M/s. Mahavir Spinning Mills v. CIT

Mata Bala Sundri Rice Mill, Village Kanipla, District Yamuna Nagar vs. Income Tax Officer-Ward-3, Yamuna Nagar, Yamunagar

In the result, appeal of the assessee is allowed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 906/Chd/2025 "नधा"रण वष" / Assessment Year: 2013-14 Mata Bala Sundri Rice Mill, The Ito, C/O Jagdamba Rice & General Mills, Vs Ward-3, Village-Kanipla, Po-Sarawan, Yamuna Nagar. Yamuna Nagar. "थायी लेखा सं./Pan No: Aatfm9813G अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Dhruv Goel, Ca Revenue By : Dr. Ranjit Kaur, Addl. Cit Sr.Dr Date Of Hearing : 12.02.2026 Date Of Pronouncement : 20.02.2026

…आयकर अपील"य अ"धकरण,च"डीगढ़ "यायपीठ, च"डीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL DIVISION BENCH, ‘B’ CHANDIGARH BEFORE SHRI RAJPAL YADAV, VICE PRESIDENT AND SHRI MANOJ KUMAR AGGARWAL, ACCOUNTANT MEMBER आयकर अपील सं./ ITA No. 906/CHD/2025 "नधा"रण वष" / Assessment Year: 2013-14 Mata Bala Sundri Rice Mill, The ITO, C/o Jagdamba Rice & General Mills, Vs Ward-3, Village-Kanipla, PO-Sarawan, Yamuna Nagar. Yamuna Nagar. "थायी लेखा सं./PAN NO: AATFM9813G अपीलाथ"/Appellant ""यथ"/Respondent Assessee by : Shri Dhruv Goel, CA Revenue by : Dr. Ranjit Kaur, Addl. CIT Sr.DR Date of Hearing : 12.02.2026 Date of Pronouncement…

Sudarshan Jeans Private Limited, Kolhapur vs. ITO, Ambala

The appeal stand allowed

Bench: SHRI LALIET KUMAR (Judicial Member), SHRI MANOJ KUMAR AGGARWAL (Accountant Member)

…ll material facts necessary for his assessment for that assessment year. When the assessee has disclosed all material facts, the reopening could not be sustained in law as held by jurisdictional Punjab & Haryana High Court in the case of Duli Chand Singhania (269 ITR 192). In this decision, the Hon’ble Court has held that in order to assume jurisdiction u/s 147 in a case where assessment has been made u/s 143(3), certain conditions are required to be satisfied viz. (i) Assessing Officer must have reason to believe that income chargeable to tax has escaped assessment, and (ii) he must also have reason to believe…

Baldev Singh, Village Jandli, Ambala vs. Income Tax Officer Ward-3, Ambala, Ambala Cantt

The appeal stand allowed

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.889/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2007-08) Shri Teja Singh Income Tax Officer C/O Rajiv Goel & Associates Ward-4 बनाम/ Vs. 179, Bank Road, Ambala Cantt. Ambala Cantt. Ambala (Haryana)-133 001 Haryana – 133 001 "थायी लेखा सं./जीआइआरसं./Pan/Gir No. Bqzps-3706-B (अपीलाथ"/Appellant) (""थ" / Respondent) : & 2. आयकर अपील सं. / Ita No.891/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2007-08) Shri Baldev Singh Income Tax Officer C/O Rajiv Goel & Associates Ward-3 बनाम/ Vs. 179, Bank Road, Ambala Cantt. Ambala Cantt. Ambala (Haryana)-133 001 Haryana – 133 001 "थायी लेखा सं./जीआइआरसं./Pan/Gir No. Brzps-4850-H (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ" कीओरसे/ Appellant By : Shri Rohit Goel (Ca) – Ld. Ar ""थ"कीओरसे/Respondent By : Dr. Ranjit Kaur (Addl. Cit) - Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 18-11-2025 घोषणाकीतारीख /Date Of Pronouncement : 10-12-2025

…facts necessary for his assessment for that assessment year. In the absence of such an allegation as mandated under statute, the reopening could not be sustained in law as held by jurisdictional Punjab & Haryana High Court in the case of Duli Chand Singhania (269 ITR 192). In this decision, the Hon’ble Court has held that in order to assume jurisdiction u/s 147 in a case where assessment has been made u/s 143(3), certain conditions are required to be satisfied viz. (i) Assessing Officer must have reason to believe that income chargeable to tax has escaped assessment, and (ii) he must also have reason to believe t…

Teja Singh, Ambala vs. Income Tax Officer, Ward-4, Ambala Cantt, Ambala

The appeal stand allowed

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.889/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2007-08) Shri Teja Singh Income Tax Officer C/O Rajiv Goel & Associates Ward-4 बनाम/ Vs. 179, Bank Road, Ambala Cantt. Ambala Cantt. Ambala (Haryana)-133 001 Haryana – 133 001 "थायी लेखा सं./जीआइआरसं./Pan/Gir No. Bqzps-3706-B (अपीलाथ"/Appellant) (""थ" / Respondent) : & 2. आयकर अपील सं. / Ita No.891/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2007-08) Shri Baldev Singh Income Tax Officer C/O Rajiv Goel & Associates Ward-3 बनाम/ Vs. 179, Bank Road, Ambala Cantt. Ambala Cantt. Ambala (Haryana)-133 001 Haryana – 133 001 "थायी लेखा सं./जीआइआरसं./Pan/Gir No. Brzps-4850-H (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ" कीओरसे/ Appellant By : Shri Rohit Goel (Ca) – Ld. Ar ""थ"कीओरसे/Respondent By : Dr. Ranjit Kaur (Addl. Cit) - Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 18-11-2025 घोषणाकीतारीख /Date Of Pronouncement : 10-12-2025

…facts necessary for his assessment for that assessment year. In the absence of such an allegation as mandated under statute, the reopening could not be sustained in law as held by jurisdictional Punjab & Haryana High Court in the case of Duli Chand Singhania (269 ITR 192). In this decision, the Hon’ble Court has held that in order to assume jurisdiction u/s 147 in a case where assessment has been made u/s 143(3), certain conditions are required to be satisfied viz. (i) Assessing Officer must have reason to believe that income chargeable to tax has escaped assessment, and (ii) he must also have reason to believe t…

Deputy Commissioner of Income Tax, Chandigarh vs. Winsome Textile Industries Ltd, Chandigarh

…uly disclosed in the profit and loss account and balance sheet there being no failure to disclose truly all material facts, the pre- sent reassessment proceedings are bad in law in terms of the ratio of the following judgments: a) Dulichand Singhania Vs. ACIT 269 ITR 192. b) Winsome Textile Industries Vs. Union of India 278 ITR 470. c) Navkar share and stock brokers Vs. ACIT 390 ITR 362 & d) Haryana Acrylics Manufacturing company Vs. CIT 308 ITR 38 ii) That it is relevant to point out that after initiation of the reassessment proceedings, a notice was issued U/s 142(1) was issued on 4th July, 2018 asking the unde…

Winsome Textile Industries Limited, Chandigarh vs. Asstt. Commissioner of Income Tax, Circle-4(1), Chandigarh

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

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

…uly disclosed in the profit and loss account and balance sheet there being no failure to disclose truly all material facts, the pre- sent reassessment proceedings are bad in law in terms of the ratio of the following judgments: a) Dulichand Singhania Vs. ACIT 269 ITR 192. b) Winsome Textile Industries Vs. Union of India 278 ITR 470. c) Navkar share and stock brokers Vs. ACIT 390 ITR 362 & d) Haryana Acrylics Manufacturing company Vs. CIT 308 ITR 38 ii) That it is relevant to point out that after initiation of the reassessment proceedings, a notice was issued U/s 142(1) was issued on 4th July, 2018 asking the unde…

Society for Education and Research, Jagadhri, Yamunangar vs. DCIT(E) (Circle-2), Chandigarh

In the result, ground no. 2 of the assessee’s appeal is allowed

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

…urisdictional defect and on this ground as well, the initiation of reassessment proceedings deserves to be set aside and in support reliance was placed on the decision of Hon’ble Punjab & Haryana High Court in case of Duli Chand Singhania Vs. Asst. CIT (2004) 269 ITR 192. 8. Per contra, the Ld. DR submitted that the AO was in receipt of non- PAN AIR information that the assessee had deposited cash amounting to Rs. 34,50,350/- in his bank account maintained with Punjab National Bank, Jagdholi, Yamuna Nagar. Further, the AO also referred to the information available in the AST Portal and wherein it was found that n…