M/S SHREE PALSIDDHA CONSTRUCTION,BULDHANA vs. PRINCIPAL C.I.T. -1,, NAGPUR

In the result, this appeal of the assessee is allowed

Bench: Shri Sandeep Gosain, Jm & Shri Arun Khodpia, Am Assessment Year: 2009-10 M/S Shree Palsiddha Construction Vs. Pr.Cit-1, Sakharkheda, Nagpur. Taluka Sindhkhedraja, Buldhana-443202. Pan No.: Ablfs 9009 H Appellant Respondent Assessee By: Shri Mahavir Atal (Ca) Revenue By : Shri Piyush Kolhe (Cit-Dr) Date Of Hearing: 28/04/2022 Date Of Pronouncement: 28 /06 /2022 Order Per: Sandeep Gosain, J.M. This Appeal Has Been Filed By The Assessee Against The Order Of The Ld. Pr.Cit-1, Nagpur Dated 08/03/2017 Passed U/S 263 Of The Income Tax Act, 1961 (In Short, The Act) For The A.Y. 2009-10 Wherein Following Grounds Have Been Raised By The Assessee: “1. On The Facts & Circumstances Of The Case, Ld. Pcit Erred In Assuming Jurisdiction U/S 263 & Thereby Setting Aside Order Passed By Assessing Officer 2. Assessee Craves Leave To Add & Alter Any Other Ground That May Be Taken At The Time Of Hearing.” 2. The Brief Facts Of The Case Are That The Assessee Is A Civil Contractor. Return Of Income Was Filed On 03/12/2009 Declaring Total Income Of 2

bogus purchases should be restricted only to gross profit, have been widely taken by the Judiciary across India. For sake of easy reference, we have enclosed the judgment of the Hon'ble Bombay High Court in the case of PCIT Vs Mohommad Haji Adam & Co (BOM)(HC) dated addition was restricted-to the Gross profit. 11/02/2019, where the (Said judgment

DY. C.I.T. CIR-.5, NAGPUR vs. M/S AVANTHA HOLDINGS LTD.,, CHANDRAPUR

In the result, appeal filed by the assessee is dismissed

bogus and inflated. Thus, the Id. CIT(A) allowed this expenditure in terms of provision of Section 30 of the I.T. Act. Taking into consideration the above facts and circumstances of the case, we find that the Department has not filed any supporting evidence/ rebuttal against the written submission Id. AR of the assessee except arguing that

AMARCHAND LAXMINARAYAN MANTRI,AMRAVATI vs. INCOME TAX OFFICER, WARD-3, AMRAVATI

In the result, appeal filed by the assessee for A

Bench: Shri V. Durga Rao

section 44AB of the Income Tax Act, 1961 ("the Act"). When demanded by the Assessing Officer, the assessee produced its books of account, bills & vouchers and the same were examined by the Assessing Officer on test check basis. On verification of Profit & Loss Account, it was noticed that the assessee had claimed brokerage and commission expenses to the tune

AMARCHAND LAXMINARAYAN MANTRI,AMRAVATI vs. INCOME TAX OFFICER, WARD-3, AMRAVATI

In the result, appeal filed by the assessee for A

Bench: Shri V. Durga Rao

section 44AB of the Income Tax Act, 1961 ("the Act"). When demanded by the Assessing Officer, the assessee produced its books of account, bills & vouchers and the same were examined by the Assessing Officer on test check basis. On verification of Profit & Loss Account, it was noticed that the assessee had claimed brokerage and commission expenses to the tune

M/S. UNIJULES LIFE SCIENCES LTD.,NAGPUR vs. ASSISTNAT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), NAGPUR

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.45/Nag/2023 िनधा"रण वष" / Assessment Year : 2012-13 M/S.Unijules Life Sciences The Assistant Ltd., V Commissioner Of Income B-35/36, Midc, S Tax, Central Circle-2(1), Kamleshwar, Nagpur. Nagpur – 441501 Pan: Aaacu8032D Appellant / Assessee Respondent / Revenue Assessee By Shri Kapil Hirani – Adv.-Ar Revenue By Shri Kailash C. Kanojiya – Cit-Dr Date Of Hearing 27/03/2024 Date Of Pronouncement 28/03/2024 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 Act, Dated 08.11.2011 For The A.Y.2012-13 Emanating From The Order Under Section 153A R.W.S 143(3) Of M/S.Unijule Life Sciences Ltd., [A]

40,535 representing disallowance of depreciation on purchase of assets allegedly held bogus which is illegal, and which deserves to be deleted as per law. 2 M/s.Unijule Life Sciences Ltd., [A] 8) On the facts and circumstances of the case and in law, the assessment being a case of unabated assessment, the additions to the extent not emanated from incriminating

ACIT-CENTRAL CIRCLE -2(1), NAGPUR vs. SHRI NANDKUMAR KHATTUMAL HARCHANDANI , NAGPUR

In the result, appeal of the Revenue stands dismissed

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

purchase and sale of shares, which is part of Paper book and also sent on remand. On 18.03.2011, the aforesaid share were sold for the Rs. 42,53,735/-. Demat account and Sale Note were produced. The loss incurred at Rs. 57,46,180/- was reflected in the ITR for A.Y. 2011- 12. At the same time, the assessee further

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.

purchase and sale transactions. Further, in case statements of CP were debatable, it was also recorded that Tribunal had not decided the ground of appeal that assessee had not filed certificate as per section 80HHC(4) and, therefore, was not eligible for deduction in the said section. Hence, matter remanded to Tribunal to examine all evidences in detail and decide

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.

purchase and sale transactions. Further, in case statements of CP were debatable, it was also recorded that Tribunal had not decided the ground of appeal that assessee had not filed certificate as per section 80HHC(4) and, therefore, was not eligible for deduction in the said section. Hence, matter remanded to Tribunal to examine all evidences in detail and decide

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.

purchase and sale transactions. Further, in case statements of CP were debatable, it was also recorded that Tribunal had not decided the ground of appeal that assessee had not filed certificate as per section 80HHC(4) and, therefore, was not eligible for deduction in the said section. Hence, matter remanded to Tribunal to examine all evidences in detail and decide

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.

purchase and sale transactions. Further, in case statements of CP were debatable, it was also recorded that Tribunal had not decided the ground of appeal that assessee had not filed certificate as per section 80HHC(4) and, therefore, was not eligible for deduction in the said section. Hence, matter remanded to Tribunal to examine all evidences in detail and decide

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.

purchase and sale transactions. Further, in case statements of CP were debatable, it was also recorded that Tribunal had not decided the ground of appeal that assessee had not filed certificate as per section 80HHC(4) and, therefore, was not eligible for deduction in the said section. Hence, matter remanded to Tribunal to examine all evidences in detail and decide

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.

purchase and sale transactions. Further, in case statements of CP were debatable, it was also recorded that Tribunal had not decided the ground of appeal that 15 ITA162/NAG/2021 SANTOSH CHANDUMAL TANWANI VS ACIT, C.C.2(1), NAGPUR assessee had not filed certificate as per section 80HHC(4) and, therefore, was not eligible for deduction in the said section. Hence, matter remanded

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.

purchase and sale transactions. Further, in case statements of CP were debatable, it was also recorded that Tribunal had not decided the ground of appeal that assessee had not filed certificate as per section 80HHC(4) and, therefore, was not eligible for deduction in the said section. Hence, matter remanded to Tribunal to examine all evidences in detail and decide

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.

purchase and sale transactions. Further, in case statements of CP were debatable, it was also recorded that Tribunal had not decided the ground of appeal that assessee had not filed certificate as per section 80HHC(4) and, therefore, was not eligible for deduction in the said section. Hence, matter remanded to Tribunal to examine all evidences in detail and decide

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.

purchase and sale transactions. Further, in case statements of CP were debatable, it was also recorded that Tribunal had not decided the ground of appeal that assessee had not filed certificate as per section 80HHC(4) and, therefore, was not eligible for deduction in the said section. Hence, matter remanded to Tribunal to examine all evidences in detail and decide

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.

purchase and sale transactions. Further, in case statements of CP were debatable, it was also recorded that Tribunal had not decided the ground of appeal that assessee had not filed certificate as per section 80HHC(4) and, therefore, was not eligible for deduction in the said section. Hence, matter remanded to Tribunal to examine all evidences in detail and decide

AVANTHA HOLDINGS LIMITED,NEW DELHI vs. A.C.I.T. CIR-5,, NAGPUR

In the result, appeal filed by the assessee is dismissed

bogus and inflated. Thus, the Id. CIT(A) allowed this expenditure in terms of provision of Section 30 of the I.T. Act. Taking into consideration the above facts and circumstances of the case, we find that the Department has not filed any supporting evidence/ rebuttal against the written submission Id. AR of the assessee except arguing that

ASSTT. C.I.T, CENTRAL CIR, -2(1), NAGPUR vs. M/S GUPTA COAL(INDIA) LTD, NAGPUR

In the result, cross objections No

Bench: Shri D. Karunakara Rao, Am & Shri Partha Sarathi Chaudhury, Jm

purchases and sales were bogus. Therefore, on the facts of case and in absence of displacing the finding of the CIT(A) and the fact that the assessee showed profit from these transactions, there is no such error in the order of the CIT(A) which requires correction. Respectfully following the above decisions, facts of the case and the evidence

ASSTT. C.I.T, CENTRAL CIR, -2(1), NAGPUR vs. M/S GUPTA COAL(INDIA) LTD, NAGPUR

In the result, cross objections No

Bench: Shri D. Karunakara Rao, Am & Shri Partha Sarathi Chaudhury, Jm

purchases and sales were bogus. Therefore, on the facts of case and in absence of displacing the finding of the CIT(A) and the fact that the assessee showed profit from these transactions, there is no such error in the order of the CIT(A) which requires correction. Respectfully following the above decisions, facts of the case and the evidence