ITAT Chandigarh Judgments — May 2025

MALKIT KAUR,NABHA vs ITO WARD NABHA, NABHA

ITA 43/CHANDI/2025[2015-16]Status: Disposed30 May 2025AY 2015-16Allowed

The Tribunal held that the assessee, being an agriculturist, was not conversant with tax laws and email communication. The physical copy of the assessment order was not served, and the email may not have reached her. Therefore, the delay in filing the appeal should have been condoned.

HARISH KUMAR,CHANDIGARH vs INCOME TAX OFFICER WARD 5(5) CHANDIGARH, CHANDIGARH

ITA 42/CHANDI/2025[2021-22]Status: Disposed30 May 2025AY 2021-22Allowed

The Tribunal held that the scheme, despite being named Voluntary Retirement Scheme (VRS), was in fact a retrenchment scheme due to BSNL's financial losses and the necessity to reduce employee costs. The compensation received was therefore a capital receipt and not taxable.

JIT SINGH,UBHAWAL, SANGRUR vs INCOME TAX OFFICER-WARD-1, SANGUR

ITA 27/CHANDI/2025[2017-18]Status: Disposed30 May 2025AY 2017-18Partly Allowed

The Tribunal held that the interests of justice would be served by giving the assessee an opportunity to present their case. The impugned order of the CIT(A) was set aside.

ZULU TELE SERVICES PRIVATE LIMITED,CHANDIGARH vs INCOME TAX OFFICER, WARD - 1(4), CHANDIGARH

ITA 1097/CHANDI/2024[2017-18]Status: Disposed30 May 2025AY 2017-18Allowed

The Tribunal held that the addition made by the lower authorities, confirming the CIT(A)'s decision, was not sustainable. The Tribunal found that the assessee had demonstrated sufficient cash in hand which was deposited due to the demonetization scheme announcement.

ASSISTANT COMMISSIONER OF INCOME TAX, PANCHKULA CIRCLE, PANCHKULA, PANCHKULA vs THE HARYANA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT, PANCHKULA

ITA 596/CHANDI/2024[2017-18]Status: Disposed30 May 2025AY 2017-18Partly Allowed

The Tribunal held that reassessment proceedings were validly initiated as the issue was not examined in the original assessment. It also ruled that disallowance under Section 14A is not warranted in the absence of exempt income, even if expenditure was incurred.

THE BUZURAG CO-OP. AGRISERVICES SOCIETY,JAGRAON vs INCOME TAX OFFICER, WARD-2, JAGRAON, JAGRAON

ITA 39/CHANDI/2025[2017-18]Status: Disposed30 May 2025AY 2017-18Allowed

The Tribunal condoned the delay in filing the appeal. It was held that the addition made by the AO was not sustainable as the assessee had demonstrated that the cash deposits in the bank account were received from farmers in lieu of earlier sales, as per the Ministry of Finance notification authorizing cooperative stores to accept specified bank notes against sales.

THE HARYANA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT,PANCHKULA vs DCIT,CIRCLE, PANCHKULA, PANCHKULA

ITA 588/CHANDI/2024[2014-15]Status: Disposed30 May 2025AY 2014-15Partly Allowed

The Tribunal held that reassessment proceedings were validly initiated as the issue was not examined in the original assessment. It also ruled that disallowance under Section 14A is not warranted in the absence of exempt income, even if expenditure was incurred.

ASSISTANT COMMISSIONER OF INCOME TAX, PANCHKULA CIRCLE, PANCHKULA, PANCHKULA vs THE HARYANA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT, PANCHKULA

ITA 594/CHANDI/2024[2016-17]Status: Disposed30 May 2025AY 2016-17Partly Allowed

The Tribunal held that reassessment proceedings were validly initiated as the issue was not examined in the original assessment. It also ruled that disallowance under Section 14A is not warranted in the absence of exempt income, even if expenditure was incurred.

THE KAROLI CMP SOCIETY,KOTI vs NWR-W-(37)(1), RAILWAY BOARD BUILDING

ITA 62/CHANDI/2025[2020-21]Status: Disposed30 May 2025AY 2020-21Allowed

The Tribunal held that the interests of justice would be served by giving the assessee an opportunity to present their case before the CIT(A). The impugned order was set aside and the matter was restored for a fresh decision.

MANPREET SINGH RANDHAWA,MALERKOTLA vs ADDITIONAL / JOINT / DEPUTY / AC / ITO, NATIONAL FACELESS ASSESSMENT CENTYER

ITA 29/CHANDI/2025[2014-2015]Status: Disposed30 May 2025AY 2014-2015Partly Allowed

The Tribunal held that the ex-parte order passed by the CIT(A) was not intentional due to the non-receipt of notices by the assessee. The impugned order was set aside, and the matter was restored to the CIT(A) for a fresh decision.

THE HARYANA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT,PANCHKULA vs DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE,, PANCHKULA

ITA 590/CHANDI/2024[2015-16]Status: Disposed30 May 2025AY 2015-16Partly Allowed

The Tribunal held that reassessment proceedings were validly initiated as the issue was not examined in the original assessment. It also ruled that disallowance under Section 14A is not warranted in the absence of exempt income, even if expenditure was incurred.

THE HARYANA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT,PANCHKULA vs DEPUTY COMMISSIONER OF INCOME TAX, CIRCLEU��, PANCHKULA

ITA 595/CHANDI/2024[2017-18]Status: Disposed30 May 2025AY 2017-18Partly Allowed

The Tribunal held that the reassessment proceedings for AY 2014-15 were valid. The reassessment was initiated based on specific information regarding unexamined NPA provisions of Rs.27,66,41,513, which were not part of the original assessment where only a minor NPA provision of Rs.28,854 was considered. The Tribunal found the Assessee's contention of a mere change of opinion to be misplaced, as the specific issue was not examined in the original assessment. The CIT(A)'s finding that the original assessment order was silent on the specific issue was upheld. The Tribunal also agreed with the CIT(A) that reopening based on audit objections is valid if the AO exercised independent judgment. The Assessee's argument regarding non-furnishing of reasons was treated as a procedural lapse. Therefore, the Assessee's ground challenging the validity of reassessment was dismissed. Regarding deduction under Section 80P for AYs 2015-16 and 2016-17, the Tribunal found no merit in interfering with the CIT(A)'s order and dismissed the ground as not pressed in one instance, while allowing it in another by applying findings from a previous appeal. For AY 2017-18, the Tribunal deleted the disallowance under Section 14A read with Rule 8D, agreeing with the CIT(A) that the disallowance was made despite the Assessee not earning any exempt income. The investments yielded taxable interest or taxable dividends from co-operative societies, and no income was claimed as exempt. The Tribunal held that the reliance on CBDT Circular No. 5/2014 by the Revenue was misplaced in this context, and the issue was covered in favour of the Assessee by High Court decisions like HDFC Bank Ltd., Lakhani Marketing, and Deepak Mittal.

THE HARYANA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT,PANCHKULA vs DCIT, CIRCLE, PANCHKULA, PANCHKULA

ITA 589/CHANDI/2024[2015-16]Status: Disposed30 May 2025AY 2015-16Partly Allowed

The Tribunal held that reassessment proceedings were validly initiated as the issue was not examined in the original assessment. It also ruled that disallowance under Section 14A is not warranted in the absence of exempt income, even if expenditure was incurred.

DD PURI FOUNDATION,PATIALA vs INCOME TAX OFFICER, WARD-3, PATIALA

ITA 68/CHANDI/2025[2021-22]Status: Disposed30 May 2025AY 2021-22Allowed

The Tribunal condoned the delay in filing the appeal before the CIT(A) and the Tribunal, observing that the delay was not intentional. The CIT(A) was directed to hear the appeal on its merits after providing adequate opportunity to the assessee.

GILL & VIRK FINANCE COMPANY LIMITED,CHANDIGARH vs INCOME TAX OFFICER, WARD 5(1), CHANDIGARH

ITA 936/CHANDI/2024[2018-19]Status: Disposed30 May 2025AY 2018-19Allowed

The Tribunal held that the disallowances made by the CPC were not warranted. The Assessing Officer had wrongly rejected the rectification application without properly considering the assessee's claims. The additions made by the lower authorities were not sustainable.

ASSISTANT COMMISSIONER OF INCOME TAX, PANCHKULA CIRCLE, PANCHKULA, PANCHKULA vs THE HARYANA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT, PANCHKULA

ITA 591/CHANDI/2024[2015-16]Status: Disposed30 May 2025AY 2015-16Partly Allowed

The Tribunal held that reassessment proceedings were validly initiated as the issue was not examined in the original assessment. It also ruled that disallowance under Section 14A is not warranted in the absence of exempt income, even if expenditure was incurred.

THE HARYANA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT,PANCHKULA vs DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE, PANCHKULA

ITA 592/CHANDI/2024[2016-17]Status: Disposed30 May 2025AY 2016-17Partly Allowed

The Tribunal held that reassessment proceedings were validly initiated as the issue was not examined in the original assessment. It also ruled that disallowance under Section 14A is not warranted in the absence of exempt income, even if expenditure was incurred.

THE HARYANA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT,PANCHKULA vs DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE, PANCHKULA

ITA 593/CHANDI/2024[2016-17]Status: Disposed30 May 2025AY 2016-17Partly Allowed

The Tribunal held that reassessment proceedings were validly initiated as the issue was not examined in the original assessment. It also ruled that disallowance under Section 14A is not warranted in the absence of exempt income, even if expenditure was incurred.

NISHANT GOYAL,CHANDIGARH vs INCOME TAX OFFICER, WARD 2(1), CHANDIGARH

ITA 1081/CHANDI/2024[2013-14]Status: Disposed30 May 2025AY 2013-14Remanded

The Tribunal held that the CIT(A) erred in dismissing the appeal without adjudicating on merits, despite the delay. The Tribunal emphasized the importance of natural justice and affording the assessee an opportunity to be heard.

INDER SINGH,LUDHIANA vs INCOME TAX OFFICER WARD-3(1), RISHI NAGAR LUDHIANA

ITA 65/CHANDI/2025[2017-18]Status: Disposed30 May 2025AY 2017-18Allowed

The Tribunal held that the assessee had demonstrated sufficient cash in hand, supported by the Cash Flow Statement and agricultural income. The lower authorities' addition was not justified as the AR could not rebut the factual aspect.

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, LUDHIANA , LUDHIANA vs ROSHA ALLOYS PVT. LTD., MANDI GOBINDGARH

ITA 923/CHANDI/2024[2020-21]Status: Disposed28 May 2025AY 2020-21Partly Allowed

The Tribunal quashed the reopening under Section 148 and the consequent assessment framed by the Assessing Officer for AY 2018-19, finding the approvals granted under Sections 148B and 151 to be invalid. This decision was based on the common facts and circumstances regarding the issuance of notice under Section 148 and the approvals granted. Consequently, the Tribunal dismissed the revenue's appeals concerning additions on account of unaccounted production based on average annual power consumption, following the decision for AY 2018-19. The appeals filed by the revenue were dismissed, and the appeals filed by the assessee were allowed. The Tribunal did not expressly leave any issue undecided.

ASSISTANT COMMISSIONER OF INCOME TAX, PANCHKULA CIRCLE, PANCHKULA, PANCHKULA vs VENUS REMEDIES LIMITED, CHANDIGARH

ITA 378/CHANDI/2024[2020-21]Status: Disposed28 May 2025AY 2020-21Dismissed

The Tribunal held that Section 28(iv) of the Income Tax Act, 1961 applies only to benefits or perquisites in kind, not in money. Since the loan waiver was in monetary terms, it did not attract Section 28(iv). The Revenue also failed to provide evidence for Section 41(1) applicability.

NID FOUNDATION,CHANDIGARH vs COMMISSIONER OF INCOME TAX (EXEMPTIONS), , CHANDIGARH

ITA 133/CHANDI/2025[2024-25]Status: Disposed28 May 2025AY 2024-25Partly Allowed

The Tribunal noted that the assessee was not given a proper opportunity to be heard due to defective service of the notice, relying on a Punjab & Haryana High Court judgment. The appeals were accordingly remanded back to the CIT(E) for fresh adjudication.

ACIT,CIRCLE--2(1), CHANDIGARH vs CSJ INFRASTRUCTURE PVT.LTD, CHANDIGARH

ITA 147/CHANDI/2020[2015-16]Status: Disposed28 May 2025AY 2015-16Partly Allowed

The Tribunal held that Section 43CA is applicable as the sale deed was registered during the relevant assessment year. However, it also considered the assessee's argument regarding the date of agreement and the proviso to Section 43CA(1) concerning the 10% variation.

GURKARTAR SINGH S/O TARSEM SINGH,PATIALA vs INCOME TAX OFFICER, WARD NABHA

ITA 1002/CHANDI/2024[2018-19]Status: Disposed28 May 2025AY 2018-19Allowed

The Tribunal held that the evidence produced, including the title deed, Tehsildar's certificate, and Jamabadi, clearly showed the assessee was the owner of the agricultural land and cultivated it. Therefore, the addition made by the AO and confirmed by the CIT(A) was not sustainable.

MOHAN SINGH,SAMANA vs INCOME TAX OFFICER WARD-1 BARNALA, BARNALA

ITA 1058/CHANDI/2024[2022-23]Status: Disposed28 May 2025AY 2022-23Remanded

The Tribunal condoned the delay in filing the appeal before the CIT(A) considering the facts and the affidavit. However, the Tribunal found that the CIT(A) had not passed a speaking order on merits, and therefore, remanded the case back to the CIT(A) for adjudication afresh.

MADHAV KRG LIMITED,PATIALA vs DCIT C C, PATIALA

ITA 291/CHANDI/2023[2018-19]Status: Disposed28 May 2025AY 2018-19Allowed

The Tribunal held that the addition was made solely on the basis of a statement recorded by the Investigation Wing, without providing the assessee an opportunity for cross-examination. Despite relevant documents and banking channel payments, the authorities doubted the purchases. The Tribunal found it illogical that purchases alleged to be bogus were accepted for production and sales. The invocation of Section 115BBE was also deemed not acceptable.

JARNAIL SINGH,PANCHKULA vs INCOME TAX OFFICER, WARD 3(5), CHANDIGARH

ITA 831/CHANDI/2024[2012-13]Status: Disposed28 May 2025AY 2012-13Partly Allowed

The Tribunal held that both the AO and CIT(A) failed to provide findings on merit and that the assessee was not given adequate opportunity of hearing. To ensure natural justice, the case was remanded back to the CIT(A) for fresh adjudication.

SH. SANJEEV GARG,PANCHKULA vs PR. C.I.T., PANCHKULA

ITA 365/CHANDI/2022[2017-18]Status: Disposed28 May 2025AY 2017-18Allowed

The Tribunal held that the CIT erred in invoking Section 263 as the AO did not exceed the limited scope of inquiry and the jurisdictional issue was not pressed by the assessee during assessment. The CIT's assumption of a complete scrutiny was based on incorrect facts.

NID FOUNDATION,CHANDIGARH vs COMMISSIONER OF INCOME TAX (EXEMPTIONS), , CHANDIGARH

ITA 134/CHANDI/2025[2024-25]Status: Disposed28 May 2025AY 2024-25Partly Allowed

The Tribunal noted that the assessee was not given a proper opportunity to be heard due to defective service of the notice, relying on a Punjab & Haryana High Court judgment. The appeals were accordingly remanded back to the CIT(E) for fresh adjudication.

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, LUDHIANA , LUDHIANA vs ROSHA ALLOYS PVT. LTD., MANDI GOBINDGARH

ITA 922/CHANDI/2024[2019-20]Status: Disposed28 May 2025AY 2019-20Partly Allowed

The Tribunal condoned the delay in filing the cross-objections for AY 2019-20 and 2020-21 in the interest of justice. For AY 2018-19, the Tribunal quashed the reopening under Section 148 and the consequent assessment framed by the AO, finding the approval granted by the PCIT under Section 151 and the Additional CIT under Section 148B to be common and based on the same arguments as presented in the assessee's appeal. Consequently, the appeals filed by the Revenue for AY 2018-19 were dismissed, and the appeals filed by the assessee were allowed. The Tribunal also held that the facts and circumstances regarding the issuance of notice under Section 148 and approvals under Section 151 and 148B were common across all assessment years. Therefore, following the decision for AY 2018-19, the reassessment proceedings were quashed. On merits, the Tribunal dismissed the Revenue's appeal concerning the deletion of additions on account of unaccounted production based on average annual power consumption, as the facts were similar to AY 2018-19. The Tribunal's ratio decidendi is that procedural defects in obtaining approvals for reassessment proceedings can vitiate the entire assessment.

FIDELITY INFORMATION SERVICES INDIA PRIVATE LIMITED,PUNJAB vs DEPUTY COMMISSIONER OF INCOME TAX, CHANDIGARH

ITA 998/CHANDI/2024[2020-21]Status: Disposed28 May 2025AY 2020-21Partly Allowed

The Tribunal decided on the issues as follows: 1. Regarding interest under Section 234A, the Tribunal noted that this issue was not adjudicated by the AO. Therefore, it set aside the issue to the file of the AO for verification and re-adjudication, allowing this ground of appeal for statistical purposes. 2. Concerning the initiation of penalty proceedings under Section 270A, the Tribunal held that this ground was premature at the current stage. The assessee would have an opportunity to explain why penalty should not be imposed and a separate remedy to appeal any penalty order. Thus, this ground was rejected. 3. On the disallowance of Foreign Travel Expenses, the Tribunal found that this issue was squarely covered in favour of the assessee by earlier orders of the ITAT for Assessment Years 2014-15, 2012-13, and 2011-12. The Tribunal noted that the expenses were part of the cost base on which a mark-up was charged to the AE, and the APA with the CBDT covered these international transactions. The Tribunal observed that the AO's action was in breach of the APA. Therefore, the disallowance was deleted. The ratio is that if foreign travel expenses are incurred in relation to business, recovered from an AE with a mark-up, and covered by an APA, they are allowable as per Section 37(1).

ACIT,CIRCLE--2(1), CHANDIGARH vs CSJ INFRASTRUCTURE PVT.LTD, CHANDIGARH

ITA 146/CHANDI/2020[2014-15]Status: Disposed28 May 2025AY 2014-15Partly Allowed

The Tribunal held that Section 43CA is applicable as the sale deed was registered during the relevant assessment year. However, it also considered the assessee's argument regarding the date of agreement and the proviso to Section 43CA(1) concerning the 10% variation.

ROSHA ALLOYS P LIMITED, AMLOH ROAD, VILLAGE TURAN, MANDI GOBINDGARH,PUNJAB vs DCIT CENTRAL CIRCLE 1, LUDHIANA, PUNJAB

ITA 888/CHANDI/2024[2018-2019]Status: Disposed28 May 2025AY 2018-2019Partly Allowed

The Tribunal held that the reopening under Section 148 and the consequent assessment framed by the Assessing Officer are quashed. This decision was based on the common facts and circumstances regarding the issuance of notice under Section 148 and the approvals granted under Section 151 and Section 148B, which were found to be flawed. The Tribunal found that a single approval order for multiple assessment years (2018-19 to 2020-21) and other procedural irregularities rendered the reassessment proceedings void ab initio. Consequently, the appeals filed by the Revenue challenging the deletions made by the CIT(A) on merits were dismissed. The Tribunal also dismissed the Revenue's appeal concerning the deletion of additions on account of unaccounted production based on average annual power consumption, following its finding for AY 2018-19. The ratio decidendi is that procedural defects in obtaining statutory approvals for reassessment proceedings vitiate the entire assessment, rendering it liable to be quashed.

CSJ INFRASTRUCTURE PVT.LTD,CHANDIGARH vs ACIT,CIRCLE--2(1), CHANDIGARH

ITA 131/CHANDI/2020[2014-15]Status: Disposed28 May 2025AY 2014-15Partly Allowed

The Tribunal held that Section 43CA is applicable as the sale deed was registered during the relevant assessment year. However, it also considered the assessee's argument regarding the date of agreement and the proviso to Section 43CA(1) concerning the 10% variation.

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, LUDHIANA , LUDHIANA vs ROSHA ALLOYS PVT. LTD., MANDI GOBINDGARH

ITA 921/CHANDI/2024[2018-19]Status: Disposed28 May 2025AY 2018-19Allowed

The Tribunal quashed the reopening under Section 148 and the consequent assessment framed by the AO for AY 2018-19, holding that the approval for reopening was illegal and unsustainable. This decision was based on the finding that a single approval order was issued for multiple assessment years and that there were material discrepancies indicating a lack of proper application of mind by the approving authority, as per the assessee's arguments and the cited precedent. Consequently, the reassessment proceedings were vitiated. For the subsequent assessment years (2019-20 and 2020-21), the Tribunal condoned the delay in filing the assessee's cross-objections. Following the decision for AY 2018-19, the Tribunal also quashed the reopening and assessment for these years. On merits, the Tribunal dismissed the Revenue's appeals concerning the deletion of additions on account of unaccounted production and suppressed sales, upholding the CIT(A)'s decision to consider average annual power consumption. The appeals filed by the Revenue were dismissed, and the appeals filed by the assessee were allowed.

CSJ INFRASTRUCTURE PVT.LTD,CHANDIGARH vs ACIT,CIRCLE--2(1), CHANDIGARH

ITA 132/CHANDI/2020[2015-16]Status: Disposed28 May 2025AY 2015-16Partly Allowed

The Tribunal held that Section 43CA is applicable as the sale deed was registered during the relevant assessment year. However, it also considered the assessee's argument regarding the date of agreement and the proviso to Section 43CA(1) concerning the 10% variation.

M/S APEX BUILDERS, LUDHIANA vs ITO, W-2(1), LUDHIANA

ITA 1284/CHANDI/2018[2012-13]Status: Disposed28 May 2025AY 2012-13Partly Allowed

The Tribunal upheld the disallowance of cash purchases exceeding limits under Section 40A(3) due to the amended provisions and lack of exceptions. However, it directed the deletion of disallowance for unverified cash expenses, finding that the assessee had provided sufficient documentary evidence.

SH. NISHANT KUMAR,MANDI DABWALI vs ITO, WARD 2, SIRSA

ITA 673/CHANDI/2022[2016-17]Status: Disposed27 May 2025AY 2016-17Partly Allowed

The Tribunal condoned the delay and restored the matter to the CIT(A) for fresh adjudication de novo, emphasizing the interest of natural justice and fair play.

STAR BIOTECH,PANCHKULA vs INCOME TAX OFFICER, WARD- PARWANOO, HIMACHAL PRADESH

ITA 700/CHANDI/2024[2013-14]Status: Disposed27 May 2025AY 2013-14Partly Allowed

The Tribunal held that the delay was due to bonafide reasons, lack of communication, and service defects, not deliberate conduct. The CIT(A)'s ex parte order was set aside, and the matter was restored for de novo adjudication.

SRI GURU TEG BAHADUR PUBLIC SCHOOL,PATIALA vs PCIT- PATIALA, PATIALA

ITA 482/CHANDI/2024[2017-18]Status: Disposed27 May 2025AY 2017-18Allowed

The Tribunal held that the assessment order was invalid as the Sri Guru Teg Bahadur Public School was part of the B.N. Khalsa Trust, a fact accepted in previous years. The PCIT's order under Section 263 was therefore void ab initio.

RANBIR SINGH,HARYANA vs WARD-2, AMBALA, RANGE CODE-65, AO NUMBER-94, JURISDICTIONAL ASSESSING OFFICER, HARYANA

ITA 851/CHANDI/2024[2021-2022]Status: Disposed27 May 2025AY 2021-2022Dismissed

The Tribunal held that the issue of late payment of PF and ESI has been settled by the Supreme Court in the case of M/s Checkmate Services Pvt. Ltd. vs. CIT. Therefore, there is no scope for further interpretation, and the appeal is dismissed.

SJVN FOUNDATION,SHANAN MALYANA vs CIT(EXEMPTIONS), CHANDIGARH

ITA 1057/CHANDI/2024[2024-25]Status: Disposed27 May 2025AY 2024-25Partly Allowed

The Tribunal held that the rejection of the application solely on the ground of selecting a wrong clause, without providing an opportunity to rectify, is not sustainable. Following judicial precedents, procedural defects are curable.

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 3, LUDHIANA, LUDHIANA vs LEEFORD HEALTHCARE LTD., PUNJAB, LUDHIANA

ITA 551/CHANDI/2024[2018-19]Status: Disposed27 May 2025AY 2018-19Dismissed

The Tribunal upheld the CIT(A)'s decision to reduce the penalty on cash to 30% and delete the penalty on property investments, as these did not fall under the definition of 'undisclosed income' for penalty purposes. The department's appeals were dismissed.

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 3, LUDHIANA, PUNJAB, LUDHIANA vs AMIT KUMAR, LUDHIANA

ITA 549/CHANDI/2024[2018-19]Status: Disposed27 May 2025AY 2018-19Dismissed

The Tribunal upheld the CIT(A)'s decision to reduce the penalty on cash to 30% and delete the penalty on property investments, as these did not fall under the definition of 'undisclosed income' for penalty purposes. The department's appeals were dismissed.

HARYANA STATE REMOTE SENSING APPLICATION CENTRE,HISSAR vs DCIT (EXEMPTIONS), CHANDIGARH

ITA 354/CHANDI/2022[2017-18]Status: Disposed26 May 2025AY 2017-18Allowed

The Tribunal held that the CIT(E) failed to demonstrate that the assessment order was erroneous or prejudicial to the revenue. The AO had conducted proper inquiry, and the assessee fulfilled the conditions of Section 10(23C)(iiiab) regarding educational purposes and substantial government funding.

BANGA HOSPITALS PRIVATE LIMITED,MANDI vs ITO, MANDI

ITA 202/CHANDI/2024[2017-2018]Status: Disposed26 May 2025AY 2017-2018Partly Allowed

The Tribunal found that the assessee had provided substantial documentary evidence for a portion of the unexplained investments, establishing a nexus with identifiable sources. However, a part of the amount remained unexplained due to lack of proper fund trail.

TYNOR ORTHOTICS PRIVATE LIMITED,MOHALI vs ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE 6(1), MOHALI, MOHALI

ITA 1032/CHANDI/2024[2017-18]Status: Disposed26 May 2025AY 2017-18Partly Allowed

The Tribunal held that the CIT(A)'s finding regarding the salary payment being revenue neutral was correct, and thus the related ground should have been allowed. The Tribunal also noted that other grounds adjudicated by the CIT(A) were irrelevant to the assessee.

SH. CHATTAR SINGH TOMAR,PAONTA SAHIB vs ITO , NAHAN

ITA 51/CHANDI/2008[2002-03]Status: Disposed23 May 2025AY 2002-03Partly Allowed

The Tribunal found contradictions in its previous order regarding limestone sale prices and directed recalculation based on specific rates for certain assessment years. It also noted that the assessee's plea regarding cross-examination for commission income had been overlooked.

SH. CHATTAR SINGH TOMAR,PAONTA SAHIB vs ITO , NAHAN

ITA 52/CHANDI/2008[2003-04]Status: Disposed23 May 2025AY 2003-04Partly Allowed

The Tribunal found contradictions in its previous order regarding limestone sale prices and directed recalculation based on specific rates for certain assessment years. It also noted that the assessee's plea regarding cross-examination for commission income had been overlooked.