INCOME TAX OFFICER, WARD-2(3)(8), SURAT, SURAT vs. SANJAYKUMAR DEVKISHAN PANWAR,, SURAT

In the result the ground No

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.569/Srt/2019 Assessment Year: (2008-09) (Physical Court Hearing) Sanjaykumar Devkishan Panwar, Vs. The Ito, Ward-2(3)(8), 207, 2Nd Floor, 6/2060/61 Vedant Surat. Building Bojabhai Ni Sheri, Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aovpp8989A (Revenue)/(Appellant) (Assessee)/(Respondent) आयकर अपील सं./Ita No.588/Srt/2019 Assessment Year: (2008-09) The Ito, Ward-2(3)(8), Vs. Sanjaykumar Devkishan Panwar, 207, 2Nd Floor, 6/2060/61 Vedant Surat. Building Bojabhai Ni Sheri, Mahidharpura, Surat – 395003 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aovpp8989A (Revenue)/(Appellant) (Assessee)/(Respondent) Assessee By Shri Rohit Vijayvargia, Ca Shri Ritesh Mishra, Cit(Dr) Respondent By Date Of Hearing 03/02/2023 Date Of Pronouncement 20/02/2023

bogus purchases are not the genuine business expenses, for the purpose of section 37 of the Act, therefore it should be disallowed entirely and order of the Assessing Officer must be upheld. 12. On the other hand, Ld. Counsel for the assessee submitted that reasons recorded by the Assessing Officer are bad in law and defective, therefore the reopening

SHRIFAL IMPEX PVT. LTD.,,SURAT vs. INCOME TAX OFFICER, WARD - 2(1)(3), SURAT

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.190 To 191/Srt/2023 Assessment Year: (2011-12 To 2012-13) (Physical Hearing) Shrifal Impex Private Limited, Vs. The Ito, No.504, 5Th Floor, H. No.6/B/1739- Ward-2(1)(3), 1380, Parshwa Complex Thoba Sheri, Surat Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaocs4409E (Appellant) (Respondent) आयकर अपील सं./Ita No.250/Srt/2023 Assessment Year: (2014-15) Shrifal Impex Private Limited, Vs. The Ito, No.504, 5Th Floor, H. No.6/B/1739- Ward-2(1)(3), 1380, Parshwa Complex Thoba Sheri, Surat Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaocs4409E (Appellant) (Respondent)

bogus purchases and was added to income of the assessee u/s 143(3) of the Act, dated 31/03/2015. 12. Aggrieved by the order of Assessing Officer, the assessee carried the matter in appeal before the ld. CIT(A) who has confirmed the action of the Assessing Officer by adjudicating various aspects/arguments raised by the assessee, as follows

SHRIFAL IMPEX PVT. LTD.,,SURAT vs. INCOME TAX OFFICER, WARD - 2(1)(3), SURAT

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.190 To 191/Srt/2023 Assessment Year: (2011-12 To 2012-13) (Physical Hearing) Shrifal Impex Private Limited, Vs. The Ito, No.504, 5Th Floor, H. No.6/B/1739- Ward-2(1)(3), 1380, Parshwa Complex Thoba Sheri, Surat Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaocs4409E (Appellant) (Respondent) आयकर अपील सं./Ita No.250/Srt/2023 Assessment Year: (2014-15) Shrifal Impex Private Limited, Vs. The Ito, No.504, 5Th Floor, H. No.6/B/1739- Ward-2(1)(3), 1380, Parshwa Complex Thoba Sheri, Surat Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaocs4409E (Appellant) (Respondent)

bogus purchases and was added to income of the assessee u/s 143(3) of the Act, dated 31/03/2015. 12. Aggrieved by the order of Assessing Officer, the assessee carried the matter in appeal before the ld. CIT(A) who has confirmed the action of the Assessing Officer by adjudicating various aspects/arguments raised by the assessee, as follows

SHRIFAL IMPEX PRIVATE LIMITED,SURAT vs. INCOME TAX OFFICER, WARD - 2(1)(3), SURAT

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.190 To 191/Srt/2023 Assessment Year: (2011-12 To 2012-13) (Physical Hearing) Shrifal Impex Private Limited, Vs. The Ito, No.504, 5Th Floor, H. No.6/B/1739- Ward-2(1)(3), 1380, Parshwa Complex Thoba Sheri, Surat Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaocs4409E (Appellant) (Respondent) आयकर अपील सं./Ita No.250/Srt/2023 Assessment Year: (2014-15) Shrifal Impex Private Limited, Vs. The Ito, No.504, 5Th Floor, H. No.6/B/1739- Ward-2(1)(3), 1380, Parshwa Complex Thoba Sheri, Surat Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaocs4409E (Appellant) (Respondent)

bogus purchases and was added to income of the assessee u/s 143(3) of the Act, dated 31/03/2015. 12. Aggrieved by the order of Assessing Officer, the assessee carried the matter in appeal before the ld. CIT(A) who has confirmed the action of the Assessing Officer by adjudicating various aspects/arguments raised by the assessee, as follows

INCOME TAX OFFICER, WARD 2(3)(8), SURAT vs. SHRI RAJESH KUMAR PAMECHA, AJMER

In the result the ground No

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble Accountnat Member (Physical Court Hearing) Sl.

reopening and assessment on this ground would mean that the appellant is given undue benefit of mistakes by an individual officer. This is neither fair nor equitable for the revenue. Hence, this ground is not allowed. 13. On merits, Ld. CIT(A) held as follows: “7.2 Ground regarding disallowance of bogus/ unverified purchases

ITO, WARD-2(3)(7), SURAT vs. ANSHUMAN RAMDAYALJI KUMAWAT, SURAT

In the result the ground No

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble Accountnat Member (Physical Court Hearing) Sl.

reopening and assessment on this ground would mean that the appellant is given undue benefit of mistakes by an individual officer. This is neither fair nor equitable for the revenue. Hence, this ground is not allowed. 13. On merits, Ld. CIT(A) held as follows: “7.2 Ground regarding disallowance of bogus/ unverified purchases

ITO, WARD-2(3)(7), SURAT vs. ANSHUMAN RAMDAYALJI KUMAWAT, SURAT

In the result the ground No

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble Accountnat Member (Physical Court Hearing) Sl.

reopening and assessment on this ground would mean that the appellant is given undue benefit of mistakes by an individual officer. This is neither fair nor equitable for the revenue. Hence, this ground is not allowed. 13. On merits, Ld. CIT(A) held as follows: “7.2 Ground regarding disallowance of bogus/ unverified purchases

ITO, WARD 2(3)(8), SURAT vs. MUKESH MAHAVIRPRASAD SEN, SURAT

In the result the ground No

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble Accountnat Member (Physical Court Hearing) Sl.

reopening and assessment on this ground would mean that the appellant is given undue benefit of mistakes by an individual officer. This is neither fair nor equitable for the revenue. Hence, this ground is not allowed. 13. On merits, Ld. CIT(A) held as follows: “7.2 Ground regarding disallowance of bogus/ unverified purchases

ITO, WARD 2(3)(8), SURAT vs. MUKESH MAHAVIRPRASAD SEN, SURAT

In the result the ground No

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble Accountnat Member (Physical Court Hearing) Sl.

reopening and assessment on this ground would mean that the appellant is given undue benefit of mistakes by an individual officer. This is neither fair nor equitable for the revenue. Hence, this ground is not allowed. 13. On merits, Ld. CIT(A) held as follows: “7.2 Ground regarding disallowance of bogus/ unverified purchases

INCOME TAX OFFICER, WARD 2(3)(7), SURAT vs. SHRI ANIL PUKHRAJ JAIN, SURAT

In the result the ground No

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.89/Srt/2017 िनधा"रण वष"/Assessment Year: (2008-09) (Physical Court Hearing) Income Tax Officer, Ward-2(3)(7), Anil Pukhraj Jain, Room No.414, 4Th Floor, Aayakar Prop. Of Aakruti Stone, 206-2Nd Floor, Tulsi Building, Bhavan, Adajan, Surat-395009 Vs. Somnath Mahadev Ni Sheri, Mahidharpura, Surat – 395009. (Appellant) (Respondent)/ "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Ahapj8569Q ""या"ेप सं Cross Objection No.10/Srt/2021 (A/O Ita No.89/Srt/2017) िनधा"रण वष"/Assessment Year: (2008-09) Anil Pukhraj Jain, Income Tax Officer, Ward-2(3)(7), Room No.414, 4Th Floor, Aayakar Prop. Of Aakruti Stone, 206- 2Nd Floor, Tulsi Building, Vs. Bhavan, Adajan, Surat-395009 Somnath Mahadev Ni Sheri, Mahidharpura, Surat – 395009. Appellant/Co-Objector (Respondent) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Ahapj8569Q िनधा"रती क" ओर से /Assessee By Shri Sapnesh R. Sheth, Ca राज"व क" ओर से /Respondent By Shri Ashok B. Koli, Cit-Dr सुनवाई क" तारीख/Date Of Hearing 23/12/2022 उ"ोषणा क" तारीख/Date Of Pronouncement 23/ 01/2023

purchase bill of diamonds received by assessee firm are bogus in nature and escaped assessment due to failure on the part of the assessee to disclosed fully and truly all the material facts necessary for the purpose of assessment. The case was reopened

SHRI RAVJIBHAI BECHARBHAI DHAMELIYA,,SURAT vs. INCOME TAX OFFICER WARD-3(1(1), SURAT

In the result, assessee`s appeal for both the assessment years, that is,

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Hearing) Sl.

bogus purchase bills, therefore reassessment proceedings initiated by the assessing officer u/s 147/148 is valid for both the assessment years, 2010-11 and 2011-12. 18. We heard both sides in detail and also perused the records of the case including the paper book filed by the assesses running in to 223 pages for assessment year

DCIT, CIRCLE-3(3), SURAT vs. SHRI RAVJIBHAI BECHARBHAI DHAMELIYA,, SURAT

In the result, assessee`s appeal for both the assessment years, that is,

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Hearing) Sl.

bogus purchase bills, therefore reassessment proceedings initiated by the assessing officer u/s 147/148 is valid for both the assessment years, 2010-11 and 2011-12. 18. We heard both sides in detail and also perused the records of the case including the paper book filed by the assesses running in to 223 pages for assessment year

ACIT, CIRCLE-3(3), SURAT vs. SHRI RAVJIBHAI BECHARBHAI DHAMELIYA, SURAT

In the result, assessee`s appeal for both the assessment years, that is,

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Hearing) Sl.

bogus purchase bills, therefore reassessment proceedings initiated by the assessing officer u/s 147/148 is valid for both the assessment years, 2010-11 and 2011-12. 18. We heard both sides in detail and also perused the records of the case including the paper book filed by the assesses running in to 223 pages for assessment year

SHRI RAVJIBHAI B DHAMELIYA,SURAT vs. DCIT, CIRCLE-2(1)(2), SURAT

In the result, assessee`s appeal for both the assessment years, that is,

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Hearing) Sl.

bogus purchase bills, therefore reassessment proceedings initiated by the assessing officer u/s 147/148 is valid for both the assessment years, 2010-11 and 2011-12. 18. We heard both sides in detail and also perused the records of the case including the paper book filed by the assesses running in to 223 pages for assessment year

INCOME TAX OFFICER, SURAT vs. MAGNIFIQUE GEMS PRIVATE LIMITED, SURAT

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

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.389 & 458/Srt/2023 "नधा"रण वष"/Assessment Year: (2011-12) (Physical Court Hearing) Magnifique Gems Pvt. Ltd. Income Tax Officer, Ward- 105, Rajshree Building, Maniyara 1(1)(4), Surat, Aayakar Bhawan, Sheri Na Naka,Mahidharpura, Near Majura Gate, Opp. New Surat-395003. Civil Hospital, Surat-395001

reopening as well as restricting the addition to the extent of 12.50% of the alleged bogus purchases. The ld.AR of the assessee submits during the assessment

MAGNIFIQUE GEMS PRIVATE LIMITED,SURAT vs. INCOME TAX OFFICER, WARD -1(1)(4), SURAT

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

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.389 & 458/Srt/2023 "नधा"रण वष"/Assessment Year: (2011-12) (Physical Court Hearing) Magnifique Gems Pvt. Ltd. Income Tax Officer, Ward- 105, Rajshree Building, Maniyara 1(1)(4), Surat, Aayakar Bhawan, Sheri Na Naka,Mahidharpura, Near Majura Gate, Opp. New Surat-395003. Civil Hospital, Surat-395001

reopening as well as restricting the addition to the extent of 12.50% of the alleged bogus purchases. The ld.AR of the assessee submits during the assessment

ITO, WARD-2(3)(8), SURAT vs. MUKESHKUMAR LALCHAND JAIN, SURAT

In the result, appeal filed by the Revenue is partly allowed

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.452/Srt/2019 ("नधा"रण वष" /Assessment Year: (2008-09) (Physical Court Hearing) Income Tax Officer, Ward- Mukeshkumar Lalchand Jain, 2(3)(8), Room No.407, 4Th Prop. Of M/S Mukesh Diamonds, 1St Floor, Anavil Business Vs. Office No. 401, Floor, H. Centre, Adajan-Hajira Road, No.5/1171/72/73/1090, New Dtc, Adajan, Surat-395009 Hath Falia, Haripura, Surat – 395008. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Agupj3281A (Appellant)/(Revenue) (Respondent)/(Assessee)

reopening as well as restricting the addition to the ITA No.452/SRT/2019/AY.2008-09 Mukeshkumar Lalchand Jain extent of 12.50% of the alleged bogus purchases. The ld.AR of the assessee submits during the assessment

INCOME TAX OFFICER, WARD - 2(3)(6), SURAT vs. SHRI ABHISHEK NAVNITKUMAR DOSHI, SURAT

In the result the ground No

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No. 21/Srt/2022 Assessment Year: (2012-13) (Physical Court Hearing) Abhishek Navnitkumar Doshi, Vs. The Ito, Ward-2(3)(7), 204/205, 2Nd Floor, 6/1911-12, Surat. Jin Shanti Building, Jada Khadi, Mahidharpura – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afhpd0064M (Appellant) (Respondent) आयकर अपील सं./Ita No.38/Srt/2022 Assessment Year: (2012-13) The Ito, Ward-2(3)(6), Vs. Abhishek Navnitkumar Doshi, 204/205, 2Nd Floor, 6/1911-12, Surat. Jin Shanti Building, Jada Khadi, Mahidharpura – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afhpd0064M (Appellant) (Respondent) Assessee By Shri Sapnesh Sheth, Ca Respondent By Shri Vinod Kumar, Sr. Dr Date Of Hearing 28/12/2022 09/01/2023 Date Of Pronouncement

reopening as well as restricting the addition to the extent of 12.50% of the alleged bogus purchases. The ld.AR of the assessee submits during the assessment

ABHISHEK NAVNITKUMAR DOSHI,SURAT vs. INCOME TAX OFFICER, WD. 2(3)(7), SURAT

In the result the ground No

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No. 21/Srt/2022 Assessment Year: (2012-13) (Physical Court Hearing) Abhishek Navnitkumar Doshi, Vs. The Ito, Ward-2(3)(7), 204/205, 2Nd Floor, 6/1911-12, Surat. Jin Shanti Building, Jada Khadi, Mahidharpura – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afhpd0064M (Appellant) (Respondent) आयकर अपील सं./Ita No.38/Srt/2022 Assessment Year: (2012-13) The Ito, Ward-2(3)(6), Vs. Abhishek Navnitkumar Doshi, 204/205, 2Nd Floor, 6/1911-12, Surat. Jin Shanti Building, Jada Khadi, Mahidharpura – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afhpd0064M (Appellant) (Respondent) Assessee By Shri Sapnesh Sheth, Ca Respondent By Shri Vinod Kumar, Sr. Dr Date Of Hearing 28/12/2022 09/01/2023 Date Of Pronouncement

reopening as well as restricting the addition to the extent of 12.50% of the alleged bogus purchases. The ld.AR of the assessee submits during the assessment