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

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

1. The Ld. CIT(A) erred on facts & law in confirming the action of the AO of assessing the income at Rs.3,87,73,310/- + Agriculture income at Rs. 11,56,169/- vide order u/s 143(3)1147 dated 20.12.2017. 2. The Ld. CIT(A) erred on facts & law in confirming the validity of the proceedings u/s 1471148 because

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

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

1. The Ld. CIT(A) erred on facts & law in confirming the action of the AO of assessing the income at Rs.3,87,73,310/- + Agriculture income at Rs. 11,56,169/- vide order u/s 143(3)1147 dated 20.12.2017. 2. The Ld. CIT(A) erred on facts & law in confirming the validity of the proceedings u/s 1471148 because

M/S ACTIVE TOOLS (P). LIMITED,JALANDHAR vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE -II, JALANDHAR

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

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

MAX FINANCIAL SERVICE LIMITED ,NAWANSHAHR vs. PRINCIPAL COMMISSIONER OF INCOME TAX -1, JALANDHAR

In the result, the appeal of the assessee is therefore partly allowed

gains of business” as against “income from house property” and consequential claim of depredation under section 32 of the Act, being supported by various decisions of the High Courts could not have been termed as erroneous. 9. Without prejudice to the above, the PCIT failed to appreciate that business expenditure as claimed by the Appellant for the purposes of carrying

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

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

gain instead of long term capital loss shown by the assessee and accepted by the AO. The AO has not enquired even from the assessee, the reasons for selling the property at a rate which would yield long term capital loss as a prudent person would not sell property, the property which would yield. But, even

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

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

gain instead of long term capital loss shown by the assessee and accepted by the AO. The AO has not enquired even from the assessee, the reasons for selling the property at a rate which would yield long term capital loss as a prudent person would not sell property, the property which would yield. But, even

SH. ARASHPREET SINGH S/O. LATE SH. GURMAIL SINGH,MUKTSAR vs. DY. COMMISSIONER OF INCOME TAX CIRCLE-II, BATHINDA

Appeals are disposed of in the terms and observation made as above

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

282 of the Income-tax Act, 1961. The proceedings u/s 147/148 are void ab-initio because the reasons to believe recorded by the AO are infact reasons to suspect. That no satisfaction was recorded by the Principle CIT which was mandatory under the provisions of Section 151(1) & reliance for the contention has been placed on the following judgments

SH. ARASHPREET SINGH. S/O.LATE.SH. GURMAIL SINGH,MUKTSAR vs. DY. COMMISSIONER OF INCOME TAX .CIRCLE-II, BATHINDA

Appeals are disposed of in the terms and observation made as above

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

282 of the Income-tax Act, 1961. The proceedings u/s 147/148 are void ab-initio because the reasons to believe recorded by the AO are infact reasons to suspect. That no satisfaction was recorded by the Principle CIT which was mandatory under the provisions of Section 151(1) & reliance for the contention has been placed on the following judgments

SH. ARSPREET SINGH . S/O. LATE. SH. GURMAIL SINGH ,MUKTSAR vs. DY. COMMISSIONER OF INCOME TAX CIRCLE .II, BATHINDA

Appeals are disposed of in the terms and observation made as above

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

282 of the Income-tax Act, 1961. The proceedings u/s 147/148 are void ab-initio because the reasons to believe recorded by the AO are infact reasons to suspect. That no satisfaction was recorded by the Principle CIT which was mandatory under the provisions of Section 151(1) & reliance for the contention has been placed on the following judgments

LATE. SH. GURMAIL SINGH.S/O. LATE SH. LAL SINGH,SRI MUKTSAR vs. DY. COMMISSIONER OF INCOME TAX CIRCLE -II, BATHINDA

Appeals are disposed of in the terms and observation made as above

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

282 of the Income-tax Act, 1961. The proceedings u/s 147/148 are void ab-initio because the reasons to believe recorded by the AO are infact reasons to suspect. That no satisfaction was recorded by the Principle CIT which was mandatory under the provisions of Section 151(1) & reliance for the contention has been placed on the following judgments

LATE. SH. GUMAIL SINGH . S/O. SH. LAL SINGH,MUKTSAR vs. DY. COMMISSIONER OF INCOME TAX CIRCLE -II, BATHINDA

Appeals are disposed of in the terms and observation made as above

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

282 of the Income-tax Act, 1961. The proceedings u/s 147/148 are void ab-initio because the reasons to believe recorded by the AO are infact reasons to suspect. That no satisfaction was recorded by the Principle CIT which was mandatory under the provisions of Section 151(1) & reliance for the contention has been placed on the following judgments

LATE. SH. GURMAIL. SINGH S/O. SH. LAL SINGH,SHRI MUKAT SAR vs. DY. COMMISSIONER OF 9INCOME TAX. CIRCLE -II, BATHINDA

Appeals are disposed of in the terms and observation made as above

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

282 of the Income-tax Act, 1961. The proceedings u/s 147/148 are void ab-initio because the reasons to believe recorded by the AO are infact reasons to suspect. That no satisfaction was recorded by the Principle CIT which was mandatory under the provisions of Section 151(1) & reliance for the contention has been placed on the following judgments

LATE. SH. GURMAIL. SINGH. S/O. SH. LAL SINGH,SRI MUKATSAR vs. DY.COMMISSIONER OF INCOME TAX CIRCLE -II, BATHINDA

Appeals are disposed of in the terms and observation made as above

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

282 of the Income-tax Act, 1961. The proceedings u/s 147/148 are void ab-initio because the reasons to believe recorded by the AO are infact reasons to suspect. That no satisfaction was recorded by the Principle CIT which was mandatory under the provisions of Section 151(1) & reliance for the contention has been placed on the following judgments

LATE. SH. GURMAIL SINGH S/O. SH. LAL SINGH,SRI MUKATSAR vs. DY.COMMISSIONER OF INCOME TAX CIRCLE -II, BATHINDA

Appeals are disposed of in the terms and observation made as above

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

282 of the Income-tax Act, 1961. The proceedings u/s 147/148 are void ab-initio because the reasons to believe recorded by the AO are infact reasons to suspect. That no satisfaction was recorded by the Principle CIT which was mandatory under the provisions of Section 151(1) & reliance for the contention has been placed on the following judgments

SH. ARASHPREET SINGH S/O LATE SH. GURMAIL SINGH,SHRI MUKATSAR vs. DY. COMMISSIONER OF INCOME TAX CIRCLE-II, BATHINDA

Appeals are disposed of in the terms and observation made as above

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

282 of the Income-tax Act, 1961. The proceedings u/s 147/148 are void ab-initio because the reasons to believe recorded by the AO are infact reasons to suspect. That no satisfaction was recorded by the Principle CIT which was mandatory under the provisions of Section 151(1) & reliance for the contention has been placed on the following judgments

SH. ARASHPREET SINGH S/O. LATE SH. GURMAIL SINGH,MUKTSAR vs. DY. COMMISSIONER OF INCOME TAX CERCLE- II, BATHINDA

Appeals are disposed of in the terms and observation made as above

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

282 of the Income-tax Act, 1961. The proceedings u/s 147/148 are void ab-initio because the reasons to believe recorded by the AO are infact reasons to suspect. That no satisfaction was recorded by the Principle CIT which was mandatory under the provisions of Section 151(1) & reliance for the contention has been placed on the following judgments

SMT. PARMINDER KAUR BRAR,KOTKAPURA vs. PRINCIPAL COMMISSIONER OF INCOME TAX -1, AMRITSAR

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

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

capital gain. So, theissuewas needed to be investigated. The assessee has claimed I.T.A. No.72/Asr/2022 5 Assessment Year: 2011-12 exemption u/s 54 amounting to Rs.22,84,849/-. The grievance of the ld. PCIT that the ld. AO had not raised any query to verify the genuineness of the exemption claimed nor verify as to whether the pre-requisite required being

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

282 (SC). Accordingly the interest earned from Cooperative Bank was added back with the total income of the assessee society. The assessee filed an appeal before the ld. CIT(A) and the ld. CIT(A) upheld the assessment order. Being dissatisfied, the assessee filed the appeal for further adjudication before the ITAT. 3. The ld. AR filed a written submission