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58 results for “bogus purchases”+ Section 145(3)clear

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Key Topics

Addition to Income43Section 143(3)42Section 14829Section 92C(3)24Search & Seizure23Disallowance23Section 153A21Section 145(3)20Section 143(2)18Section 40A(3)

DY COMMISSIONER OF INCOME TAX, SATARA vs. KAY BOUVET ENGINEERING LIMITED, SATARA

In the result, both the appeals filed by the Revenue and both the COs filed\nby the assessee are dismissed

ITA 1374/PUN/2025[2018-19]Status: DisposedITAT Pune16 Dec 2025AY 2018-19
Section 131Section 133ASection 143(1)(a)Section 143(3)Section 148

145 taxmann.com 546 (Bombay)]\n(iv) Principal Commissioner of Income-tax v. Shapoorji Pallonji & Co.\nLtd [2020] 117 taxmann.com 625 (Bombay)\n(v) Principal Commissioner of Income-tax v. Jagdish Thakkar [2022]\n145 taxmann.com 414 (Bombay)\n(vi) Principal Commissioner of Income-tax, Mumbai v. Chawla Interbild\nConstruction Co. (P.) Ltd [2019] 104 taxmann.com 402 (Bombay)\n(vii) Pr. Commissioner

M/S. SAVA HEALTHCARE LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX,, PUNE

In the result, 70% of world profits are added in the hands of assessee under guise of Profit Split Method

Showing 1–20 of 58 · Page 1 of 3

17
Section 133(6)16
Survey u/s 133A13
ITA 1065/PUN/2017[2010-11]Status: DisposedITAT Pune27 Jun 2019AY 2010-11

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.1062 To 1068/Pun/2017 यििाारण वषा / Assessment Years : 2007-08 To 2013-14

For Appellant: Shri Kishore PhadkeFor Respondent: Ms Nandita Kanchan
Section 143(3)Section 144CSection 144C(8)Section 92C(3)

bogus; when no authority to such effect existed with the learned TPO. The learned DRP erred in not deleting the entire addition proposed by the learned TPO on the above analogy as such and further erred in not proceeding with the matter instead of leaving the matter at that point, considering the scope of powers u/s 144C

M/S. SAVA HEALTHCARE LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX,, PUNE

In the result, 70% of world profits are added in the hands of assessee under guise of Profit Split Method

ITA 1063/PUN/2017[2008-09]Status: DisposedITAT Pune27 Jun 2019AY 2008-09

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.1062 To 1068/Pun/2017 यििाारण वषा / Assessment Years : 2007-08 To 2013-14

For Appellant: Shri Kishore PhadkeFor Respondent: Ms Nandita Kanchan
Section 143(3)Section 144CSection 144C(8)Section 92C(3)

bogus; when no authority to such effect existed with the learned TPO. The learned DRP erred in not deleting the entire addition proposed by the learned TPO on the above analogy as such and further erred in not proceeding with the matter instead of leaving the matter at that point, considering the scope of powers u/s 144C

M/S. SAVA HEALTHCARE LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX,, PUNE

In the result, 70% of world profits are added in the hands of assessee under guise of Profit Split Method

ITA 1066/PUN/2017[2011-12]Status: DisposedITAT Pune27 Jun 2019AY 2011-12

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.1062 To 1068/Pun/2017 यििाारण वषा / Assessment Years : 2007-08 To 2013-14

For Appellant: Shri Kishore PhadkeFor Respondent: Ms Nandita Kanchan
Section 143(3)Section 144CSection 144C(8)Section 92C(3)

bogus; when no authority to such effect existed with the learned TPO. The learned DRP erred in not deleting the entire addition proposed by the learned TPO on the above analogy as such and further erred in not proceeding with the matter instead of leaving the matter at that point, considering the scope of powers u/s 144C

M/S. SAVA HEALTHCARE LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX,, PUNE

In the result, 70% of world profits are added in the hands of assessee under guise of Profit Split Method

ITA 1062/PUN/2017[2007-08]Status: DisposedITAT Pune27 Jun 2019AY 2007-08

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.1062 To 1068/Pun/2017 यििाारण वषा / Assessment Years : 2007-08 To 2013-14

For Appellant: Shri Kishore PhadkeFor Respondent: Ms Nandita Kanchan
Section 143(3)Section 144CSection 144C(8)Section 92C(3)

bogus; when no authority to such effect existed with the learned TPO. The learned DRP erred in not deleting the entire addition proposed by the learned TPO on the above analogy as such and further erred in not proceeding with the matter instead of leaving the matter at that point, considering the scope of powers u/s 144C

M/S. SAVA HEALTHCARE LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX,, PUNE

In the result, 70% of world profits are added in the hands of assessee under guise of Profit Split Method

ITA 1067/PUN/2017[2012-13]Status: DisposedITAT Pune27 Jun 2019AY 2012-13

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.1062 To 1068/Pun/2017 यििाारण वषा / Assessment Years : 2007-08 To 2013-14

For Appellant: Shri Kishore PhadkeFor Respondent: Ms Nandita Kanchan
Section 143(3)Section 144CSection 144C(8)Section 92C(3)

bogus; when no authority to such effect existed with the learned TPO. The learned DRP erred in not deleting the entire addition proposed by the learned TPO on the above analogy as such and further erred in not proceeding with the matter instead of leaving the matter at that point, considering the scope of powers u/s 144C

M/S. SAVA HEALTHCARE LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX,, PUNE

In the result, 70% of world profits are added in the hands of assessee under guise of Profit Split Method

ITA 1064/PUN/2017[2009-10]Status: DisposedITAT Pune27 Jun 2019AY 2009-10

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.1062 To 1068/Pun/2017 यििाारण वषा / Assessment Years : 2007-08 To 2013-14

For Appellant: Shri Kishore PhadkeFor Respondent: Ms Nandita Kanchan
Section 143(3)Section 144CSection 144C(8)Section 92C(3)

bogus; when no authority to such effect existed with the learned TPO. The learned DRP erred in not deleting the entire addition proposed by the learned TPO on the above analogy as such and further erred in not proceeding with the matter instead of leaving the matter at that point, considering the scope of powers u/s 144C

ASSISTANT COMMISSIONER OF INCOME TAX, KOLHAPUR vs. NATHMAL RUPCHAND JAIN, KOLHAPUR

In the result, the appeal filed by the Revenue is dismissed

ITA 1295/PUN/2024[2020-21]Status: DisposedITAT Pune27 Jan 2025AY 2020-21

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2020-21

For Appellant: Shri Suhas P BoraFor Respondent: Shri Amol Khairnar CIT-DR
Section 132Section 133(6)Section 143(2)Section 145(3)Section 69A

purchases made by the assessee to the tune of Rs.2,24,40,000/- are bogus, the Assessing Officer rejected the books of account by applying the provisions of section 145(3

INCOME TAX OFFICER, PUNE vs. COOPERATION METALS, PUNE

In the result, the appeals filed by the assessee are partly allowed and the appeals filed by the Revenue are dismissed

ITA 2263/PUN/2024[2011-12]Status: DisposedITAT Pune21 Apr 2026AY 2011-12

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Madhan Thirmanpalli, Addl. CIT
Section 131Section 133ASection 143(1)Section 143(2)Section 143(3)Section 147

145 taxmann.com 546. 4. The learned CIT(A), NFAC erred in law and on facts in assessing the gross profit margin (GPM) of the appellant at 18% on alleged HAWALA purchases instead of a reasonable lower plausible GPM. Appellant contends that, in business of trading of goods and assuming, such huge 18% GPM on alleged HAWALA Purchases is abnormal

CO-OPERATION METALS,PUNE vs. ITO WARD 6(3), PUNE

In the result, the appeals filed by the assessee are partly allowed and the appeals filed by the Revenue are dismissed

ITA 2319/PUN/2024[2009-10]Status: DisposedITAT Pune21 Apr 2026AY 2009-10

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Madhan Thirmanpalli, Addl. CIT
Section 131Section 133ASection 143(1)Section 143(2)Section 143(3)Section 147

145 taxmann.com 546. 4. The learned CIT(A), NFAC erred in law and on facts in assessing the gross profit margin (GPM) of the appellant at 18% on alleged HAWALA purchases instead of a reasonable lower plausible GPM. Appellant contends that, in business of trading of goods and assuming, such huge 18% GPM on alleged HAWALA Purchases is abnormal

CO-OPERATION METALS,PUNE vs. ITO WARD 6(3), PUNE

In the result, the appeals filed by the assessee are partly allowed and the appeals filed by the Revenue are dismissed

ITA 2320/PUN/2024[2011-12]Status: DisposedITAT Pune21 Apr 2026AY 2011-12

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Madhan Thirmanpalli, Addl. CIT
Section 131Section 133ASection 143(1)Section 143(2)Section 143(3)Section 147

145 taxmann.com 546. 4. The learned CIT(A), NFAC erred in law and on facts in assessing the gross profit margin (GPM) of the appellant at 18% on alleged HAWALA purchases instead of a reasonable lower plausible GPM. Appellant contends that, in business of trading of goods and assuming, such huge 18% GPM on alleged HAWALA Purchases is abnormal

INCOME TAX OFFICER, PUNE vs. COOPERATION METALS, PUNE

In the result, the appeals filed by the assessee are partly allowed and the appeals filed by the Revenue are dismissed

ITA 2262/PUN/2024[2009-10]Status: DisposedITAT Pune21 Apr 2026AY 2009-10

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Madhan Thirmanpalli, Addl. CIT
Section 131Section 133ASection 143(1)Section 143(2)Section 143(3)Section 147

145 taxmann.com 546. 4. The learned CIT(A), NFAC erred in law and on facts in assessing the gross profit margin (GPM) of the appellant at 18% on alleged HAWALA purchases instead of a reasonable lower plausible GPM. Appellant contends that, in business of trading of goods and assuming, such huge 18% GPM on alleged HAWALA Purchases is abnormal

CO-OPERATION METALS,PUNE vs. ITO WARD 6(3), PUNE

In the result, the appeals filed by the assessee are partly allowed and the appeals filed by the Revenue are dismissed

ITA 2321/PUN/2024[2010-11]Status: DisposedITAT Pune21 Apr 2026AY 2010-11

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Madhan Thirmanpalli, Addl. CIT
Section 131Section 133ASection 143(1)Section 143(2)Section 143(3)Section 147

145 taxmann.com 546. 4. The learned CIT(A), NFAC erred in law and on facts in assessing the gross profit margin (GPM) of the appellant at 18% on alleged HAWALA purchases instead of a reasonable lower plausible GPM. Appellant contends that, in business of trading of goods and assuming, such huge 18% GPM on alleged HAWALA Purchases is abnormal

INCOME TAX OFFICER, PUNE vs. COOPERATION METALS, PUNE

In the result, the appeals filed by the assessee are partly allowed and the appeals filed by the Revenue are dismissed

ITA 2271/PUN/2024[2010-11]Status: DisposedITAT Pune21 Apr 2026AY 2010-11

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Madhan Thirmanpalli, Addl. CIT
Section 131Section 133ASection 143(1)Section 143(2)Section 143(3)Section 147

145 taxmann.com 546. 4. The learned CIT(A), NFAC erred in law and on facts in assessing the gross profit margin (GPM) of the appellant at 18% on alleged HAWALA purchases instead of a reasonable lower plausible GPM. Appellant contends that, in business of trading of goods and assuming, such huge 18% GPM on alleged HAWALA Purchases is abnormal

ITO, WARD-1(1), SOLAPUR, SOLAPUR vs. MS. KSHIRSAGAR FABRICS, SOLAPUR

In the result, the appeal filed by the Revenue is dismissed

ITA 97/PUN/2024[2009-10]Status: DisposedITAT Pune17 Sept 2024AY 2009-10

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2009-10

For Appellant: Shri Nikhil PathakFor Respondent: Shri Sourabh Nayak, Addl. CIT
Section 143(3)Section 147Section 148Section 40A(3)

145 taxmann.com 228 (Bom), he submitted that the Hon’ble High Court in the said decision has held that when initially Assessing Officer had not accepted audit objection that as assessee was not satisfying condition of an industrial undertaking as prescribed under section 72A, set-off of brought forward losses on amalgamating company on amalgamation with assessee

ACIT, CIRCLE-1, NASHIK, NASHIK vs. TAPARIA TOOLS LIMITED, NASHIK

In the result, both the appeal of the Revenue as well as Cross Objection of the assessee are allowed for statistical purposes as per the terms indicated above

ITA 1337/PUN/2025[2017-18]Status: DisposedITAT Pune10 Dec 2025AY 2017-18

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1337/Pun/2025 Assessment Year : 2017-18

For Appellant: Shri Amit BobdeFor Respondent: Shri Viral Shah
Section 142(1)Section 147Section 148Section 37(1)

3) etc. Thus, in the fitness of things, purchases as such are being disallowed in this case is completely justified. 6.5. Thus, in the case under hands, an addition on account of bogus purchases amounting to Rs.87,64,74,079/-is being made u/s 37(1) of the Act, and added to the total income of the assessee. Penalty

R. K. WINES,PEN vs. ITO, WARD 4, PANVEL, PANVEL

In the result, appeal of the assessee is partly allowed

ITA 301/PUN/2025[2022-23]Status: DisposedITAT Pune29 May 2025AY 2022-23
Section 133(6)Section 145(3)Section 250

bogus purchases from the disputed\ncreditors. It is thus the case that without such purchases the subsequent\nsale of liquor could not have been effected.\nThe appellant submits that non responding by some parties to notice us\n133(6) cannot be a ground to reject book results u/s 145(3) Reliance\nplaced on CIT-vs-Jas Jack Elegance Exports

DCIT, CIRCLE-5, PUNE vs. SHRI PURUSHOTTAM R MOGHE, PUNE

ITA 66/PUN/2021[2006-07]Status: DisposedITAT Pune09 Oct 2023AY 2006-07

Bench: Shri Satbeer Singh Godara & Shri Gd Padmahshali

For Appellant: Shri Sharad A VazeFor Respondent: Shri Keyur Patel, CIT-DR with Shri Ramnath P Murkunde, Sr. AR
Section 148Section 40A(3)

bogus sale purchase transactions with many other parties involving these twin assessees. We further note from a combined perusal of all these case files with the able assistance coming from both the learned representatives that the Assessing Officer(s) three re-assessments herein treated their respective trading business turnovers as bougs; being 3 ITA.Nos.72, 73 & 66/PUN./2021 And ITA.Nos

DCIT, CIRCLE-5, PUNE vs. SHRI PURUSHOTTAM R MOGHE, PUNE

ITA 73/PUN/2021[2005-06]Status: DisposedITAT Pune09 Oct 2023AY 2005-06

Bench: Shri Satbeer Singh Godara & Shri Gd Padmahshali

For Appellant: Shri Sharad A VazeFor Respondent: Shri Keyur Patel, CIT-DR with Shri Ramnath P Murkunde, Sr. AR
Section 148Section 40A(3)

bogus sale purchase transactions with many other parties involving these twin assessees. We further note from a combined perusal of all these case files with the able assistance coming from both the learned representatives that the Assessing Officer(s) three re-assessments herein treated their respective trading business turnovers as bougs; being 3 ITA.Nos.72, 73 & 66/PUN./2021 And ITA.Nos

DCIT CIRCLE- 5, PUNE vs. SAILAB MARKETING SERVICES PVT. LTD., PUNE

ITA 72/PUN/2021[2005-06]Status: DisposedITAT Pune09 Oct 2023AY 2005-06

Bench: Shri Satbeer Singh Godara & Shri Gd Padmahshali

For Appellant: Shri Sharad A VazeFor Respondent: Shri Keyur Patel, CIT-DR with Shri Ramnath P Murkunde, Sr. AR
Section 148Section 40A(3)

bogus sale purchase transactions with many other parties involving these twin assessees. We further note from a combined perusal of all these case files with the able assistance coming from both the learned representatives that the Assessing Officer(s) three re-assessments herein treated their respective trading business turnovers as bougs; being 3 ITA.Nos.72, 73 & 66/PUN./2021 And ITA.Nos