RAMINDERJEET KAUR, H.NO. 5623, SECTOR 38, WEST CHANDIGARH CHANDIGARH,CHANDIGARH vs. ASSISTANT COMMISSIONER OF INCOME TAX , CC-2, , CHANDIGARH
1
IN THE INCOME TAX APPELLATE TRIBUNAL
“B” BENCH, CHANDIGARH
HYBRID HEARING
BEFORE HON’BLE SHRI LALIET KUMAR, JM
AND HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM
आयकर अपील सं./ ITA No.149/CHANDI/2025 (िनधाŊरण वषŊ / Assessment Year: 2020-21) Shri Nirmal Singh S/o Shri Banta Singh H.No 5623 Sector 38 (West) Chandigarh -160036 बनाम/ Vs. DCIT-Central Circle-2 CR Building, Himalaya Marg Sector 17-E, Chandigarh-160017 ̾थायीलेखासं./जीआइआरसं./PAN/GIR No. AERPS-8844-M (अपीलाथŎ/Appellant) : (ŮȑथŎ / Respondent) & 2. आयकर अपील सं./ ITA No.151/CHANDI/2025 (िनधाŊरण वषŊ / Assessment Year: 2020-21) Smt. Raminderjeet Kaur H. No 5623 Sector 38 (West) Chandigarh -160036. बनाम/ Vs. ACIT-Central Circle-2 CR Building, Himalaya Marg Sector 17-E, Chandigarh-160017 ̾थायीलेखासं./जीआइआरसं./PAN/GIR No. AEGPR-6888-H (अपीलाथŎ/Appellant) : (ŮȑथŎ / Respondent)
अपीलाथŎकीओरसे/ Appellant by : Shri Sudhir Sehgal (Advocate) – Ld. AR
ŮȑथŎकीओरसे/Respondent by :
Smt. Kusum Bansal (CIT) – Ld. DR
सुनवाईकीतारीख/Date of Hearing
:
06-08-2025
घोषणाकीतारीख /Date of Pronouncement
:
02-09-2025
आदेश / O R D E R
Manoj Kumar Aggarwal (Accountant Member)
Aforesaid appeals by two assessees for Assessment Year (AY) 2020-21 have common issue. First, we take up ITA
No.149/Chandi/2025 which arises out of a common order of learned
Commissioner of Income Tax (Appeals)-3, Gurgaon [CIT(A)] dated 31-
12-2024 in the matter of an assessment framed by Ld. Assessing
Officer [AO] u/s. 153A(1)(b) r.w.s. 143(3) of the Act on 26-09-2022. In the assessment order, Ld. AO has made addition of Rs.12 Lacs which represent transfer of funds from Gyan Jyoti Educational and Social
Welfare Society (GJESWS). Another addition has been made for Rs.7.61 Lacs on account of facility of car which is alleged to be in violation of Sec.13(1)(c) of the Act.
2. The Ld. AR advanced arguments on legal grounds as well as on merits. The Ld. CIT-DR, on the other hand, controverted the arguments of Ld. AR and advanced arguments favoring the case of the revenue.
Having heard rival submissions and upon perusal of case records, the appeal is disposed-off as under.
Proceedings before lower authorities
3.1 The assessee filed return of income u/s 139 on 27-02-2021 post search action on the assessee-group on 28-01-2021. The assessee declared income of Rs.5.45 Lacs. In response to notice u/s 153A, the assessee furnished same return of income on 22-09-2021 which was subjected to scrutiny proceedings.
3.2 It transpired that the assessee acted as a Vice President of Universal Educational Society (UES) which was also covered under search action. The assessee also acted as President of Gyan Jyoti
Educational and Social Welfare Society (GJESWS). M/s GJESWS was registered with