HI-TECH ENGINEERS,MUMBAI vs. CENTRAL CIRCLE 5(1), BANDRA EAST, MUMBAI,

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI OMKARESHWAR CHIDARA (Accountant Member)

purchases were bogus and had merely related upon the report of the Investigation Wing; and (c) that the additions were made on estimate basis. It was further submitted that in the penalty notices dated 30/09/2021 and 23/11/2023, the Assessing Officer had specified whether penalty was leviable for under-reporting of income in terms of Section 270A(2)(a) to 270A

DCIT-3(1)(1), MUMBAI, MUMBAI vs. RELCON INFRAPROJECTS LTD., MUMBAI

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

purchase from the bogus parties, as discussed above in FY 2016-2017 relevant to Assessment Year 2017-18 is hereby disallowed and is added to the total income of the assessee in Assessment Year 2017- 18 as bogus expense. Penalty proceedings under Section 270A of the Income Tax Act 1961 are hereby initiated on this issue for concealing the particulars

DCIT-3(1)(1), MUMBAI, MUMBAI vs. RELCON INFRAPROJECTS LTD., MUMBAI

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

purchase from the bogus parties, as discussed above in FY 2016-2017 relevant to Assessment Year 2017-18 is hereby disallowed and is added to the total income of the assessee in Assessment Year 2017- 18 as bogus expense. Penalty proceedings under Section 270A of the Income Tax Act 1961 are hereby initiated on this issue for concealing the particulars

DCIT-3(1)(1), MUMBAI, MUMBAI vs. RELCON INFRAPROJECTS LTD., MUMBAI

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

purchase from the bogus parties, as discussed above in FY 2016-2017 relevant to Assessment Year 2017-18 is hereby disallowed and is added to the total income of the assessee in Assessment Year 2017- 18 as bogus expense. Penalty proceedings under Section 270A of the Income Tax Act 1961 are hereby initiated on this issue for concealing the particulars

DCIT-3(1)(1), MUMBAI, MUMBAI vs. RELCON INFRAPROJECTS LTD., MUMBAI

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

purchase from the bogus parties, as discussed above in FY 2016-2017 relevant to Assessment Year 2017-18 is hereby disallowed and is added to the total income of the assessee in Assessment Year 2017- 18 as bogus expense. Penalty proceedings under Section 270A of the Income Tax Act 1961 are hereby initiated on this issue for concealing the particulars

DCIT-3(1)(1), MUMBAI, MUMBAI vs. RELCON INFRAPROJECTS LTD., MUMBAI

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

purchase from the bogus parties, as discussed above in FY 2016-2017 relevant to Assessment Year 2017-18 is hereby disallowed and is added to the total income of the assessee in Assessment Year 2017- 18 as bogus expense. Penalty proceedings under Section 270A of the Income Tax Act 1961 are hereby initiated on this issue for concealing the particulars

DCIT 3(1)(1),MUMBAI, MUMBAI vs. RELCON INFRAPROJECTS LTD, MUMBAI

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

purchase from the bogus parties, as discussed above in FY 2016-2017 relevant to Assessment Year 2017-18 is hereby disallowed and is added to the total income of the assessee in Assessment Year 2017- 18 as bogus expense. Penalty proceedings under Section 270A of the Income Tax Act 1961 are hereby initiated on this issue for concealing the particulars

DCIT-3(1)(1), MUMBAI, MUMBAI vs. RELCON INFRAPROJECTS LTD., MUMBAI

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

purchase from the bogus parties, as discussed above in FY 2016-2017 relevant to Assessment Year 2017-18 is hereby disallowed and is added to the total income of the assessee in Assessment Year 2017- 18 as bogus expense. Penalty proceedings under Section 270A of the Income Tax Act 1961 are hereby initiated on this issue for concealing the particulars

INCOME TAX OFFICER - 13(1)(1), MUMBAI, MUMBAI vs. JAIDEEP METALLICS AND ALLOY PVT LTD, MUMBAI

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI GIRISH AGRAWAL (Accountant Member)

9) 1.The appellant has further submitted that the Gross Profit Ratio and Net Profit ratio of the appellant company for the current year as well as for earlier years are as under: Particulars Assessment Years 2022-23 2021-22 2020-21 Turnover 6,43,22,07,459 3,62,98,27,724 2,73,88,76,101 Gross Profit

INCOME TAX OFFICER - 13(1)(1), MUMBAI, MUMBAI vs. JAIDEEP METALLICS AND ALLOYS PVT LTD, MUMBAI

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI GIRISH AGRAWAL (Accountant Member)

9) 1.The appellant has further submitted that the Gross Profit Ratio and Net Profit ratio of the appellant company for the current year as well as for earlier years are as under: Particulars Assessment Years 2022-23 2021-22 2020-21 Turnover 6,43,22,07,459 3,62,98,27,724 2,73,88,76,101 Gross Profit

WRITER BUSINESS SERVICES PVT. LTD.,MUMBAI vs. DCIT, CIRCLE-8(3)(1), MUMBAI

In the result, the appeal filed by the assessee is allowed

Bench: BEFORE, SHRI B R BASKARAN (Accountant Member), SHRI ANIKESH BANERJEE (Judicial Member)

bogus purchases, we notice that the assessee could not furnish explanations, since it had accounted those purchases under the trade name of M/s KLS Packaging Industries, while the assessing officer has noted it down in the name of the proprietor Shri Krishan Lal. However, the very same PAN number has been noted by the assessee and AO. This fact substantiates

ABANS REALTY AND INFRASTRUCTURE PRIVATE LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 4(3), MUMBAI

In the result, the appeal by the assessee for the

bogus.\n5. The Learned CIT(A) failed to consider the specific facts of each alleged non-\ngenuine entities:\nA) Manmish Traders Pvt Ltd.\na. The name of the directors and shareholders mentioned in para 7.3.3 and para\n7.3.4 were not the directors or shareholders of the company in AY 2018-19.\nb. The Learned CIT (A) has ignored the fact

ABANS REALTY AND INFRASTRUCTURE PRIVATE LTD,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 4(3), MUMBAI

In the result, the appeal by the assessee for the

bogus.\n5. The Learned CIT(A) failed to consider the specific facts of each alleged non-\ngenuine entities:\nA) Manmish Traders Pvt Ltd.\na. The name of the directors and shareholders mentioned in para 7.3.3 and para\n7.3.4 were not the directors or shareholders of the company in AY 2018-19.\nb. The Learned CIT (A) has ignored the fact

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-5(1), MUMBAI , MUMBAI vs. CEC-ITD CEM-TPL JOINT VENTURE , MUMBAI

In the result, all the appeals filed by the assessee are allowed and Revenue’s appeals are dismissed

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 148 of the Act. 24. Thus, if we follow the aforesaid principle laid down by the Hon‟ble Delhi High Court, it becomes manifest that foundational material alone would be relevant for the purpose of evaluating whether re-assessment powers were justifiably invoked. The ld. AO cannot take fresh ground while passing the order u/s. 148A(d). Thus

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-5(1), MUMBAI , MUMBAI vs. CEC-ITD CEM-TPL JOINT VENTURE , MUMBAI

In the result, all the appeals filed by the assessee are allowed and Revenue’s appeals are dismissed

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 148 of the Act. 24. Thus, if we follow the aforesaid principle laid down by the Hon‟ble Delhi High Court, it becomes manifest that foundational material alone would be relevant for the purpose of evaluating whether re-assessment powers were justifiably invoked. The ld. AO cannot take fresh ground while passing the order u/s. 148A(d). Thus

CEC - ITD CEM TPL JOINT VENTURE,MUMBAI vs. DCIT, CENTRAL CIRCLE 5(1), MUMBAI

In the result, all the appeals filed by the assessee are allowed and Revenue’s appeals are dismissed

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 148 of the Act. 24. Thus, if we follow the aforesaid principle laid down by the Hon‟ble Delhi High Court, it becomes manifest that foundational material alone would be relevant for the purpose of evaluating whether re-assessment powers were justifiably invoked. The ld. AO cannot take fresh ground while passing the order u/s. 148A(d). Thus

CEC- ITD CEM TPL JOINT VENTURE,MUMBAI vs. DCIT, CENTRAL CIRCLE 5(1), MUMBAI

In the result, all the appeals filed by the assessee are allowed and Revenue’s appeals are dismissed

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 148 of the Act. 24. Thus, if we follow the aforesaid principle laid down by the Hon‟ble Delhi High Court, it becomes manifest that foundational material alone would be relevant for the purpose of evaluating whether re-assessment powers were justifiably invoked. The ld. AO cannot take fresh ground while passing the order u/s. 148A(d). Thus

CEC-ITD CEM TPL JOINT VENTURE,MUMBAI vs. DCIT, CENTRAL CIRCLE 5(1), MUMBAI

In the result, all the appeals filed by the assessee are allowed and Revenue’s appeals are dismissed

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 148 of the Act. 24. Thus, if we follow the aforesaid principle laid down by the Hon‟ble Delhi High Court, it becomes manifest that foundational material alone would be relevant for the purpose of evaluating whether re-assessment powers were justifiably invoked. The ld. AO cannot take fresh ground while passing the order u/s. 148A(d). Thus

CEC- ITD CEM TPL JOINT VENTURE,MUMBAI vs. DCIT, CENTRAL CIRCLE 5(1), MUMBAI

In the result, all the appeals filed by the assessee are allowed and Revenue’s appeals are dismissed

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 148 of the Act. 24. Thus, if we follow the aforesaid principle laid down by the Hon‟ble Delhi High Court, it becomes manifest that foundational material alone would be relevant for the purpose of evaluating whether re-assessment powers were justifiably invoked. The ld. AO cannot take fresh ground while passing the order u/s. 148A(d). Thus