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

iii) Demat account statement for the period of purchase and sale of shares iv) Share allotment letter on allotment of shares v) Contact notes of sale of shares 16 20. He submitted that the Ld. CIT(A) / NFAC did not consider the various documents including bank statements, share allotment letter, copy of demat account, bills, contract notes etc., in respect

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

III of\nthis submission, has\nclearly explained the\nbasis on which the\nshares were purchased\nby the accountant of the\nassessee's family.\nAdditionally,\nthe\nassessee has provided\nthe phone number and\nname of the sub-broker\nwhose advice was\nfollowed by the\naccountant in\npurchasing PFL shares.\nFurthermore, this is not\na case where the\nassessee invested a\nsubstantial

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

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

III of\nthis submission, has\nclearly explained the\nbasis on which the\nshares were purchased\nby the accountant of the\nassessee's family.\nAdditionally, the\nassessee has provided\nthe phone number and\nname of the sub-broker\nwhose advice was\nfollowed by the\naccountant in\npurchasing PFL shares.\nFurthermore, this is not\na case where the\nassessee invested a\nsubstantial

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

III of\nthis submission, has\nclearly explained the\nbasis on which the\nshares were purchased\nby the accountant of the\nassessee's family.\nAdditionally,\nthe\nassessee has provided\nthe phone number and\nname of the sub-broker\nwhose advice was\nfollowed by the\naccountant\nin\npurchasing PFL shares.\nFurthermore, this is not\na case where the\nassessee invested a\nsubstantial

SHRIKANT ANANTRAO ZORI,AURANGABAD vs. INCOME TAX OFFICER WARD 1(1) AURANGABAD , AURANGABAD

In the result, the appeal of the assessee is partly allowed

bogus. Without establishing the letter as\nnon- genuine or without examining the sanctity of the payment made simply\ninvoking the provisions of the Act for making addition is not appropriate for a\nquasi-judicial authority. The revenue should have verified and examined the\ngenuneness of the letter which was produced by the assessee wherein the\nemployer had stated that

DINESHKUMAR RAMCHANDRA TULSYAN (HUF),,NASHIK vs. INCOME-TAX OFFICER, WARD - 1(5),, NASHIK

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

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2014-15 Dineshkumar Ramchandra Tulsyan (Huf) Ito, Ward 1(5), 214B, Laxmi Niwas, Mahatma Nagar, Vs. Nashik Nashik – 422007 Pan: Aachd5953R (Appellant) (Respondent) Assessment Year : 2014-15 Smt. Sumandevi Dineshkumar Tulsyan Ito, Ward 1(5), 214B, Laxmi Niwas, Mahatma Nagar, Vs. Nashik Nashik – 422007 Pan: Ackpt1322Q (Appellant) (Respondent)

iii) ITO vs. Omprakash Asaram Mantri vide ITA Nos.140 & 141/PUN/2024 & other batch of appeals order dated 17.07.2025 iv) ACIT vs. Sidharth Ratanlal Bafna vide ITA Nos.1555, 1560, 1561 & 1565/PUN/2024 vide order dated 27.10.2025 26. Referring to the order of the SEBI, he submitted that SEBI vide order dated 05.10.2017 has revoked its earlier order dated 17.04.2015 which was the basis

INCOME TAX OFFICER, WARD-1, JALNA, JALNA vs. PRAMILA OMPRAKASH MANTRI, JALNA

In the result, all the appeals filed by the Revenue are dismissed

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

iii) Mr. Shiv Sundar Banka of Kolkata Copies of these statements are submitted at Page-64 onwards in Paper- Book. Perusal of these statements reveal that, nowhere, assessee has been named by these three brokers as any beneficiary of the alleged bogus LTCG. Yet, the I-T department has relied upon these statements for taxing the exempt LTCG as bogus

INCOME TAX OFFICER, WARD -1, JALNA, JALNA vs. PRAMILA OMPRAKASH MANTRI, JALNA

In the result, all the appeals filed by the Revenue are dismissed

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

iii) Mr. Shiv Sundar Banka of Kolkata Copies of these statements are submitted at Page-64 onwards in Paper- Book. Perusal of these statements reveal that, nowhere, assessee has been named by these three brokers as any beneficiary of the alleged bogus LTCG. Yet, the I-T department has relied upon these statements for taxing the exempt LTCG as bogus

INCOME TAX OFFICER, WARD-1, JALNA, JALNA vs. ATUL OMPRAKASH MANTRI, JALNA

In the result, all the appeals filed by the Revenue are dismissed

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

iii) Mr. Shiv Sundar Banka of Kolkata Copies of these statements are submitted at Page-64 onwards in Paper- Book. Perusal of these statements reveal that, nowhere, assessee has been named by these three brokers as any beneficiary of the alleged bogus LTCG. Yet, the I-T department has relied upon these statements for taxing the exempt LTCG as bogus

INCOME TAX OFFICER, WARD-1, JALNA, JALNA vs. ATUL OMPRAKASH MANTRI, JALNA

In the result, all the appeals filed by the Revenue are dismissed

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

iii) Mr. Shiv Sundar Banka of Kolkata Copies of these statements are submitted at Page-64 onwards in Paper- Book. Perusal of these statements reveal that, nowhere, assessee has been named by these three brokers as any beneficiary of the alleged bogus LTCG. Yet, the I-T department has relied upon these statements for taxing the exempt LTCG as bogus

INCOME TAX OFFICER, WARD-1, JALNA, JALNA vs. OMPRAKASH ASARAM MANTRI, JALNA

In the result, all the appeals filed by the Revenue are dismissed

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

iii) Mr. Shiv Sundar Banka of Kolkata Copies of these statements are submitted at Page-64 onwards in Paper- Book. Perusal of these statements reveal that, nowhere, assessee has been named by these three brokers as any beneficiary of the alleged bogus LTCG. Yet, the I-T department has relied upon these statements for taxing the exempt LTCG as bogus