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.

bogus purchases and added to the total income of the assessee.” 12. Aggrieved by the order of the Assessing Officer, the assessee carried the matter in appeal before the ld. CIT(A) who has dismissed the technical ground raised by assessee about validity of reassessment u/s 147

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.

bogus purchases and added to the total income of the assessee.” 12. Aggrieved by the order of the Assessing Officer, the assessee carried the matter in appeal before the ld. CIT(A) who has dismissed the technical ground raised by assessee about validity of reassessment u/s 147

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.

bogus purchases and added to the total income of the assessee.” 12. Aggrieved by the order of the Assessing Officer, the assessee carried the matter in appeal before the ld. CIT(A) who has dismissed the technical ground raised by assessee about validity of reassessment u/s 147

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.

bogus purchases and added to the total income of the assessee.” 12. Aggrieved by the order of the Assessing Officer, the assessee carried the matter in appeal before the ld. CIT(A) who has dismissed the technical ground raised by assessee about validity of reassessment u/s 147

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.

bogus purchases and added to the total income of the assessee.” 12. Aggrieved by the order of the Assessing Officer, the assessee carried the matter in appeal before the ld. CIT(A) who has dismissed the technical ground raised by assessee about validity of reassessment u/s 147

M/S. NAZAR IMPEX PVT. LTD.,,SURAT vs. THE ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL CIRCEL-4,, SURAT

In the result all the grounds of appeal raised by the assessee are rejected

Bench: Shri Pawan Singh, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita Nos.1364 &1366/Ahd/2017 (िनधा"रणवष" / Assessment Year: (2007-08) (Virtual Court Hearing) M/S. Nazar Impex, Vs. The Acit, Central Circle-4, C/O. 408, Saryu Diamond Complex, Surat. Jaddakhadi, Mahidharpura, Surat-395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaccn3603R (Assessee) (Respondent)

u/s 147 of the Act. 7.2.1 Having gone through the entire gamut of facts and circumstances, I am of considered opinion that not only there existed new information with the AO from the credible sources, but also that he has applied has mind and recorded the conclusion that the purchases claimed were non-genuine and therefore bogus, (clearly meaning that

SHRI SANJAY KUMAR CHOUDHARY HUF,,SURAT vs. THE ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL CIRCEL-4,, SURAT

In the result all the grounds of appeal raised by the assessee are rejected

Bench: Shri Pawan Singh, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita Nos.1364 &1366/Ahd/2017 (िनधा"रणवष" / Assessment Year: (2007-08) (Virtual Court Hearing) M/S. Nazar Impex, Vs. The Acit, Central Circle-4, C/O. 408, Saryu Diamond Complex, Surat. Jaddakhadi, Mahidharpura, Surat-395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaccn3603R (Assessee) (Respondent)

u/s 147 of the Act. 7.2.1 Having gone through the entire gamut of facts and circumstances, I am of considered opinion that not only there existed new information with the AO from the credible sources, but also that he has applied has mind and recorded the conclusion that the purchases claimed were non-genuine and therefore bogus, (clearly meaning that

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)

147 of the IT Act and notice u/s. 148 of the Act was issued to the assessee on 30/03/2019. In response to notice u/s. 148 of the Act the assessee filed its return of income on 26/04/2019 declaring total income at Rs.2,09,220/-. The assessee was provided copy of reasons recorded for reopening of case vide letter dated 25/05/2019

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)

147 of the IT Act and notice u/s. 148 of the Act was issued to the assessee on 30/03/2019. In response to notice u/s. 148 of the Act the assessee filed its return of income on 26/04/2019 declaring total income at Rs.2,09,220/-. The assessee was provided copy of reasons recorded for reopening of case vide letter dated 25/05/2019

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)

147 of the IT Act and notice u/s. 148 of the Act was issued to the assessee on 30/03/2019. In response to notice u/s. 148 of the Act the assessee filed its return of income on 26/04/2019 declaring total income at Rs.2,09,220/-. The assessee was provided copy of reasons recorded for reopening of case vide letter dated 25/05/2019

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

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

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

ASSISTANT COMMISSIONER OF INCOME TAX, NA vs. ARIVS.M/S RUSHABH INTERNATIONAL, NAVSARI

In the result, all three C

Bench: Shri Sudhanshu Srivastava & Shri Vikram S. Yadavassessment Year: 2011-12 Assessment Year: 2010-11 Assessment Year: 2012-13

bogus nature of the purchases was said to be confirmed by the statement of Shri ITA 347,349,350/SRT/2018 CO 9 to 11/SRT/2018 Dharmichand Jain. The Assessing Officer proceeded to reopen the case u/s 147 of the Act and in response to notice u/s 148 of the Act, the assessee requested the Assessing Officer to treat the original return/s

ASSISTANT COMMISSIONER OF INCOME TAX, NA vs. ARI CIRCLE, NAVSARIVS.M/S RUSHABH INTERNATIONAL , NAVSARI

In the result, all three C

Bench: Shri Sudhanshu Srivastava & Shri Vikram S. Yadavassessment Year: 2011-12 Assessment Year: 2010-11 Assessment Year: 2012-13

bogus nature of the purchases was said to be confirmed by the statement of Shri ITA 347,349,350/SRT/2018 CO 9 to 11/SRT/2018 Dharmichand Jain. The Assessing Officer proceeded to reopen the case u/s 147 of the Act and in response to notice u/s 148 of the Act, the assessee requested the Assessing Officer to treat the original return/s

ASSISTANT COMMISSIONER OF INCOME TAX, NA vs. ARI CIRCLE, SURATVS.M/S RUSHABH INTERNATIONAL, NAVSARI

In the result, all three C

Bench: Shri Sudhanshu Srivastava & Shri Vikram S. Yadavassessment Year: 2011-12 Assessment Year: 2010-11 Assessment Year: 2012-13

bogus nature of the purchases was said to be confirmed by the statement of Shri ITA 347,349,350/SRT/2018 CO 9 to 11/SRT/2018 Dharmichand Jain. The Assessing Officer proceeded to reopen the case u/s 147 of the Act and in response to notice u/s 148 of the Act, the assessee requested the Assessing Officer to treat the original return/s

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

147 of the IT Act For the reason discussed above, assessee's contention is rejected and as the assessee failed to explained that the purchase worth Rs.17,41,74,472/- are the genuine purchases therefore appropriate addition on ITA 89/SRT/2017 & CO. 10/SRT/2021/AY.2008-09 Anil Pukhraj Jain account of bogus purchase of Rs.17,41,74,472/- u/s