DEPUTY COMMISSIONER OF INCOME, AURANGABAD vs. METAROLLS ISPAT PVT. LTD, JALNA

In the result, both the appeals filed by the Revenue are partly allowed

36,451\nTotal\n17,49,83,488\n3,14,97,032\n20,64,80,520\n19. However, we find the Assessing Officer in the impugned assessment order,\nhas made the entire addition of bogus / untested purchases and these orders of the\nAssessing Officer passed u/s 143(3) / 147 were passed after the order of the Ld.\nCIT(A). Although

DEPUTY COMMISSIONER OF INCOME TAX, AURANGABAD vs. METAROLLS ISPAT PVT. LTD., JALNA

In the result, both the appeals filed by the Revenue are partly allowed

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

36,451 Total 17,49,83,488 3,14,97,032 20,64,80,520 19. However, we find the Assessing Officer in the impugned assessment order, has made the entire addition of bogus / untested purchases and these orders of the Assessing Officer passed u/s 143(3) / 147 were passed after the order of the Ld. CIT(A). Although

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

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

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 u/s 270A(9) of misreporting of income is being initiated. Section 37. General-(1) Any expenditure (not being expenditure of the nature described in sections 30 to 36

DCIT-CIRCLE 7 PUNE, BODHI TOWER SALISBURY PARK PUNE vs. TRIO CHEMSUCROTECH ENG. PROJECTS PVT. LTD, PUNE

purchases and expenses were pending to be received even till 31.03.2010, the provisioning made was not accepted and added back to the income, After making the above two additions, the income of the assessee was assessed at Rs.30,94,50,800/-.\n6. Aggrieved assessee preferred appeal before the ld.CIT(A). During the course of appellate proceedings, assessee along with making

INCOME TAX OFFICER, WARD 7(1), PUNE, PUNE vs. ANIL JAIRAM GOEL, PUNE

In the result, the appeal filed by the Revenue in ITA

Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

section 68 and 69C of the Act. 4. Whether on the facts and circumstances of the case and in law, when the appellate authority has categorically found that the alleged purchases are bogus in nature, the Ld. CIT (A) has erred in restricting the profit margin to 12.5%. 5. The appellant craves leave to add, amend or alter any grounds

INCOME TAX OFFICER, PUNE vs. ANIL JAIRAM GOEL, PUNE

In the result, the appeal filed by the Revenue in ITA

Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

section 68 and 69C of the Act. 4. Whether on the facts and circumstances of the case and in law, when the appellate authority has categorically found that the alleged purchases are bogus in nature, the Ld. CIT (A) has erred in restricting the profit margin to 12.5%. 5. The appellant craves leave to add, amend or alter any grounds

DEPUTY COMMISSIONER OF INCOME TAX, AURANGABAD vs. SURYACHANDRA LALMANI DUBEY, AURANGABAD

In the result, appeal of the Revenue is allowed

Bench: SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND DR.DIPAK P. RIPOTE (Accountant Member)

36,903/-. Therefore, it is evident that M/s Brahma Steels has shown bogus purchases to the tune of Rs.36,56,250/- and suppressed the gross profit for the year under consideration………………… Therefore, 1 have reasons to believe that for A.Y. 2014-15, income to the tune of Rs.36,56,250/-has escaped assessment within the meaning of Section

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(2), PUNE vs. M/S. BILCARE LIMITED, PUNE

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपीऱ सं. / Ita No.273/Pun/2021 निर्धारण वर्ा / Assessment Year: 2016-17 Dcit, Central Circle-2(2), Vs. M/S. Bilcare Limited, Pune. 601, Icc Trade Tower, Pune- 411016. Pan : Aabcb2242F Appellant Respondent आयकर अपीऱ सं. / Ita No.334/Pun/2021 निर्धारण वर्ा / Assessment Year: 2016-17 M/S. Bilcare Limited, Vs. Dcit, Central Circle- 6Th Floor, B Wing, Icc 2(2), Pune. Trade Tower, Senapati Bapat Road, Pune- 411006. Pan : Aabcb2242F Appellant Respondent

36. The Revenue raised the following grounds of appeal :- ―1) Whether on the facts and circumstances of the case, the LdCIT(A) is justified in considering Performance Guarantee and Corporate Guarantee separately ? 2) Whether on the facts and circumstances of the case, the LdCIT(A) is justified in directing TPO to adopt Internal TNMM as most appropriate method for benchmarking

M/S. BILCARE LIMITED,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(2), PUNE

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपीऱ सं. / Ita No.273/Pun/2021 निर्धारण वर्ा / Assessment Year: 2016-17 Dcit, Central Circle-2(2), Vs. M/S. Bilcare Limited, Pune. 601, Icc Trade Tower, Pune- 411016. Pan : Aabcb2242F Appellant Respondent आयकर अपीऱ सं. / Ita No.334/Pun/2021 निर्धारण वर्ा / Assessment Year: 2016-17 M/S. Bilcare Limited, Vs. Dcit, Central Circle- 6Th Floor, B Wing, Icc 2(2), Pune. Trade Tower, Senapati Bapat Road, Pune- 411006. Pan : Aabcb2242F Appellant Respondent

36. The Revenue raised the following grounds of appeal :- ―1) Whether on the facts and circumstances of the case, the LdCIT(A) is justified in considering Performance Guarantee and Corporate Guarantee separately ? 2) Whether on the facts and circumstances of the case, the LdCIT(A) is justified in directing TPO to adopt Internal TNMM as most appropriate method for benchmarking

HETAL RAKESH MEHTA ,MUMBAI vs. ACIT, CC-1(2), PUNE

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2018-19 Hetal Rakesh Mehta Acit, Central Circle 1(2), 9/10, Vidya Nagar, 60 Feet Road, Vs. Pune Ghatkopar East, Mumbai – 400077 Pan: Ammpm9670L (Appellant) (Respondent)

36,791/- made in the assessment order passed by the Assessing Officer u/s 143(3) r.w.s 153A of the Income Tax Act, 1961 on 30.09.2021 on account of alleged commission income @1% of sales from providing alleged accommodation entry to BVG India Limited disregarding the materials / evidence placed on record in support of the genuineness of transactions and without appreciating

SHRI MANOJ MADANLAL CHHAJED,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE -1(1)PUNE, PUNE

In the result, the appeal filed by the assessee in ITA

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपील सं. / It(Ss)A Nos.91 To 96/Pun/2022 िनधा"रण वष" / Assessment Years : 2012-13 To 2017-18 Shri Manoj Madanlal Vs. Acit, Central Circle- Chhajed, 1(1), Pune. 601, A-8 Building, Karishma Housing Society, Near Sangam Press, Kothrud, Pune- 411029. Pan : Aalpc4991M Appellant Respondent आयकर अपील सं. / It(Ss)A Nos.97 & 98/Pun/2022 िनधा"रण वष" / Assessment Years : 2012-13 & 2015-16 Acit, Circle-1(1), Pune. Vs. Shri Manoj Madanlal Chhajed, 601, A-8 Building, Karishma Housing Society, Near Sangam Press, Kothrud, Pune- 411029. Pan : Aalpc4991M Appellant Respondent आयकर अपील सं. / Ita No.725/Pun/2022 िनधा"रण वष" / Assessment Year: 2018-19 Shri Manoj Madanlal Vs. Acit, Circle-1(1), Pune. Chhajed, 601, A-8 Building, Karishma Housing Society, Near Sangam Press, Kothrud, Pune- 411029. Pan : Aalpc4991M Appellant Respondent

36,710 1,00,00,000 2015-16 24/01/2019 22,27,420 NIL 2016-17 24/01/2019 1,46,95,030 1,00,00,000 2017-18 24/01/2019 1,75,91,360 1,00,00,000 6 IT(SS)A Nos.91 to 96/PUN/2022 IT(SS)A Nos.97 & 98/PUN/2022 2018-19 - - NIL 5. Subsequently, the Assessing Officer had proceeded to frame

JAIBHAGWAN BANARASIDAS JINDAL,JALNA vs. THE INCOME TAX OFFICER, WARD-1, JALNA

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2016-17

1 but that does not help the revenue in as much as the facts in that case were entirely different. 5. In our view, the Tribunal has not committed any perversity or applied incorrect principles to the given facts and when the facts and circumstances are properly analysed and correct test is applied to decide the issue at hand, then

ASSISTANT COMMISSIONER OF INCOME TAX, JALGAON vs. SIDHARTH RATANLAL BAFNA, JALGAON

bogus. If the purchase and sale of shares are reflected\nin the Assessee's DMAT account, yet they are termed as arranged transactions\nand projected to be real, then, such conclusion which has been reached by the\nCommissioner and the Assessing Officer required a deeper scrutiny. It was also\nrevealed during the course of inquiry by the Assessing Officer that

DEPUTY COMMISSIONER OF INCOME TAX, JALGAON vs. TARADEVI RATANLAL BAFNA, JALGAON

bogus. If the purchase and sale of shares are reflected\nin the Assessee's DMAT account, yet they are termed as arranged transactions\nand projected to be real, then, such conclusion which has been reached by the\nCommissioner and the Assessing Officer required a deeper scrutiny. It was also\nrevealed during the course of inquiry by the Assessing Officer that

ASSISTANT COMMISSIONER OF INCOME TAX, JALGAON vs. SIDHARTH RATANLAL BAFNA, JALGAON

bogus. If the purchase and sale of shares are reflected\nin the Assessee's DMAT account, yet they are termed as arranged transactions\nand projected to be real, then, such conclusion which has been reached by the\nCommissioner and the Assessing Officer required a deeper scrutiny. It was also\nrevealed during the course of inquiry by the Assessing Officer that

HAMAJA MOHAMMED MALPEKAR,RATNAGIRI vs. INCOME TAX OFFICER, RATNAGIRI WARD, RATNAGIRI

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

36,192/-. Out of which 1,77,96,343/- was seen to be secured loans from banks and Rs.88,39,849/- out of the unsecured loans. The assessee is seen to have repaid most of the loans, however, availed a new loan of Rs.2,00,000/- from Mr. Hanif H. Malpekar. Thus showing the closing balance for unsecured loan outstanding

ASSISTANT COMMISSIONER OF INCOME TAX, CIRLE 1, KOLHAPUR, KOLHAPUR vs. HAMAJA MOHAMMED MALPEKAR, MAHARASHTRA

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

36,192/-. Out of which 1,77,96,343/- was seen to be secured loans from banks and Rs.88,39,849/- out of the unsecured loans. The assessee is seen to have repaid most of the loans, however, availed a new loan of Rs.2,00,000/- from Mr. Hanif H. Malpekar. Thus showing the closing balance for unsecured loan outstanding

AADHUNIK INFRASTRUCTURE DEVELOPMENT PRIVATE LIMITED,JALGAON vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, JALGAON

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

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2012-13

bogus purchase by assessee received by DRI from CCE which was passed on to revenue authorities was 'tangible material outside record to initiate valid reassessment proceedings. Thus there was no borrowed satisfaction on the part of the AO. There was independent application of mind on the part of the AO. Further reliance is placed upon clause (b) of explanation