INCOME TAX OFFICER, SIRHIND, FATEHGARH SAHIB vs. GUJRAL TRADERS, MANDI GOBINDGARH

IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH, CHANDIGARH PHYSICAL HEARING HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM 1. आयकरअपीलसं./ ITA No.125/CHANDI/2026 (िनधा�रणवष� / Assessment Year: 2011-12) & 2. आयकरअपीलसं./ ITA No.126/CHANDI/2026 (िनधा�रणवष� / Assessment Year: 2012-13) & 3. आयकरअपीलसं./ ITA No.127/CHANDI/2026 (िनधा�रणवष� / Assessment Year: 2013-14) ITO M/s Gujral Traders New Libra Kothi, Railway Road #35, Sector – 20B, Motia Khan बनाम/ Vs. Sirhind, Fatehgarh Sahib Mandi Gobindgarh Punjab - 140406 Punjab – 147301 �ायीलेखासं./जीआइआरसं./PAN/GIR No. AACFG-4062-A (अपीलाथ�/Appellant) : (��थ� / Respondent) अपीलाथ�कीओरसे/ Appellant by : None ��थ�कीओरसे/Respondent by : Sh. Vivek Vardhan (Addl. CIT) - Ld. Sr. DR सुनवाईकीतारीख/Date of Hearing : 01-07-2026 घोषणाकीतारीख /Date of Pronouncement 08-07-2026 : आदेश / O R D E R 1. Aforesaid appeals by revenue for Assessment Years (AYs) 2011- 12 to 2013-14 arises out of separate orders of learned first appellate authority. First, I take up appeal for AY 2011-12 which arises out of an order of learned Addl. / Joint Commissioner of Income Tax (Appeals)- 1, Lucknow [CIT(A)] dated 03.12.2025 in the matter of an assessment

framed by Ld. Assessing Officer [AO] on best judgment basis u/s 144 of the Act on 18.03.2014. 2. In the assessment order, Ld. AO made various additions to determine assessee’s total income at Rs.9.30 Lacs. The assessment was framed on best judgment basis for want of any substantive representation from the assessee. These additions / disallowances were primarily in the nature of expense disallowances. During first appeal, the assessee furnished additional evidences which were subjected to remand proceedings. The Ld. AO could not rebut the additional evidences of the assessee. Considering the same, Ld. CIT(A) deleted the impugned disallowances against which the revenue is in further appeal before Tribunal. 3. It clearly emerges that the assessee did not file required submissions during the course of assessment proceedings rather it filed additional evidences during first appeal which were duly been confronted to Ld. AO. The assessee furnished audited financial statements and various other details which could not be rebutted by Ld. AO during remand proceedings. Considering the remand report, the impugned disallowances have been deleted by Ld. CIT(A). Once the claim of the assessee stood accepted by Ld. AO, revenue could hardly be said to be aggrieved. Therefore, I endorse the adjudication of Ld. CIT(A). 4. Similar are the facts in AYs 2012-13 & 2013-14, Facts being pari- materia the same, I find no reason to interfere in the adjudication of Ld. CIT(A).

-Sd- (MANOJ KUMAR AGGARWAL) ACCOUNTANT MEMBER AS Dated: 08-07-2026 आदेश की �ितिलिप अ�ेिषत /Copy of the Order forwarded to : 1. अपीलाथ�/Appellant 2. ��थ�/Respondent 3. आयकरआयु�/CIT 4. िवभागीय�ितिनिध/DR 5. गाड�फाईल/GF

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