SMT. INDERMEET BAINS W/O SH. D.S. BAINS,BATHINDA vs. PR. COMMISSIONER OF INCOME TAX , BATHINDA

The appeal of the assessee is disposed of in the term indicated as above

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

vi). CIT vs. Hindustan Marketing & Advertising Co. Ltd. 341 ITR 180 Delhi-HC vii). Commissioner of Income Tax vs. Anil Kumar Sharma 335 ITR 180 Delhi- HC. 7. Further, the Ld. Counsel of the assessee relied upon on the judgment of Hon’ble Bombay Court, in the case of ‘Sh. Nirav Modi’ reported in 71 Taxmann.com 273, wherein the order

SHRI NAROTAM SINGH,MANSA vs. INCOME TAX OFFICER WARD -1(4), MANSA

In the result, both the appeals of the assessees are allowed

vi) Decision of ITAT, Delhi Bench, in the case of Electra (Jaipur)(P) Ltd. Vs. Inspecting Assistant Commissioner reported in 26 ITR 236 in which it was held as under: “ Appeal CIT(A)- Additional evidence – Admissibility – if the evidence is genuine, reliable and proves the assessee’s case, assessee should not be denied the opportunity to adduce it.” (vii) Decision

SHRI TARLOCHAN SINGH,MANSA vs. INCOME TAX OFFICER WARD-1(4), MANSA

In the result, both the appeals of the assessees are allowed

vi) Decision of ITAT, Delhi Bench, in the case of Electra (Jaipur)(P) Ltd. Vs. Inspecting Assistant Commissioner reported in 26 ITR 236 in which it was held as under: “ Appeal CIT(A)- Additional evidence – Admissibility – if the evidence is genuine, reliable and proves the assessee’s case, assessee should not be denied the opportunity to adduce it.” (vii) Decision

THE DHAMAI COOPERATIVE AGRICULTURE SERVICE SOCIETY LIMITED,HOSHIARPUR vs. INCOME TAX OFFICER , HOSHIARPUR

In the result, the appeals filed by the appellant are allowed and the order(s) of the Kerala High Court and other authorities to the contrary are set aside

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjeei.T.A. No.273/Asr/2023 Assessment Year: 2017-18

24,63,842 52,086 Jalandhar Central Coop. Bank, Rama Mandi, Jalandhar The Citizen 1,29,123 8982 - urban Coop. Bank Ltd., Jalandhar Interest from 2,68,544 members Total 36,26,039/- 61,068/- 2,68,544/- Thus, it is clear that the assessee has parked its surplus/idle funds with the aforesaid banks and is earning huge interest income

M/S STEP BY STEP JUNIOR SCHOOL SOCIETY,AMRITSAR. vs. COMMISSIONER OF INCOME TAX (EXEMPTION), CHANDIGARH

Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meena

gains of business, unless the business is incidental to the attainment of its objectives and separate books of account are maintained by it in respect of such business: Provided also that any 80[notification issued by the Central Government under sub-clause (iv) or sub-clause (v), before the date on which the Taxation Laws (Amendment) Bill, 2006 receives

SHRI JASBIR SINGH ,JALANDHAR vs. INCOME TAX OFFICER,WARD-I (2), JALANDHAR

In the result, the appeal of the assessee is allowed

Bench: Shri N.K. Choudhry, Jm & Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.426/Asr/2018 ("नधा"रणवष" / Assessment Year: 2011-12)

24 sq. ft. situated at 296, Lajpat Nagar, Jalandhar vide registered sale deed No. 6,300 dated 20.10.2010. The property was sold to M/s Sirjon construction Pvt. Ltd through its director Sh. Rishikesh Upadyaya S/o Sh. Girish Ram Upadyaya R/o 10, Green Field Kapurthala Road, Jalandhar. The property was sold for Rs.1,21,00,000/- whereas value as per stamp

SH. SANTOKH SINGH BRAR,MOGA vs. ITO, WARD - 2,, MOGA

Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meena

vi) From the inspection of the documents in the possession of the Ld. Assessing Officer, officially allowed by him as per the request of the assesses, we have not found any document either in original or a photocopy signed by the assesses or any GPA document relating to the assesses, which is now also being relied upon by Your Honour

SH. GURBACHAN SINGH BRAR,MOGA vs. ITO, WARD - 1,, MOGA

Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meena

vi) From the inspection of the documents in the possession of the Ld. Assessing Officer, officially allowed by him as per the request of the assesses, we have not found any document either in original or a photocopy signed by the assesses or any GPA document relating to the assesses, which is now also being relied upon by Your Honour

THE DHAMAI COOPERATIVE AGRICULTURE SERVICE SOCIETY LIMITED,HOSHIARPUR vs. INCOME TAX OFFICER WARD, HOSHIARPUR

In the result, appeal of the assessee ITA No

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjeei.T.A. No.238/Asr/2023 Assessment Year: 2020-21

24,63,842 52,086 Jalandhar Central Coop. Bank, Rama Mandi, Jalandhar The Citizen 1,29,123 8982 - urban Coop. Bank Ltd., Jalandhar Interest from 2,68,544 members Total 36,26,039/- 61,068/- 2,68,544/- Thus, it is clear that the assessee has parked its surplus/idle funds with the aforesaid banks and is earning huge interest income

THE KOT RAM DASS COOP. THIRFT & CREDIT SOCIETY LIMITED,JALANDHAR vs. INCOME TAX OFFICER WARD-2 (4), JALANDHAR

In the result, appeal of the assessee ITA No

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjeei.T.A. No.86/Asr/2021 Assessment Year: 2017-18

24,63,842 52,086 Central Coop. Bank, Rama Mandi, Jalandhar The Citizen 1,29,123 8982 - urban Coop. Bank Ltd., Jalandhar Interest from 2,68,544 members Total 36,26,039/- 61,068/- 2,68,544/- Thus, it is clear that the assessee has parked its surplus/idle funds with the aforesaid banks and is earning huge interest income

THE INCOME TAX OFFICER, AMRITSAR. vs. M/S BHAGAT INDUSTRIAL CORPORATION LTD.,, AMRITSAR.

The appeal of the Revenue is allowed for statistical purposes and CO is also allowed for statistical purposes

Bench: Sh. Laliet Kumar & Dr. M. L. Meena

24 of the Paper-Book filed by the assessee dated 26.09.2016) describes Lord Properties as under- “ Lord Properties Pvt Ltd is a company incorporated under the laws of India, having its registered office at 54, Janpath, New Delhi ( hereinafter referred to as “ LPPL” which term shall unless the context otherwise requires include its successors in interest and permitted assigns) through

M/S SHANKAR RICE & GENERAL MILLS ,MOGA vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE, MOGA

In the result, the appeal of the assessee is dismissed

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

capital gains, nor is it income from ’other sources' because the provisions of sections 69, 69A, 69B and 69C treat unexplained investments, unexplained money, bullion, etc., and unexplained expenditure as deemed income where the nature and source of investment, acquisition or expenditure, as the case may be, have not been explained or satisfactorily explained. Therefore, in these cases, the source

SMT. GURJEET KAUR,JALANDHAR vs. INCOME TAX OFFICER, WARD- IV (2),, JALANDHAR

The appeal of the assessee is allowed in terms of our

Bench: Sh. Ravish Sood & Dr. M. L. Meena

section (4A) of Sec. 132 of the Act. As is discernible from the records, we find that the A.O in his ‘remand report’ that was filed in the course of the proceedings before the CIT(A), had fairly admitted that he had only received a copy of the “agreement to sell”, dated 25.02.2008 from the Dy. DIT (Inv.), Ludhiana

SMT. GURJEET KAUR,JALANDHAR vs. INCOME TAX OFFICER, WARD- IV (2),, JALANDHAR

The appeal of the assessee is allowed in terms of our

Bench: Sh. Ravish Sood & Dr. M. L. Meena

section (4A) of Sec. 132 of the Act. As is discernible from the records, we find that the A.O in his ‘remand report’ that was filed in the course of the proceedings before the CIT(A), had fairly admitted that he had only received a copy of the “agreement to sell”, dated 25.02.2008 from the Dy. DIT (Inv.), Ludhiana

THE ASSTT. COMMISSIONER OF INCOME TAX, JALANDHAR vs. M/S BROADWAY OVERSEAS LTD., JALANDHAR

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

capital adjusted margin of the comparables, then additional imputation of interest on the outstanding 15 I.T.A. Nos. 477 & CO 32/Asr/2015 & Ors Asstt. CIT v. Broadways Overseas Ltd. & Ors receivables is not warranted. Respectfully following the judgment of the Honourable ITAT, Mumbai and Honourable ITAT, Delhi, I also delete the addition of Rs76,45,292/- made by the Assessing Officer

THE ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR vs. M/S BROADWAYS OVERSEAS LTD, JALANDHAR

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

capital adjusted margin of the comparables, then additional imputation of interest on the outstanding 15 I.T.A. Nos. 477 & CO 32/Asr/2015 & Ors Asstt. CIT v. Broadways Overseas Ltd. & Ors receivables is not warranted. Respectfully following the judgment of the Honourable ITAT, Mumbai and Honourable ITAT, Delhi, I also delete the addition of Rs76,45,292/- made by the Assessing Officer

THE ASSTT. COMMISSIONER OF INCOME TAX, JALANDHAR vs. M/S BROADWAYS OVERSEAS LTD, JALANDHAR

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

capital adjusted margin of the comparables, then additional imputation of interest on the outstanding 15 I.T.A. Nos. 477 & CO 32/Asr/2015 & Ors Asstt. CIT v. Broadways Overseas Ltd. & Ors receivables is not warranted. Respectfully following the judgment of the Honourable ITAT, Mumbai and Honourable ITAT, Delhi, I also delete the addition of Rs76,45,292/- made by the Assessing Officer

THE ASSTT. COMMISSIONER OF INCOME TAX, JALANDHAR vs. M/S BROADWAY OVERSEAS LTD., JALANDHAR

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

capital adjusted margin of the comparables, then additional imputation of interest on the outstanding 15 I.T.A. Nos. 477 & CO 32/Asr/2015 & Ors Asstt. CIT v. Broadways Overseas Ltd. & Ors receivables is not warranted. Respectfully following the judgment of the Honourable ITAT, Mumbai and Honourable ITAT, Delhi, I also delete the addition of Rs76,45,292/- made by the Assessing Officer

BRODAWAYS OVERSEAS LIMITED,JALANDHAR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, JALANDHAR

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

capital adjusted margin of the comparables, then additional imputation of interest on the outstanding 15 I.T.A. Nos. 477 & CO 32/Asr/2015 & Ors Asstt. CIT v. Broadways Overseas Ltd. & Ors receivables is not warranted. Respectfully following the judgment of the Honourable ITAT, Mumbai and Honourable ITAT, Delhi, I also delete the addition of Rs76,45,292/- made by the Assessing Officer