SMT. SATYAWATI MARWAHA THROUGH LEGAL HEIR SH. CHANDER SHEIKHAR MARWAHA,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeal for Asstt

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

reopen assessment, though wide, are not plenary-Interest allowed as deduction in original assessment subsequently ITO found that creditors were name-lenders-Confession from creditors There was nothing to show that the confession related to a loan advanced to assessee-The live link or close nexus between material before ITO and belief he was to form regarding escapement of income

M/S CITI PLAZA,JALANDHAR vs. INCOME TAX OFFICER , WARD 3(1), JALANDHAR

In the result, the appeal of the assessee bearing ITA No

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

reopening of case for another year, while deciding an appeal before him. 5. That the long-term capital gain of Rs.1,70,00,000/-, by assuming the sale price of 'Citi Plaza' building at Rs.4 crores, based on a fake and unproved document, against the actual sale price of Rs.2,30,00,000/-, has wrongly been assessed

SHRI ARNESH KUMAR SHAKAR EX. MLA,HOSHIARPUR vs. INCOME TAX OFFICER WARD, DASUYA

In the result, appeal of the assessee ITA No

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

reopening of the assessment u/s 148. The relevant paragraph of the assessment order was read out and is reproduced as below: “As per the direction of the Ld. Commissioner of Income Tax (Appeals)-1, Jalandhar, the proceedings u/s 147/148 were initiated against the assessee. The notice u/s 148 of the Income Tax Act, 1961, dated 17.03.2017 was issued

SHRI SUKHEV SINGH ,BATHINDA vs. INCOME TAX OFFICER, WARD 1(2), BATHINDA

In the result, the appeal of the assessee is allowed for statistical purpose

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

reopening before the AO and that nature of capital for capital gains being claimed as 7 Sukhdev Singh v. ITO agricultural land etc. after considering the written submission of the assesse

INCOME TAX OFFICER, WARD-1, FARIDKOT, BSNL BUILDING vs. M/S VOHRA SOLVEX PVT. LTD, SADIQ ROAD

In the result, C.O. filed by the assessee is allowed

Bench: Sh. Udayan Dasgupta & Sh. Krinwant Sahay

capital gain on sale of shares an basis of statement of entry operators recorded on various dates in some other proceedings not connected with assessee and no opportunity to cross-examine so- called entry providers was given to assessee thereby violating principles of natural Justice, Tribunal was Justified in deleting addition made by Assessing Officer" [2023] 157 taxmann.com

INCOME TAX OFFICER WARD -2 (1), AMRITSAR vs. MS. SAVITA BANSAL, THROUGH LEGAL HEIR SH. PARVEEN KUMAR BANSAL, AMRITSAR

In the result, the revenue’s appeal stands dismissed

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Udayan Das Gupta, Jm 1. आयकर अपील सं. / Ita No. 240/Asr/2023 (िनधा"रण वष" / Assessment Year: 2016-17) Income Tax Officer Smt. Savita Bansal Ward-2(1) बनाम/ (Through L/H Shri Parveen Kumar Bansal) Amritsar 143001 H.No. 272, Green Avenue Vs. Amritsar-143001. "थायीलेखासं./Pan. Abmpb-3594-K (Assessee) / Acnpk-4131-D (Lh) (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. Cross Objection No. 1/Amritsar/2024 (In Ita No. 240/Asr/2023) (िनधा"रण वष" / Assessment Year: 2016-17) Smt. Savita Bansal Income Tax Officer बनाम/ (Through L/H Shri Parveen Kumar Bansal) Ward-2(1) H.No. 272, Green Avenue Amritsar 143001 Vs. Amritsar-143001. "थायीलेखासं./Pan. Abmpb-3594-K (Assessee) / Acnpk-4131-D (Lh) (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/Appellant By : Dr Rakesh Gupta (Advocate) –Ld. Ar ""थ"कीओरसे/Respondent By : Shri B. Srinivas Kumar (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 10-07-2025 घोषणाकीतारीख /Date Of Pronouncement : 21-08-2025 आदेश / O R D E R Manoj Kumar Aggarwal () Aforesaid Appeal By Revenue For Assessment Year (Ay) 2016- 1. 17 Arises Out Of An Order Of Ld. Commissioner Of Income Tax

capital gains. Accordingly, a show-cause notice was issued. The Ld. AO observed that there was abnormal increase in the price of the scrips which could be possible only if the prices were rigged. In the absence of any rebuttal as forthcoming from the assessee, the LTCG so earned for Rs.482.86 Lacs & claimed exempt u/s 10(38) was considered

SHRI GURKHA SINGH ALIAS JOGINDER SINGH ,BATHINDA vs. INCOME TAX OFFIER WARD 1(1), BATHINDA

In the result, the appeal of the assessee bearing ITA No

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjeei.T.A. No.145/Asr/2018 Assessment Year: 2009-10

reopening of the case as well as re-assessment in individual status is liable to be quashed. 3. That the sale of agricultural land in question is not liable to long term capital gain

M/S BLUE CITY TOWNSHIP & COLONIZERS,AMRITSAR. vs. THE INCOME TAX OFFICER,, AMRITSAR.

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Capital Gains' as income of the previous year when the transfer took place, i.e., 1964. Therefore, the assessee was liable to pay additional tax on the income that escaped assessment.” 13. Per contra, the ld. Addl. CIT-DR submitted that it was a case of deemed escapement of income as per clause (b) to (Explanation

ASSISTANT COMMISSIONER OF INCOME TAX (CENTRAL CIRCLE), JAMMU vs. ANITA KAPAHI, JAMMU

In the result, the appeal of the revenue is dismissed being devoid of merits

Bench: Sh. Udayan Dasgupta & Sh. Krinwant Sahay

capital gains , which was ultimately assessed , with an addition of Rs.2.05 cores u/s 69 of the Act, on the basis of suspicion of alleged on money payment relating to purchase of a plot of land , information flowing from impounded document Annexure A – 3. 4. The assessee’s husband Mr. Anil Kapahi and her two sons Mr. Akhil Kapahi

M/S. SATIA INDUSTRIES LIMITED,MUKTSAR vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1, BATHINDA

In the result, the appeal of the assessee bearing ITA No

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

gains from these REC/ESCs in India contain to right to transfer it. These credits have no other value. It must be emphasized if there is no carrying on of the business there are no RECs/ESCs The question of savings to emission arises only in to I.T.A. No.193/Asr/2022 23 Assessment Year: 2018-19 course of the business. The REC/ESCs

SHRI BHUPINDER SINGH ( PROP) THE NEST HOTELS & MOTELS,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-3, JALANDHAR

In the result, the appeal of the assessee bearing ITA No

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

assessment year was reopened u/s 148 for non-showing of Capital Gains in respect of same property and where the explanation

SHRI JASPREERT SINGH S/O SHRI SURJIT SINGH,JALANDHAR vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1, JALANDHAR

In the result, the appeal of the assessee bearing ITA No

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjeei.T.A. No.58/Asr/2023 Assessment Year: 2012-13

capital gain. The ld. AO completed the assessment with the addition amount of Rs.2 lacs for land expenses and Rs.2 lacs for commission payment. Aggrieved assessee filed an appeal before the ld. CIT(A). The ld. CIT(A) upheld the order of the ld. AO, after adjudicating both the legal and factual ground. Aggrieved the assessee filed the appeal before

SHRI NIRVAIR SINGH,AMRITSAR vs. INCOME TAX OFFICER WARD-4(3), AMRITSAR

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

assessment u/s 148 as the case was opened for reasons recorded evasion of capital gain whereas additions are made on altogether different grounds.” 4. Brief facts emerging from the records are that proceedings for this year was reopened

SHRI SATBIR SINGH BHULLAR,AMRITSAR vs. INCOME TAX OFFICER WARD- 5 (4), AMRITSAR

In the result, the appeal of the assessee bearing ITA No

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

reopened u/s 148 for AY 2008-09on the basis of AIR information available with the department that the assessee has deposited cash to the tune of Rs 1046000/- in ICICI Bank account no 006601529228. However, the Ld. AO has made the addition to the tune of Rs 737948/- by relying upon the peak. Please refer page

SMT. SATVIR KAUR W/O SH. SHINDER SINGH,FEROZEPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX-1, AMRITSAR

In the result, the appeal of the assessee is allowed

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

reopened on the reasons that the assessee had deposited cash of Rs. 60,00,000 in her saving bank account maintained with the Oriental Bank of Commerce during the financial year 2010-11 and that no voluntary return has been filed for the year under consideration. Thus, it was incumbent on the Assessing Officer to examine and inquire into

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-3, SRINAGAR vs. M/S TRUMBO CEMENT INDUSTRIES PRIVATE LIMITED, SRINAGAR

In the result, the Ground no-1 of the Revenue for ITA No

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Capital Gain or Loss from the sale transaction of the land I.T.A. No.123/Asr/2020 11 I.T.A. No.124/Asr/2020 by the Directors, had to be examined by the A.O, in their returns or by reopening of the assessments

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-3, SRINAGAR vs. M/S TRUMBO CEMENT INDUSTRIES PRIVATE LIMITED , SRINAGAR

In the result, the Ground no-1 of the Revenue for ITA No

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Capital Gain or Loss from the sale transaction of the land I.T.A. No.123/Asr/2020 11 I.T.A. No.124/Asr/2020 by the Directors, had to be examined by the A.O, in their returns or by reopening of the assessments

THE DY. COMMISSIONER OF INCOME TAX, AMRITSAR. vs. SH. JAIMAL SINGH, L/H. SH. PREM CHAND,, TARN TARAN

In the result, the appeal bearing ITA No

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

reopened. Thereafter, the assessment was completed with addition amount of Rs.1,61,43,719/- and Rs.4,29,431/- which works out total amount of Rs.1,75,73,150/- related to deposit in bank from unexplained source. The addition was framed u/s 69C of the Act. Aggrieved assessee filed an appeal before the ld. CIT(A). The ld. CIT(A) allowed

INCOME TAX OFFICER, WARD-3(1),FEROZEPUR, FEROZEPUR vs. MS.JATIN AGRO, FORT ROAD

In the result, the appeal of the revenue is dismissed

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta(Physical Hearing) I.T.A. No. 103 & 104/Asr/2024 Assessment Years: 2014-15 & 2017-18 Ito, Ward-3(1), Vs. M/S Jatin Agro Fort Road, Ferozepur. 152-P, Ferozepur. [Pan:-Aarpm5393F] (Appellant) (Respondent) Sh. Ashray Sarna, Ca Appellant By Respondent By Sh. Sunil Gautam, Cit. Dr

reopened u/s 148 vide notice dated 29.03.2019 (after necessary approval from higher authorities), mainly on the issue regarding availability of deduction claimed u/s 35AD(8)(c)(ii) of the Act. I.T.A. No. 103 & 104/Asr/202 Assessment Years: 2014-15 and 2017-18 4 The relevant portion of the recorded reasons are reproduced below for ready reference: “2. The assessee has constructed