DCIT(CENTRAL)-1, RAIPUR vs. KALMESH KUMAR KESHARWANI, RAIPUR

In the result, appeal filed by the assessee in ITA No

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos.122, 123 & 124/Rpr/2024 "नधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 Kamlesh Kumar Kesharwani 112, Janta Colony, Gudhiyari, Raipur (C.G.)-492 001 Pan: Aewpk6876Q .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax-1(1), Raipur (C.G.) ……""यथ" / Respondent आयकर अपील सं. / Ita Nos.135, 136 & 138/Rpr/2024 "नधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 The Deputy Commissioner Of Income Tax-(Central)-1, Raipur (C.G.)

12,76,610/- i.e. 143295 Qntls. of paddy/rice/broken rice made during the subject year. The Ld. AR on being called upon to fortify his aforesaid claim had taken us through the synopsis filed by him dated 28.10.2024. The Ld. AR on being called upon to substantiate the veracity of the aforesaid facts and figures as was canvassed before

KAMLESH KUMAR KESHARWANI,RAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX-1(1), RAIPUR, RAIPUR

In the result, appeal filed by the assessee in ITA No

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos.122, 123 & 124/Rpr/2024 "नधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 Kamlesh Kumar Kesharwani 112, Janta Colony, Gudhiyari, Raipur (C.G.)-492 001 Pan: Aewpk6876Q .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax-1(1), Raipur (C.G.) ……""यथ" / Respondent आयकर अपील सं. / Ita Nos.135, 136 & 138/Rpr/2024 "नधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 The Deputy Commissioner Of Income Tax-(Central)-1, Raipur (C.G.)

12,76,610/- i.e. 143295 Qntls. of paddy/rice/broken rice made during the subject year. The Ld. AR on being called upon to fortify his aforesaid claim had taken us through the synopsis filed by him dated 28.10.2024. The Ld. AR on being called upon to substantiate the veracity of the aforesaid facts and figures as was canvassed before

KAMLESH KUMAR KESHARWANI,RAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX-1(1), RAIPUR, RAIPUR

In the result, appeal filed by the assessee in ITA No

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos.122, 123 & 124/Rpr/2024 "नधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 Kamlesh Kumar Kesharwani 112, Janta Colony, Gudhiyari, Raipur (C.G.)-492 001 Pan: Aewpk6876Q .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax-1(1), Raipur (C.G.) ……""यथ" / Respondent आयकर अपील सं. / Ita Nos.135, 136 & 138/Rpr/2024 "नधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 The Deputy Commissioner Of Income Tax-(Central)-1, Raipur (C.G.)

12,76,610/- i.e. 143295 Qntls. of paddy/rice/broken rice made during the subject year. The Ld. AR on being called upon to fortify his aforesaid claim had taken us through the synopsis filed by him dated 28.10.2024. The Ld. AR on being called upon to substantiate the veracity of the aforesaid facts and figures as was canvassed before

DCIT(CENTRAL)-1,RAIPUR, RAIPUR vs. KALMESH KUMAR KESHARWANI, RAIPUR

In the result, appeal filed by the assessee in ITA No

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos.122, 123 & 124/Rpr/2024 "नधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 Kamlesh Kumar Kesharwani 112, Janta Colony, Gudhiyari, Raipur (C.G.)-492 001 Pan: Aewpk6876Q .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax-1(1), Raipur (C.G.) ……""यथ" / Respondent आयकर अपील सं. / Ita Nos.135, 136 & 138/Rpr/2024 "नधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 The Deputy Commissioner Of Income Tax-(Central)-1, Raipur (C.G.)

12,76,610/- i.e. 143295 Qntls. of paddy/rice/broken rice made during the subject year. The Ld. AR on being called upon to fortify his aforesaid claim had taken us through the synopsis filed by him dated 28.10.2024. The Ld. AR on being called upon to substantiate the veracity of the aforesaid facts and figures as was canvassed before

KAMLESH KUMAR KESHARWANI,RAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX-1(1), RAIPUR, RAIPUR

In the result, appeal filed by the assessee in ITA No

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos.122, 123 & 124/Rpr/2024 "नधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 Kamlesh Kumar Kesharwani 112, Janta Colony, Gudhiyari, Raipur (C.G.)-492 001 Pan: Aewpk6876Q .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax-1(1), Raipur (C.G.) ……""यथ" / Respondent आयकर अपील सं. / Ita Nos.135, 136 & 138/Rpr/2024 "नधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 The Deputy Commissioner Of Income Tax-(Central)-1, Raipur (C.G.)

12,76,610/- i.e. 143295 Qntls. of paddy/rice/broken rice made during the subject year. The Ld. AR on being called upon to fortify his aforesaid claim had taken us through the synopsis filed by him dated 28.10.2024. The Ld. AR on being called upon to substantiate the veracity of the aforesaid facts and figures as was canvassed before

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 1(1), RAIPUR vs. MESERS BHAGWATI INDUSTRIES, RAIPUR

In the result, appeal of the revenue is partly allowed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.184/Rpr/2019 "नधा"रण वष" / Assessment Year : 2013-14 The Assistant Commissioner Of Income Tax, Circle-1(1), Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. Bhagawati Industries Behind Samrat Talkies, Station Road, Raipur-492 001 (C.G.) Pan : Aaifk4253H ……""यथ" / Respondent

section 69C on the basis of GP ratio is unjustified?" 7. Whether on points of law and on points of facts & circumstances of the case, the Ld. CIT(A) having concurrent powers of the AO u/s 250(4) of the Act, was justified in deleting the addition of Rs. 48,46,852/- out of total addition made

DEPUTY COMMISSIONER OF INCOME TAX-1(1), RAIPUR vs. SHANTA TECHNO PRIVATE LIMITED, RAIPUR

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 155/Rpr/2025 (िनधा"रण वष" Assessment Year: 2018-19)

12. In sum and substance, being the final fact-finding authority, we are of the considered opinion that in instant matters, the assessee squarely failed in discharging the onus regarding bogus purchases transacted by it and claimed as expenditure. Ld. AO elaborated the facts and surfaced that the assessee was involved in bogus purchases transactions, however, there was gross failure

DEPUTY COMMISSIONER OF INCOME TAX, 1(1), RAIPUR vs. MESERS P.D. RICE UDYOG,, RAIPUR

In the result, appeal of the assessee is disposed off in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.210/Rpr/2018 "नधा"रण वष" / Assessment Year : 2013-14 M/S. P.D Rice Udyog Samrat Talkies, Station Road, Raipur (C.G.)-492 001 Pan: Aadfp0368H .......अपीलाथ" / Appellant बनाम / V/S. The Deputy Commissioner Of Income Tax-1(1), Raipur (C.G.) ……""यथ" / Respondent आयकर अपील सं. / Ita No.11/Rpr/2019 "नधा"रण वष" / Assessment Year : 2013-14 The Deputy Commissioner Of Income Tax-1(1), Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. P.D Rice Udyog Samrat Talkies, Station Road, Raipur (C.G.)-492 001 Pan: Aadfp0368H

purchased by it nor it could ensure presence of supplier, the addition under section 69C on the basis of GP ratio is unjustified?" 7. Whether on points of law and on points of facts & circumstances of the case, the Ld. CIT(A) having concurrent powers of the AO u/s 250(4) of the Act, was justified in deleting the addition

MESERS P.D. RICE UDYOG,,RAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, 1(1), RAIPUR

In the result, appeal of the assessee is disposed off in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.210/Rpr/2018 "नधा"रण वष" / Assessment Year : 2013-14 M/S. P.D Rice Udyog Samrat Talkies, Station Road, Raipur (C.G.)-492 001 Pan: Aadfp0368H .......अपीलाथ" / Appellant बनाम / V/S. The Deputy Commissioner Of Income Tax-1(1), Raipur (C.G.) ……""यथ" / Respondent आयकर अपील सं. / Ita No.11/Rpr/2019 "नधा"रण वष" / Assessment Year : 2013-14 The Deputy Commissioner Of Income Tax-1(1), Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. P.D Rice Udyog Samrat Talkies, Station Road, Raipur (C.G.)-492 001 Pan: Aadfp0368H

purchased by it nor it could ensure presence of supplier, the addition under section 69C on the basis of GP ratio is unjustified?" 7. Whether on points of law and on points of facts & circumstances of the case, the Ld. CIT(A) having concurrent powers of the AO u/s 250(4) of the Act, was justified in deleting the addition

INCOME TAX OFFICER, WARD 1(2),, RAIPUR vs. SHRI RAJENDRA KUMAR AGRAWAL, NEORA, RAIPUR

In the result, appeal of the revenue is partly allowed for statistical purposes in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं./ Ita No.15/Rpr/2019 "नधा"रण वष" / Assessment Year : 2013-14 The Income Tax Officer, Ward-1(2), Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. Shri Rajendra Kumar Agrawal, M/S. Amit Chawal Udyog Neora, Tilda, Raipur (C.G.) Pan : Acipa5919L ……""यथ" / Respondent Assessee By :S/Shri G.S. Agrawal & N.C Gupta, Ar’S Revenue By : Shri Sanjay Kumar, Sr. Dr

bogus bills only?" 7. "Whether on points of law and on facts & circumstances of the case, the ld. CIT(A) was justified in ignoring the ratio of the ITAT Mumbai in the case of Soman Sun City Vs. JCIT, wherein it was held that purchases could not be treated as genuine even if the purchase bill produced and payment

INCOME TAX OFFICER, WARD-1(2), RAIPUR vs. MESERS BALAJI RICE INDUSTRIES, RAIPUR

In the result, appeal of the revenue is partly allowed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.168/Rpr/2019 "नधा"रण वष" / Assessment Year : 2013-14 M/S. Balaji Rice Industries, Kharora, Tah-Tilda, Raipur (C.G.)-493 225 Pan : Aacfb4543M .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-1(2), Raipur (C.G.) ……""यथ" / Respondent आयकर अपील सं. / Ita No.181/Rpr/2019 "नधा"रण वष" / Assessment Year : 2013-14 The Income Tax Officer-1(2), Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. Balaji Rice Industries, Kharora, Tah-Tilda, Raipur (C.G.)-493 225 Pan : Aacfb4543M ……""यथ" / Respondent

section 69C on the basis of GP ratio is unjustified"? 5. Whether on points of law and on facts & circumstances of the case, the Ld. CIT(A) having concurrent powers of the AO u/s. 250(4) of the Act, was justified in deletion the addition of Rs. 1,43,22,138/- out of total addition made

MESERS BALAJI RICE INDUSTRIES,RAIPUR vs. INCOME TAX OFFICER, WARD-1(2), RAIPUR

In the result, appeal of the revenue is partly allowed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.168/Rpr/2019 "नधा"रण वष" / Assessment Year : 2013-14 M/S. Balaji Rice Industries, Kharora, Tah-Tilda, Raipur (C.G.)-493 225 Pan : Aacfb4543M .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-1(2), Raipur (C.G.) ……""यथ" / Respondent आयकर अपील सं. / Ita No.181/Rpr/2019 "नधा"रण वष" / Assessment Year : 2013-14 The Income Tax Officer-1(2), Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. Balaji Rice Industries, Kharora, Tah-Tilda, Raipur (C.G.)-493 225 Pan : Aacfb4543M ……""यथ" / Respondent

section 69C on the basis of GP ratio is unjustified"? 5. Whether on points of law and on facts & circumstances of the case, the Ld. CIT(A) having concurrent powers of the AO u/s. 250(4) of the Act, was justified in deletion the addition of Rs. 1,43,22,138/- out of total addition made

INCOME TAX OFFICER, WARD 1(2), RAIPUR vs. MESERS SATYANARAYAN NATHULAL, TILDA-NEORA

In the result appeal of the revenue is allowed for statistical purposes

Bench: Shri Ravish Sood & Shri Rathod Kamlesh Jayantbhaiआयकर अपील सं. / Ita No. 178/Rpr/2018 "नधा"रण वष" / Assessment Year : 2014-15 Income Tax Officer-1(2) Raipur (C.G) .......अपीलाथ" / Appellant बनाम / V/S. M/S Satyanarayan Nathulal Gandhi Chowk, Tilda-Neora Dist: Raipur (C.G) Pan : Aakfs1487K ……""यथ" / Respondent Assessee By : Shri Ravi Agrawal Revenue By : Shri Debashish Lahiri

bogus purchase to suppress the profits and the profits shown by the assessee is real and genuine. In the instant case the profitability has been in consistency with past trend and in-accordance with the assessment framed by your honor in regular assessment of previous year. iii. The sales were affected by the assessee out of the stock purchased from

DEPUTY COMMISSIONER OF INCOME TAX 1(1), RAIPUR vs. TIRUPATI BALAJI FOODS PRIVATE LIMITED, RAIPUR

In the result, appeal of the Revenue is allowed for statistical purposes

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita No.657/Rpr/2025 "नधा"रण वष" / Assessment Year : 2012-13 The Deputy Commissioner Of Income Tax-1(1), Raipur (C.G.)

bogus purchases before the said authority needs to be examined. The Ld. CIT(Appeals)/NFAC shall pass order while considering the decision of the Hon’ble High Court of Bombay in the case of Pr. CIT Vs. Kanak Impex (India) Ltd. (supra) vis-a-vis the facts of the case of the assesse and pass a speaking order in terms

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1(1), RAIPUR vs. MESERS TIRUPATI BALAJI FOOD PRIVATE LIMITED, TILDA

In the result, appeal of the revenue in ITA No

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.202/Rpr/2018 "नधा"रण वष" / Assessment Year : 2014-15 The Assistant Commissioner Of Income Tax-1(1), Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. Tirupati Balaji Foods Pvt. Ltd., Tilda-Neora, Raipur (C.G.) Pan : Aacct7476L ……""यथ" / Respondent आयकर अपील सं. / Ita No.13/Rpr/2019 "नधा"रण वष" / Assessment Year : 2015-16 The Assistant Commissioner Of Income Tax-1(1), Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. Tirupati Balaji Foods Pvt. Ltd., Tilda-Neora, Raipur (C.G.) Pan : Aacct7476L ……""यथ" / Respondent

section 69C on the basis of GP ratio is unjustified?" 5. "Whether on points of law and on fact & circumstances of the case, the Ld.CIT(A) having concurrent powers of the AO u/s 250(4) of the Act, was justified in deleting the addition of Rs.5,37,29,238/- out of total addition made by the AO as the assessee

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1(1), RAIPUR vs. MESERS TIRUPATI BALAJI FOOD PRIVATE LIMITED, TILDA

In the result, appeal of the revenue in ITA No

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.202/Rpr/2018 "नधा"रण वष" / Assessment Year : 2014-15 The Assistant Commissioner Of Income Tax-1(1), Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. Tirupati Balaji Foods Pvt. Ltd., Tilda-Neora, Raipur (C.G.) Pan : Aacct7476L ……""यथ" / Respondent आयकर अपील सं. / Ita No.13/Rpr/2019 "नधा"रण वष" / Assessment Year : 2015-16 The Assistant Commissioner Of Income Tax-1(1), Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. Tirupati Balaji Foods Pvt. Ltd., Tilda-Neora, Raipur (C.G.) Pan : Aacct7476L ……""यथ" / Respondent

section 69C on the basis of GP ratio is unjustified?" 5. "Whether on points of law and on fact & circumstances of the case, the Ld.CIT(A) having concurrent powers of the AO u/s 250(4) of the Act, was justified in deleting the addition of Rs.5,37,29,238/- out of total addition made by the AO as the assessee

ASHOK KUMAR WADHWANI, RAIPUR,RAIPUR vs. INCOME TAX OFFICER, WARD-1(2), RAIPUR, RAIPUR

In the result, appeal in ITA No

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं./Ita Nos.117 &118/Rpr/2024 "नधा"रण वष" /Assessment Year: 2014-15 & 2016-17 Ashok Kumar Wadhwani, Ujwal Udyog, Sinodha, Neora, Tilda, Raipur, Chhattisgarh. Pan: Aahpw1400B .......अपीलाथ" / Appellant बनाम / V/S.

12 Ashok Kumar Wadhwani Vs. Income Tax Officer, Ward 1(2), Raipur ITA Nos.117 &118/RPR/2024 fictitious invoices in the name of 33 bogus parties should be disallowed out of the amount of purchases shown to have been made from those 33 bogus suppliers." Point No. 21.1:- "We have already considered the facts relating to bogus purchases invoices in respect

ASHOK KUMAR WADHWANI, RAIPUR,RAIPUR vs. INCOME TAX OFFICER, WARD-1(2), RAIPUR, RAIPUR

In the result, appeal in ITA No

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं./Ita Nos.117 &118/Rpr/2024 "नधा"रण वष" /Assessment Year: 2014-15 & 2016-17 Ashok Kumar Wadhwani, Ujwal Udyog, Sinodha, Neora, Tilda, Raipur, Chhattisgarh. Pan: Aahpw1400B .......अपीलाथ" / Appellant बनाम / V/S.

12 Ashok Kumar Wadhwani Vs. Income Tax Officer, Ward 1(2), Raipur ITA Nos.117 &118/RPR/2024 fictitious invoices in the name of 33 bogus parties should be disallowed out of the amount of purchases shown to have been made from those 33 bogus suppliers." Point No. 21.1:- "We have already considered the facts relating to bogus purchases invoices in respect

RAVI KEDIA, BALODA BAZAR,BALODA BAZAR vs. INCOME TAX OFFICER, WARD BHATAPARA, BALODA BAZAR, BALODA BAZAR

In the result, appeal of the assessee is allowed for statistical purposes in terms of my aforesaid observations

Bench: Shri Ravish Soodआयकर अपील सं./ Ita No. 111/Rpr/2023 "नधा"रण वष" / Assessment Year : 2012-13 Ravi Kedia, Ekdand Chawal Udyog, Village Risda, Baloda Bazar, Chhattisgarh-493 332 Pan : Ajrpk5750D .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-Bhatapara (C.G.). ……""यथ" / Respondent

bogus purchases at the same rate as that of the other genuine purchases.” Adopting a similar approach, the Ld. AR has filed before me a calculation chart, Page 158 of APB, wherein on similar lines he had worked out the variance between the gross profit of the genuine purchase transactions and gross profit of the bogus/unverified purchase transactions at Rs.1