M/S. UNIFUES LIFE SCIENCES LTD.,NAGPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX,, NAGPUR

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.419/Nag/2022 िनधा"रण वष" / Assessment Year : 2011-12 M/S.Unijules Life Sciences The Assistant Ltd., V Commissioner Of Income B 35/36, Midc Kalmehwar, S Tax, Central Circle-2(1), Nagpur – 441501. Nagpur. Pan: Aaacu8032D Appellant/ Assessee Respondent/Revenue Assessee By None. Revenue By Shri Abhay Y. Marathe – Sr.Dr Date Of Hearing 27/02/2024 Date Of Pronouncement 28/02/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeals)-3, Nagpur Under Section 250 Of The Income Tax Act, 1961 Dated 08.11.2021 Emanating From The Order Under Section 153A R.W.S 143(3) Of The Act, 1961 Dated 30.03.2016. The Grounds Of Appeal Raised By The Assessee Are As Under : M/S.Unijules Life Sciences Ltd., [A]

250 of the Income Tax Act, 1961 dated 08.11.2021 emanating from the order under section 153A r.w.s 143(3) of the Act, 1961 dated 30.03.2016. The grounds of appeal raised by the Assessee are as under : M/s.Unijules Life Sciences Ltd., [A] “1) The Assessment u/s 153A r.w.s 143(3) of Income Tax Act, 1961 (“Act”) is illegal, invalid and deserves

SUNRISE STRUCTURALS & ENGINEERING PVT LTD,NAGPUR vs. ASSISTANT/ DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-4 NAGPUR, NAGPUR

In the result, appeal filed by the assessee stands allowed

Bench: Shri Pawan Singh & Shri Khettra Mohan Roysunrise Structural & Acit/Dcit, Circle-4, Engineering P. Ltd., A10, Vs Nagpur Hingna Midc, Nagpur (Urban), Nagpur-440016 Pan : Aaccs 3220 M Assessee Respondent Assessee By : Shri K.P. Dewani, Advocate Revenue By : Shri Surjit Kumar Saha, Sr. Dr Date Of Hearing : 25.02.2026 Date Of Pronouncement : 10.04.2026 O R D E R

4 purchase to be genuine. A.O. after noting of incident report and investigation by DGGI has concluded escapement of income. No valid belief of escapement of income can be drawn by any person properly instructed in law. Notice is issued only on borrowed satisfaction. D) A.O. did not appreciate the submissions and documentary evidences filed during 148A proceedings. AO proceeded

M/S UNIJULES LIFE SCIENCES LTD.,NAGPUR vs. DCIT CENTRAL CIRCLE-2(1), NAGPUR

In the result, appeal filed by the assessee is allowed for statistical purposes

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

purchase of assets allegedly held bogus which is illegal, and which deserves to be deleted as per law. 7) On the facts and circumstances of the case and in law, the AO grossly erred in making and the CIT(A) grossly erred in confirming addition of Rs. 194,04,18,971 representing disallowance of bad debts written off debited

M/S UNIJULES LIFE SCIENCES LTD.,NAGPUR vs. ACIT CENTRAL CIRCLE-2(1), NAGPUR

In the result, appeal filed by the assessee is allowed for statistical purposes

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

purchase of assets allegedly held bogus which is illegal, and which deserves to be deleted as per law. 7) On the facts and circumstances of the case and in law, the AO grossly erred in making and the CIT(A) grossly erred in confirming addition of Rs. 194,04,18,971 representing disallowance of bad debts written off debited

M/S UNIJULES LIFE SCIENCES LTD.,NAGPUR vs. DCIT CENTRAL CIRCLE-2(1), NAGPUR

In the result, appeal filed by the assessee is allowed for statistical purposes

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

bogus being duly supported by third party evidences, the addition made by the AO without objectively and subjectively disproving the evidences so filed, and solely on the basis of statements recorded and information shared by officers other than the Assessing Officer, makes the addition grossly illegal and liable to be deleted as per law and in the interest of justice

SHRI ANKIT SHANKARLAL TANWANI,CHHINDWARA vs. ASSISTANAT COMMISSIONER OF INCOME TAX, NAGPUR

In the result, assessee’s appeal is partly allowed

Bench: Shri Sandeep Gosain, Jm & Shri Arun Khodpia, Am Assessment Year: 2019-20 Shri Ankit Shankar Lal Tanwani Vs. The Acit Near Shankar Mandir, Shankar Central Circle 2(1) Nagar, Pandhuna Pandhurna Nagpur Chhindwara – 480 334 (M.P.) Pan No.:Biapt 4756 R Appellant Respondent Assessee By: Shri Manoj G. Moryani, Adv. & Shri Bhavesh Moryani, Adv Revenue By :Shri Piyush Kolhe (Cit-Dr) Date Of Hearing: 28/04/2022 Date Of Pronouncement: 8/6 /2022 Order Per: Sandeep Gosain, J.M. The Captioned Appeal Has Been Filed By The Assessee Challenging The Impugned Order Dated 8Th October 2021, Passed By The Commissioner Of Income Tax (Appeals)–3, Nagpur, [In Short “The Learned Cit(A)”] Under Section 250 Of The Income Tax Act, 1961 (In Short "The Act") For The Assessment Year 2019-20. The Assessee Has Filed The Present Appeal On The Following Grounds:- 2. “1. The Commissioner Of Income Tax (Appeals)-3, Nagpur Erred In Confirming Addition, Therefore Order Passed Is Illegal, Invalid & Bad In Law.

4. AnkitShankarlalTanwani Assessee 21,50,000/- The main contention of the department is that the assessee has shown the 12. abnormal amount of profit U/s. 44AD to explain the money found and seized from locker. In the written submission, the department has further relied on statement recorded U/s. 131 of the Act. The contention of the departmental representative was that

M/S UNIJULES LIFE SCIENCES LTD,NAGPUR vs. ACIT, CENTRAL CIRCLE-2(1), NAGPUR

In the result, appeal filed by the assessee is allowed for statistical purposes

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

purchase of assets allegedly held bogus which is illegal, and which deserves to be deleted as per law. 6) On the facts and circumstances of the case and in law, the AO grossly erred in making and the CIT(A) grossly erred in confirming addition of Rs. 60,00,000 representing unaccounted income which is illegal, and which deserves

NIKITA SHANKARLAL TANWANI,CHHINDWARA vs. ASSISTANT COMMISSIONER OF INCOME TAX, NAGPUR

In the result, assessee’s appeal is partly allowed

Bench: Shri Sandeep Gosain, Jm & Shri Arun Khodpia, Am Assessment Year: 2018-19 Ms. Nikita Shankar Lal Tanwani Vs. The Acit Near Shankar Mandir, Shankar Central Circle 2(1) Nagar, Pandhuna Pandhurna Nagpur Chhindwara – 480 334 (M.P.) Pan No.:Borpt 4644 F Appellant Respondent Assessee By: Shri Manoj G. Moryani, Adv. & Shri Bhavesh Moryani, Adv Revenue By :Shri Piyush Kolhe (Cit-Dr) Date Of Hearing: 28/04/2022 Date Of Pronouncement: 8 /62022 Order Per: Sandeep Gosain, J.M. The Captioned Appeal Has Been Filed By The Assessee Challenging The Impugned Order Dated 8Th October 2021, Passed By The Commissioner Of Income Tax (Appeals)–3, Nagpur, [In Short “The Learned Cit(A)”] Under Section 250 Of The Income Tax Act, 1961 (In Short "The Act") For The Assessment Year 2018-19. The Present Appeal Has Been Filed On The Following Grounds:- 2. “1. The Commissioner Of Income Tax (Appeals)-3, Nagpur Erred In Confirming Addition, Therefore Order Passed Is Illegal, Invalid & Bad In Law.

4. Nikita Assessee 33,00,000/- ShankarlalTanwani 5. HarshaSantoshTanwani Anti 19,00,000/- TOTAL 1,88,50,000/- 12 Nikita Shankarlal Tanwani vs ACIT, CentralCircle 2(1), Nagpur 12. The main contention of the department is that the assessee has shown the abnormal amount of profit U/s. 44AD to explain the money found and seized from locker. In the written

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -1(2), NAGPUR vs. VIDARBHA INFOTECH PRIVATE LIMITED, NAGPUR

In the result, appeal by the Revenue is dismissed

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

purchases as bogus u/s 69C. I, therefore, hold that the impugned addition is not sustainable in law also.” The Revenue being aggrieved is in appeal before the Tribunal. 7. The learned Departmental Representative submitted that the assessee has not filed any details before the Assessing Officer and the expenditure incurred by the assessee is bogus in nature. He further submitted

ASHA SHANKARLAL TANWANI,CHHINDWARA vs. ASSISTANT COMMISSIONER OF INCOME TAX, NAGPUR

In the result, assessee’s appeal is partly allowed

Bench: Shri Sandeep Gosain, Jm & Shri Arun Khodpia, Am Assessment Year: 2018-19 Smt. Asha Shankarlal Tanwani Vs. The Acit 01, Shankar Nagar, Pandhuna Central Circle 2(1) Chhindwara – 480 334 (M.P.) Nagpur Pan No.:Bnvpt 1763 J Appellant Respondent Assessee By: Shri Manoj G. Moryani, Adv. & Shri Bhavesh Moryani, Adv Revenue By :Shri Piyush Kolhe (Cit-Dr) Date Of Hearing: 28/04/2022 Date Of Pronouncement: 8 /6/2022 Order Per: Sandeep Gosain, J.M. The Aforesaid Appeal By The Assessee Challenging The Impugned Order Dated 8Th October 2021, Passed By The Commissioner Of Income Tax (Appeals)– 3, Nagpur, [In Short “The Learned Cit(A)”] Under Section 250 Of The Income Tax Act, 1961 (In Short "The Act") For The Assessment Year 2018-19. The Present Appeal Has Been Filed On The Following Grounds:- 2. “1. The Commissioner Of Income Tax (Appeals)-3, Nagpur Erred In Confirming Addition, Therefore Order Passed Is Illegal, Invalid & Bad In Law. 2. On The Fact & Circumstances Learned Commissioner Of Income Tax (Appeals)-3, Nagpur Erred In Confirming Income Determined By The Assessing Officer At Rs.15,02,106/- Is Illegal, Invalid & Bad In Law.

4. Nikita ShankarlalTanwani Daughter 33,00,000/- 5. HarshaSantoshTanwani Sister in law 19,00,000/- TOTAL 1,88,50,000/- The main contention of the department is that the assessee has shown the 12. abnormal amount of profit U/s. 44AD to explain the money found and seized from locker. In the written submission the department has further relied on statement

HARSHA SANTOSH TANWANI,CHHINDWARA vs. ASSISTANT COMMISSIONER OF INCOME TAX, NAGPUR

In the result, assessee’s appeal is partly allowed

Bench: Shri Sandeep Gosain, Jm & Shri Arun Khodpia, Am Assessment Year: 2018-19 Shri Harsha Santosh Tanwani Vs. The Acit Near Shankar Mandir, Shankar Central Circle 2(1) Nagar,Pandhuna, Nagpur Pandhurna 480334 (M.P.) Pan No.:Bobpt 5794 Q Appellant Respondent Assessee By: Shri Manoj G. Moryani, Adv. & Shri Bhavesh Moryani, Adv Revenue By :Shri Piyush Kolhe (Cit-Dr) Date Of Hearing: 28/04/2022 Date Of Pronouncement: 8 / 6 /2022 Order Per: Sandeep Gosain, J.M. The Aforesaid Appeal By The Assessee Challenging The Impugned Order Dated 8Th October 2021, Passed By The Commissioner Of Income Tax (Appeals)–3, Nagpur, [In Short “The Learned Cit(A)”] Under Section 250 Of The Income Tax Act, 1961 (In Short "The Act") For The Assessment Year 2018-19. The Present Appeal Has Been Filed On The Following Grounds:- 2. “1. The Commissioner Of Income Tax (Appeals)-3, Nagpur Erred In Confirming Addition, Therefore Order Passed Is Illegal, Invalid & Bad In Law.

4. Nikita Niece 33,00,000/- ShankarlalTanwani 5. HarshaSantoshTanwani Assessee 19,00,000/- TOTAL 1,88,50,000/- The main contention of the department is that the assessee has 12. shown the abnormal amount of profit U/s. 44AD to explain the money found and seized from locker. In the written submission the department has further relied on statement recorded

HARSHA SANTOSH TANWANI,CHHINDWARA vs. ASSISTANT COMMISSIONER OF INCOME TAX, NAGPUR

In the result, assessee’s appeal is partly allowed

Bench: Shri Sandeep Gosain, Jm & Shri Arun Khodpia, Am Assessment Year: 2019-20 Shri Harsha Santosh Tanwani Vs. The Acit Near Shankar Mandir, Shankar Central Circle 2(1) Nagar,Pandhuna, Pandhurna, Nagpur Chhindwara 480334 (M.P.) Pan No.:Bobpt 5794 Q Appellant Respondent Assessee By: Shri Manoj G. Moryani, Adv. & Shri Bhavesh Moryani, Adv Revenue By :Shri Piyush Kolhe (Cit-Dr) Date Of Hearing: 28/04/2022 Date Of Pronouncement: 8 /6 /2022 Order Per: Sandeep Gosain, J.M. The Aforesaid Appeal By The Assessee Challenging The Impugned Order Dated 8Thoctober 2021, Passed By The Commissioner Of Income Tax (Appeals)–3, Nagpur, [In Short “The Learned Cit(A)”] Under Section 250 Of The Income Tax Act, 1961 (In Short "The Act") For The Assessment Year 2019-20. The Present Appeal Has Been Filed On The Following Grounds:- 2. “1. The Commissioner Of Income Tax (Appeals)-3, Nagpur Erred In Confirming Addition, Therefore Order Passed Is Illegal, Invalid & Bad In Law.

4. Nikita Niece 33,00,000/- ShankarlalTanwani 5. HarshaSantoshTanwani Assessee 19,00,000/- TOTAL 1,88,50,000/- The main contention of the department is that the assessee has 12. shown the abnormal amount of profit U/s. 44AD to explain the money found and seized from locker. In the written submission the department has further relied on statement recorded

ASHA SHANKARLAL TANWANI,CHHINDWARA vs. ASSISTANT COMMISSIONER OF INCOME TAX, NAGPUR

In the result, assessee’s appeal is party allowed

Bench: Shri Sandeep Gosain, Jm & Shri Arun Khodpia, Am Assessment Year: 2019-20 Smt. Asha Shankarlal Tanwani Vs. The Acit 01, Shankar Nagar, Pandhuna Central Circle 2(1) Chhindwara – 480 334 (M.P.) Nagpur Pan No.:Bnvpt 1763 J Appellant Respondent Assessee By: Shri Manoj G. Moryani, Adv. & Shri Bhavesh Moryani, Adv Revenue By :Shri Piyush Kolhe (Cit-Dr) Date Of Hearing: 28/04/2022 Date Of Pronouncement: 8 / 6 /2022 Order Per: Sandeep Gosain, J.M. The Aforesaid Appeal By The Assessee Challenging The Impugned Order Dated 8Th October 2021, Passed By The Commissioner Of Income Tax (Appeals)–3, Nagpur, [In Short “The Learned Cit(A)”] Under Section 250 Of The Income Tax Act, 1961 (In Short "The Act") For The Assessment Year 2019-20. The Present Appeal Has Been Filed On The Following Grounds:- 2. “1. The Commissioner Of Income Tax (Appeals)-3, Nagpur Erred In Confirming Addition, Therefore Order Passed Is Illegal, Invalid & Bad In Law.

4. Nikita ShankarlalTanwani Daughter 33,00,000/- 5. HarshaSantoshTanwani Sister in law 19,00,000/- TOTAL 1,88,50,000/- 12. The main contention of the department is that the assessee has shown the abnormal amount of profit U/s. 44AD to explain the money found and seized from locker. In the written submission the department has further relied on statement

NIKITA SHANKARLAL TANWANI,CHHINDWARA vs. ASSISTANT COMMISSIONER OF INCOME TAX, NAGPUR

In the result, assessee’s appeal is partly allowed

Bench: Shri Sandeep Gosain, Jm & Shri Arun Khodpia, Am Assessment Year: 2019-20 Ms. Nikita Shankar Lal Tanwani Vs. The Acit Near Shankar Mandir, Shankar Central Circle 2(1) Nagar, Pandhuna Pandhurna Nagpur Chhindwara – 480 334 (M.P.) Pan No.:Borpt 4644 F Appellant Respondent Assessee By: Shri Manoj G. Moryani, Adv. & Shri Bhavesh Moryani, Adv Revenue By :Shri Piyush Kolhe (Cit-Dr) Date Of Hearing: 28/04/2022 Date Of Pronouncement: 8 /6 /2022 Order Per: Sandeep Gosain, J.M. The Captioned Appeal Has Been Filed By The Assessee Challenging The Impugned Order Dated 8Th October 2021, Passed By The Commissioner Of Income Tax (Appeals)–3, Nagpur, [In Short “The Learned Cit(A)”] Under Section 250 Of The Income Tax Act, 1961 (In Short "The Act") For The Assessment Year 2019-20. The Present Appeal Has Been Filed On The Following Grounds:- 2. “1. The Passed Is Illegal, Invalid & Bad In Law.

4. Nikita Assessee 33,00,000/- ShankarlalTanwani 5. HarshaSantoshTanwani Anti 19,00,000/- TOTAL 1,88,50,000/- The main contention of the department is that the assessee has 12. shown the abnormal amount of profit U/s. 44AD to explain the money found and seized from locker. In the written submission the department has further relied on statement recorded

SHRI SHANKARLAL CHANDUMAL TANWANI,CHHINDWARA vs. ASSISTANT COMMISSIONER OF INCOME TAX , NAGPUR

In the result, assessee’s appeal is partly allowed

Bench: Shri Sandeep Gosain, Jm & Shri Arun Khodpia, Am Assessment Year: 2019-20 Shri Shankarlal Chandumal Tanwani Vs. The Acit 41, Prop. Shankar Kirana, Tar Bazar, Central Circle 2(1) Main Road,Pandhurna 480334 (M.P.) Nagpur Pan No.:Aiqpt 1252 M Appellant Respondent Assessee By: Shri Manoj G. Moryani, Adv. & Shri Bhavesh Moryani, Adv Revenue By :Shri Piyush Kolhe (Cit-Dr) Date Of Hearing: 28/04/2022 Date Of Pronouncement: 8 / 6 /2022 Order Per: Sandeep Gosain, J.M. The Captioned Appeal Has Been Filed By The Assessee Challenging The Impugned Order Dated 7Th October 2021, Passed By The Commissioner Of Income Tax (Appeals)–3, Nagpur, [In Short “The Learned Cit(A)”] Under Section 250 Of The Income Tax Act, 1961 (In Short "The Act") For The Assessment Year 2019-20. The Assessee Has Filed The Present Appeal On The Following Grounds:- 2. “1. The Commissioner Of Income Tax (Appeals)-3, Nagpur Erred In Confirming Addition, Therefore Order Passed Is Illegal, Invalid & Bad In Law.

4. Nikita ShankarlalTanwani Daughter 33,00,000/- 5. HarshaSantoshTanwani Sister in law 19,00,000/- TOTAL 1,88,50,000/- 10. The main contention of the department is that the assessee failed to give any satisfactory explanation i.e. identity of the persons who allegedly gave brokerage and genuineness of the brokerage transaction income and only stated that he has paid

SHRI SANTOSH CHANDUMAL TANWANI,CHHINDWARA vs. ASSISTANT COMMISSIONER OF INCOME TAX, NAGPUR

In the result, assessee’s appeal is partly allowed

Bench: Shri Sandeep Gosain, Jm & Shri Arun Khodpia, Am Assessment Year: 2019-20 Shri Santosh Tanwani Vs. The Acit A-56, Near Jain Bhavan, Bus Stand, Central Circle 2(1) Pandhurna,Chhindwara 480334 (M.P.) Nagpur Pan No.:Adapt 8743 N Appellant Respondent Assessee By: Shri Manoj G. Moryani, Adv. & Shri Bhavesh Moryani, Adv Revenue By :Shri Piyush Kolhe (Cit-Dr) Date Of Hearing: 28/04/2022 Date Of Pronouncement: 8 /06/2022 Order Per: Sandeep Gosain, J.M. The Present Appeal Has Been Preferred By The Assessee Challenging The Impugned Order Dated 8Th October 2021, Passed By The Commissioner Of Income Tax (Appeals)–3, Nagpur, [In Short “The Learned Cit(A)”] Under Section 250 Of The Income Tax Act, 1961 (In Short "The Act") For The Assessment Year 2019-20. The Assessee Has Filed The Present Appeal On The Following Grounds:- 2. “1. The Commissioner Of Income Tax (Appeals)-3, Nagpur Erred In Confirming Addition, Therefore Order Passed Is Illegal, Invalid & Bad In Law. 2. On The Fact & Circumstances Learned Commissioner Of Income Tax (Appeals)-3, Nagpur Erred In Confirming Brokerage Income At Rs.

4. AnkitShankarlalTanwani Nephew 21,50,000/- The main contention of the department is that the assessee failed to give 9. any satisfactory explanation i.e. identity of the persons who allegedly gave brokerage and genuineness of the brokerage transaction income and only stated that he has paid advance tax on declared income. In the written submission the department has further relied

ANKIT SHANKARLAL TANWANI,CHHINDWARA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), NAGPUR

In the result, assessee’s appeal is partly allowed

Bench: Shri Sandeep Gosain, Jm & Shri Arun Khodpia, Am Assessment Year: 2018-19 Shri Ankit Shankar Lal Tanwani Vs. The Acit Near Shankar Mandir, Shankar Central Circle 2(1) Nagar, Pandhuna Pandhurna Nagpur Chhindwara – 480 334 (M.P.) Pan No.:Biapt 4756 R Appellant Respondent Assessee By: Shri Manoj G. Moryani, Adv. & Shri Bhavesh Moryani, Adv Revenue By :Shri Piyush Kolhe (Cit-Dr) Date Of Hearing: 28/04/2022 Date Of Pronouncement: 8 / 6 /2022 Order Per: Sandeep Gosain, J.M. The Captioned Appeal Has Been Filed By The Assessee Challenging The Impugned Order Dated 8Th October 2021, Passed By The Commissioner Of Income Tax (Appeals)–3, Nagpur, [In Short “The Learned Cit(A)”] Under Section 250 Of The Income Tax Act, 1961 (In Short "The Act") For The Assessment Year 2018-19. The Present Appeal Has Been Filed On The Following Grounds:- 2. “1. The Commissioner Of Income Tax (Appeals)-3, Nagpur Erred In Confirming Addition, Therefore Order Passed Is Illegal, Invalid & Bad In Law.

4. AnkitShankarlalTanwani Assessee 21,50,000/- The main contention of the department is that the assessee has shown the 12. abnormal amount of profit U/s. 44AD to explain the money found and seized from locker. In the written submission the department has further relied on statement recorded U/s. 131 of the Act. The contention of the departmental representative was that

M/S MAHESHWARI COAL BENEFICATION & INFRASTRUCTURE P LTD.,BILASPUR vs. ACIT CENTRAL CIRCLE 1(1), NAGPUR

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant Mmber

250 of the Income Tax Act, 1961 (“the Act”) by the learned Commissioner of Income Tax (Appeals)–3, Nagpur, [“learned CIT(A)”], for the assessment years 2014-15, 2015-16, 2016- 17, 2017-18, 2018-19, 2019-20 and 2020-21. 2 Maheshwari Coal Beneficatgion & Infrastructure Pvt. Ltd. A.Y. 2014–15 to 2020–21 2. A search and seizure action