI

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

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Prime Star 3-M, Ambika Darshan The Acit Moti Kadiya Sheri Central Circle-1(3) Sayedpura, Vs. Pratishtha Bhavan Surat, Gujarat-395003 Mumbai

purchases of ₹ 16.17 crores and on bogus sales of ₹1.51 crores amounting to ₹11,394/-. The learned Assessing Officer has categorically held that the total undisclosed commission income of ₹18,95,851/- is added in the hands of Mr. Bhanwarlal Jain on substantive basis for A.Y. 2015-16. This addition is also made in the hands of the assessee

MOTHER EXPORTS,SURAT vs. ACIT, CC 1(3), MUMBAI

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

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Prime Star 3-M, Ambika Darshan The Acit Moti Kadiya Sheri Central Circle-1(3) Sayedpura, Vs. Pratishtha Bhavan Surat, Gujarat-395003 Mumbai

purchases of ₹ 16.17 crores and on bogus sales of ₹1.51 crores amounting to ₹11,394/-. The learned Assessing Officer has categorically held that the total undisclosed commission income of ₹18,95,851/- is added in the hands of Mr. Bhanwarlal Jain on substantive basis for A.Y. 2015-16. This addition is also made in the hands of the assessee

PRIME STAR,SURAT vs. ACIT , CC-1(3) , MUMBAI

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

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Prime Star 3-M, Ambika Darshan The Acit Moti Kadiya Sheri Central Circle-1(3) Sayedpura, Vs. Pratishtha Bhavan Surat, Gujarat-395003 Mumbai

purchases of ₹ 16.17 crores and on bogus sales of ₹1.51 crores amounting to ₹11,394/-. The learned Assessing Officer has categorically held that the total undisclosed commission income of ₹18,95,851/- is added in the hands of Mr. Bhanwarlal Jain on substantive basis for A.Y. 2015-16. This addition is also made in the hands of the assessee