SIDDHI VINAYAK KNOTS & PRINTERS PVT. LTD.,SURAT vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, SURAT

In the result, all the appeals of the assessee are allowed and appeals of revenue are dismissed

Bench: Shri Pawan Singh & Dr. Arjun Lal Sainiit(Ss)A Nos. 40, 41, 42, 43 & 115/Srt/2021 (Assessment Years 2010-11 To 2014-15) (Physical Hearing) Siddhi Vinayak Knots & Prints D.C.I.T., Pvt. Ltd., Central Circle-2, Vs. A-26, Central Park, Gidc, Surat. Pandesara, Surat-394221. Pan No. Aamcs 4421 L Appellant/ Assessee Respondent/ Revenue

1,30,09,514/- out of total addition of Rs. 4,68,34,249/- on account of alleged bogus purchase by estimation of profit at the rate of 5% of alleged bogus purchase. 4. It is therefore prayed that addition made by the Assessing Officer and confirmed by ld. CIT(A) may please be deleted or the matter may please

ITO, WARD-2(3)(2), SURAT, SURAT vs. KISHOR BHANUBHAI ASODARIA, SURAT

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

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Bijayananda Pruseth (Accountant Member)

purchase of shares because he has not disputed the same by proving them fake, fabricated, fictious & bogus. Also, applying the test of human probabilities, the taxing Authorities cannot put on blinkers while looking at the documents produced before them by the appellant. They were entitled to look in to the surrounding circumstances to find out the reality of the recitals

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, VAPI vs. GUJARAT POLYSOL CHEMICALS LIMITED, VAPI

In the result, all the appeals filed by the revenue\nstands dismissed

1 (SC)[20-01-\n2010) and in the case of PCIT (Inv.) & Ors. Vs. Laljibhai\nKanjibhai Mandalia 2022 IETL 1944: (2022) 446 ITR 18: (2022)\n327 CTR 353: (2022) 215 DTR 417: (2022) 288 Тахтап 361.\n11. On merit of the addition, the Ld. AR of the assessee also\nrelied upon the decision of Hon'ble Delhi High Court

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, VAPI vs. GUJARAT POLYSOL CHEMICALS LIMITED, VAPI

In the result, the appeal of assessee is partly allowed whereas appeal of Revenue is dismissed

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Om Prakash Kant & & Assistant Commissioner Of Vs. Gujarat Polysol Income Tax Chemicals Limited 9Th Floor, Fortune Square Ii, 1, Plot No. 1734, 3Rd Daman Road, Chala, Vapi Phase, Gidc, Vapi, 396191 Gujarat 396195 Pan/Gir No. Aaacg8908Q (Applicant) (Respondent)

153A proceeded to make the assessment under section 147 of the Act. The Assessing Officer disallowed 25% of purchase considered by him disputed / inflated purchase. We further find that before Ld. CIT(A), the assessee reiterated its stand and contended that assessee's purchase are supported by bills, vouchers and their sales were not disputed. The consumption and sales

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, VAPI vs. GUJARAT POLYSOL CHEMICALS LIMITED, VAPI

In the result, the appeal of assessee is partly allowed whereas appeal of Revenue is dismissed

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Om Prakash Kant & & Assistant Commissioner Of Vs. Gujarat Polysol Income Tax Chemicals Limited 9Th Floor, Fortune Square Ii, 1, Plot No. 1734, 3Rd Daman Road, Chala, Vapi Phase, Gidc, Vapi, 396191 Gujarat 396195 Pan/Gir No. Aaacg8908Q (Applicant) (Respondent)

153A proceeded to make the assessment under section 147 of the Act. The Assessing Officer disallowed 25% of purchase considered by him disputed / inflated purchase. We further find that before Ld. CIT(A), the assessee reiterated its stand and contended that assessee's purchase are supported by bills, vouchers and their sales were not disputed. The consumption and sales

INCOME TAX OFFICER, WARD-2(3)(8), SURAT vs. MAHAVEER SHANTILAL JAIN, SURAT

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.453/Srt/2019 "नधा"रण वष"/Assessment Year: (2013-14) (Physical Hearing) The Ito, Vs. Mahaveer Shantilal Jain, Ward-2(3)(8), Prop. M/S Mukesh Diamonds, 1St Surat. Office No.401, Floor, H.No.5/1171/72/73/1090, New Dtc, Hath Falia, Haripura, Surat – 395009. (Appellant) (Respondent) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aqupj6439L Appellant By Shri Ritesh Mishra, Cit(Dr) Respondent By Shri P. M. Jagasheth, Ca Date Of Hearing 08/09/2023 Date Of Pronouncement 25/09/2023

bogus purchases, observing as follows: “10.1.7 It is further seen that the Honorable Gujarat High Court in the cases decided subsequent to N K Proteins ltd (supra) has not followed it, viz in the cases of Jagdish H. Patel, TA No.411 of 2017 dtd 01/08/2017 (8% disallowance) and TEJUA ROHITKUMAR KAPADIA, Surat in TA No. 691/2017 dated 18.09.2017 (0% disallowance

VIJAYBHAI MALABHAI BHARWAD,SURAT vs. ASST. COMMISSIONER OF INCOME TAX, CIR.,-1(2), SURAT

In the result, ground no.2 raised by the assessee in ITA

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर(खोज-और-ज"ती)अपील सं/It(Ss)A Nos.23 & 24/Srt/2021 (Assessment Years: 2012-13 & 2013-14) (Physical Hearing) The Dcit, Vs. Vijaybhai Malabhai Bharwad, Central Circle – 3, B-58, Chandramani Apartment, Surat. Udhana Magdalla Road, Surat - 395007 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aclpv4173C (Appellant) (Respondent) आयकर अपील सं./Ita No.118/Srt/2021 (Assessment Year: 2014-15) Vijaybhai Malabhai Bharwad, Vs. The Acit, B-58, Chandramani Apartment, Circle -1(2), Udhana Magdalla Road, Surat - 395007 Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aclpv4173C (Appellant) (Respondent) आयकर अपील सं./Ita No.121/Srt/2021 (Assessment Year: 2014-15) The Dcit, Vs. Vijaybhai Malabhai Bharwad, Central Circle – 2, B-58, Chandramani Apartment, Surat. Udhana Magdalla Road, Surat - 395007 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aclpv4173C (Appellant) (Respondent) आयकर(खोज-और-ज"ती)अपील सं It(Ss)A Nos.90/Srt/2022 (Assessment Year: 2014-15) Vijaybhai Malabhai Bharwad, Vs. The Dcit, B-58, Chandramani Apartment, Central Circle – 3, Udhana Magdalla Road, Surat. Surat - 395007 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aclpv4173C (Appellant) (Respondent)

bogus. We note that assessment has been made u/s 153C of the Act, as the search was conducted on 04.09.2015, in the case M/s Param Properties and during the course of search, some documents belonging to the assessee were found pertaining to few assessment years. However, for the assessment year under consideration, there is no mention of any incriminating document

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIR.,2, SURAT vs. VIJAYBHAI MALABHAI BHARWAD, SURAT

In the result, ground no.2 raised by the assessee in ITA

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर(खोज-और-ज"ती)अपील सं/It(Ss)A Nos.23 & 24/Srt/2021 (Assessment Years: 2012-13 & 2013-14) (Physical Hearing) The Dcit, Vs. Vijaybhai Malabhai Bharwad, Central Circle – 3, B-58, Chandramani Apartment, Surat. Udhana Magdalla Road, Surat - 395007 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aclpv4173C (Appellant) (Respondent) आयकर अपील सं./Ita No.118/Srt/2021 (Assessment Year: 2014-15) Vijaybhai Malabhai Bharwad, Vs. The Acit, B-58, Chandramani Apartment, Circle -1(2), Udhana Magdalla Road, Surat - 395007 Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aclpv4173C (Appellant) (Respondent) आयकर अपील सं./Ita No.121/Srt/2021 (Assessment Year: 2014-15) The Dcit, Vs. Vijaybhai Malabhai Bharwad, Central Circle – 2, B-58, Chandramani Apartment, Surat. Udhana Magdalla Road, Surat - 395007 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aclpv4173C (Appellant) (Respondent) आयकर(खोज-और-ज"ती)अपील सं It(Ss)A Nos.90/Srt/2022 (Assessment Year: 2014-15) Vijaybhai Malabhai Bharwad, Vs. The Dcit, B-58, Chandramani Apartment, Central Circle – 3, Udhana Magdalla Road, Surat. Surat - 395007 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aclpv4173C (Appellant) (Respondent)

bogus. We note that assessment has been made u/s 153C of the Act, as the search was conducted on 04.09.2015, in the case M/s Param Properties and during the course of search, some documents belonging to the assessee were found pertaining to few assessment years. However, for the assessment year under consideration, there is no mention of any incriminating document

GUJARAT POLYSOL CHEMICALS LIMITED LIMITED,VAPI vs. THE ASST. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1, VAPI, VAPI

In the result, the appeal of assessee is partly allowed whereas appeal of Revenue is dismissed

Bench: Shri Pawan Singh & Dr Arjun Lal Sainiआ.अ.सं./Ita No.513 & 595/Srt/2023 (Ay 2018-19) (Hearing In Physical Court) Gujarat Polysol Chemicals Ltd. Assistant Commissioner Of 1, Plot No.1734, 3Rd Phase. Income Tax, Central Circle-1, Vs Gidc, Vapi-396195 Vapi, 8Th Floor, Fortune Square- Pan No. Aaacg 8908 Q Ii, Above Tbz, Chala-396191 अपीलाथ"/Appellant ""थ" /Respondent /Ita No.595/Srt/2023 (Ay 2018-19) Deputy Commissioner Of Gujarat Polysol Chemicals Ltd., Income Tax, Central Circle, I, Plot No.1734, 3Rd Phase, Gidc, Vs Vapi, 9Th Floor, Fortune Vapi-396195 Pan No.Aaacg 8908 Q Square-Ii, Daman Road, Chala, Vapi-396191 अपीलाथ"/Appellant ""थ" /Respondent

153A proceeded to make the assessment under section 147 of the Act. The Assessing Officer disallowed 25% of purchase considered by him disputed / inflated purchase. We further find that before Ld. CIT(A), the assessee reiterated its stand and contended that assessee’s purchase are supported by bills, vouchers and their sales 15 ITA Nos. 513 & 595/SRT/2023

DCIT, VAPI vs. GUJARART POLYSOL CHEMICAL LTD, VAPI

In the result, the appeal of assessee is partly allowed whereas appeal of Revenue is dismissed

Bench: Shri Pawan Singh & Dr Arjun Lal Sainiआ.अ.सं./Ita No.513 & 595/Srt/2023 (Ay 2018-19) (Hearing In Physical Court) Gujarat Polysol Chemicals Ltd. Assistant Commissioner Of 1, Plot No.1734, 3Rd Phase. Income Tax, Central Circle-1, Vs Gidc, Vapi-396195 Vapi, 8Th Floor, Fortune Square- Pan No. Aaacg 8908 Q Ii, Above Tbz, Chala-396191 अपीलाथ"/Appellant ""थ" /Respondent /Ita No.595/Srt/2023 (Ay 2018-19) Deputy Commissioner Of Gujarat Polysol Chemicals Ltd., Income Tax, Central Circle, I, Plot No.1734, 3Rd Phase, Gidc, Vs Vapi, 9Th Floor, Fortune Vapi-396195 Pan No.Aaacg 8908 Q Square-Ii, Daman Road, Chala, Vapi-396191 अपीलाथ"/Appellant ""थ" /Respondent

153A proceeded to make the assessment under section 147 of the Act. The Assessing Officer disallowed 25% of purchase considered by him disputed / inflated purchase. We further find that before Ld. CIT(A), the assessee reiterated its stand and contended that assessee’s purchase are supported by bills, vouchers and their sales 15 ITA Nos. 513 & 595/SRT/2023

ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, SURAT, SURAT vs. TANMAN JEWELS PVT. LTD., SURAT

In the result, appeals filed by the Assessee in ITA Nos

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

section 153A was served on the assessee to file return of income. The assessee filed return in response to the said notice, but no additional income was offered. The assessing officer after serving statutory notices proceeded for assessment. During the assessment the assessing officer referred relevant part of the statement of assessee and diagram of modus operandi of business operation

ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-3, SURAT, SURAT vs. ANTIQUE EXIM PVT. LTD., SURAT

In the result, appeals filed by the Assessee in ITA Nos

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

section 153A was served on the assessee to file return of income. The assessee filed return in response to the said notice, but no additional income was offered. The assessing officer after serving statutory notices proceeded for assessment. During the assessment the assessing officer referred relevant part of the statement of assessee and diagram of modus operandi of business operation

TANMAN JEWELS PVT LTD,SURAT vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, SURAT

In the result, appeals filed by the Assessee in ITA Nos

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

section 153A was served on the assessee to file return of income. The assessee filed return in response to the said notice, but no additional income was offered. The assessing officer after serving statutory notices proceeded for assessment. During the assessment the assessing officer referred relevant part of the statement of assessee and diagram of modus operandi of business operation

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, SURAT, SURAT vs. SAFFRON GEMS PVT. LTD., SURAT

In the result, appeals filed by the Assessee in ITA Nos

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

section 153A was served on the assessee to file return of income. The assessee filed return in response to the said notice, but no additional income was offered. The assessing officer after serving statutory notices proceeded for assessment. During the assessment the assessing officer referred relevant part of the statement of assessee and diagram of modus operandi of business operation

ACIT, CENTRAL CIRCLE-3, SURAT, SURAT vs. NOBAL JEWELS PVT. LTD., SURAT

In the result, appeals filed by the Assessee in ITA Nos

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

section 153A was served on the assessee to file return of income. The assessee filed return in response to the said notice, but no additional income was offered. The assessing officer after serving statutory notices proceeded for assessment. During the assessment the assessing officer referred relevant part of the statement of assessee and diagram of modus operandi of business operation

SAFFRON GEMS PVT LTD,SURAT vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, SURAT

In the result, appeals filed by the Assessee in ITA Nos

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

section 153A was served on the assessee to file return of income. The assessee filed return in response to the said notice, but no additional income was offered. The assessing officer after serving statutory notices proceeded for assessment. During the assessment the assessing officer referred relevant part of the statement of assessee and diagram of modus operandi of business operation

ANTIQUE EXIM PVT. LTD, SURAT,SURAT vs. ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, SURAT

In the result, appeals filed by the Assessee in ITA Nos

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

section 153A was served on the assessee to file return of income. The assessee filed return in response to the said notice, but no additional income was offered. The assessing officer after serving statutory notices proceeded for assessment. During the assessment the assessing officer referred relevant part of the statement of assessee and diagram of modus operandi of business operation

NOBAL JEWELS PVT LTD ,SURAT vs. ASST COMMISSIONER OF INCOME TAX, SURAT

In the result, appeals filed by the Assessee in ITA Nos

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

section 153A was served on the assessee to file return of income. The assessee filed return in response to the said notice, but no additional income was offered. The assessing officer after serving statutory notices proceeded for assessment. During the assessment the assessing officer referred relevant part of the statement of assessee and diagram of modus operandi of business operation