INCOME TAX OFFICER WARD-2 (1), JAMMU vs. SHRI MOHD ASLAM BAGGAR, JAMMU

In the result, the appeal of the department is dismissed

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

1) sub-clause (i) of section 10(37) of the Income tax Act, 1961 mentioning that the land which is situated in any area referred to in item (a) or item (b) of section 2(14)(iii) is exempt from charging to capital gain. (2) under sub-clause (ii) of section 10(37) of the Income tax Act, 1961 mentioning

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

36 are as under: “1. That the order passed by the Hon'ble CIT(A) dated 31.05.2024 is against the law and facts of the case. 2. That having regard to the facts and circumstances of the case, Hon'ble CIT(A) has erred in law and on facts in confirming the action of Ld. AO in framing the impugned

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

36 are as under: “1. That the order passed by the Hon'ble CIT(A) dated 31.05.2024 is against the law and facts of the case. 2. That having regard to the facts and circumstances of the case, Hon'ble CIT(A) has erred in law and on facts in confirming the action of Ld. AO in framing the impugned

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

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

gains derived from eligible industrial undertaking from any business. Whereas, under section 10B the deduction has been provided on profits of the business of the undertaking by a hundred percent export- oriented undertaking. Thus, the Judgement of Hon’ble Supreme Court in the cases of Liberty India (supra) and Saraf Exports (supra) relied by the Ld. DR are distinguishable

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

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

gains derived from eligible industrial undertaking from any business. Whereas, under section 10B the deduction has been provided on profits of the business of the undertaking by a hundred percent export- oriented undertaking. Thus, the Judgement of Hon’ble Supreme Court in the cases of Liberty India (supra) and Saraf Exports (supra) relied by the Ld. DR are distinguishable

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

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

gains derived from eligible industrial undertaking from any business. Whereas, under section 10B the deduction has been provided on profits of the business of the undertaking by a hundred percent export- oriented undertaking. Thus, the Judgement of Hon’ble Supreme Court in the cases of Liberty India (supra) and Saraf Exports (supra) relied by the Ld. DR are distinguishable

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

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

gains derived from eligible industrial undertaking from any business. Whereas, under section 10B the deduction has been provided on profits of the business of the undertaking by a hundred percent export- oriented undertaking. Thus, the Judgement of Hon’ble Supreme Court in the cases of Liberty India (supra) and Saraf Exports (supra) relied by the Ld. DR are distinguishable

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

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

gains derived from eligible industrial undertaking from any business. Whereas, under section 10B the deduction has been provided on profits of the business of the undertaking by a hundred percent export- oriented undertaking. Thus, the Judgement of Hon’ble Supreme Court in the cases of Liberty India (supra) and Saraf Exports (supra) relied by the Ld. DR are distinguishable

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

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

gains derived from eligible industrial undertaking from any business. Whereas, under section 10B the deduction has been provided on profits of the business of the undertaking by a hundred percent export- oriented undertaking. Thus, the Judgement of Hon’ble Supreme Court in the cases of Liberty India (supra) and Saraf Exports (supra) relied by the Ld. DR are distinguishable

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

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

gains derived from eligible industrial undertaking from any business. Whereas, under section 10B the deduction has been provided on profits of the business of the undertaking by a hundred percent export- oriented undertaking. Thus, the Judgement of Hon’ble Supreme Court in the cases of Liberty India (supra) and Saraf Exports (supra) relied by the Ld. DR are distinguishable

SHRI RANJEET SINGH,BATHINDA vs. INCOME TAX OFFICER WARD-1 (1), BATHINDA

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

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

1. That the learned CIT(A) is not justified in dismissing appeal of the appellant and confirming the addition of Rs. 87,36,536/- made by the Assessing Officer. 2. That the learned CIT(A) has erred in law and on facts in confirming addition of Rs. 87,36,536/- on account of capital gain by upholding that the provisions

INCOME TAX OFFICER WARD-2 (2), MUKTSAR vs. AJAIB SINGH, VILLAGE BHARU

In the result, the appeal of the revenue is dismissed

Bench: Sh. Udayan Dasgupta & Sh. Krinwant Sahay(Hybrid Hearing) I.T.A. No. 354/Asr/2024 Assessment Year: 2012-13

1,36,00,000/- per acre and the total sale consideration for 23 Kanai 2 Marla is Rs.3,92,70,000/-. The Assessing Officer observed that as per information available, the Assessee had made cash deposit of Rs.27,00,000/- in his bank account. Since, the Assessee had not filed the Return of Income, I.T.A. No. 354/Asr/2024 5 Assessment Year

BHUPENDRA FLOUR MILLS PVT LTD,BATHINDA vs. ITO, WARD 1(1), BATHINDA, BATHINDA

The appeal stands partly allowed in terms of out above order

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Shri Udayandasgupta, Jm आयकरअपीलसं. / Ita No.54/Asr/2025 (िनधा"रणवष" / Assessment Year: 2017-18) M/S Bhupendra Flour Mills Pvt Ltd. Ito Ward - 1(1) बनाम/ Railway Road Central Revenue Building Bhatinda, Punjab – 151001 Civil Lines, Bhatinda Vs. Punjab - 151001 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aaccb-6192-P (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Sudhir Sehgal (Advocate) - Ld. Ar " थ"कीओरसे/Respondent By : Sh. Farhat Khan (Cit) – Ld. Dr (Virtual) सुनवाईकीतारीख/Date Of Hearing : 05-02-2026 घोषणाकीतारीख /Date Of Pronouncement 20.02.2026 : आदेश / O R D E R

36 of Land Acquisition Act. Against the award, the assessee preferred petition before Hon’ble Punjab & Haryana High Court wherein vide order dated 23-08-2011, the compensation was enhanced to Rs.60/- per square yards along with consequential interest thereon. Pursuant to the judgment of Hon’ble High Court, the assessee receiveenhanced compensation and interest of Rs.2

INCOME TAX OFFICER WARD-1 , HOSHIAPUR vs. SHRI HARPINDER SINGH GILL , HOSHIARPUR

In the result, the appeal of the Revenue is dismissed

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

1). 5.8 Therefore, in case other than those covered by Section 46 of the 2013 Land Acquisition Act, the levy of income-tax is barred by Section 96. It is not a case of the AO that the acquisition of land related to the present appeal falls within the purview of section 46 of the RFCTLAAR Act.lt being

INCOME TAX OFFICER, INCOME TAX OFFICE vs. VIKAS MEHRA, THE MALL

In the result, the appeal filed by the revenue is dismissed being devoid of

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

36 are as follows: “1. Whether on the facts and the circumstances of the case and in law, the CITIA) has erred in deleting the addition of Rs. 2,46,99,200/ made by the Assessing Officer (AO) on account of increase in capital account from undisclosed sources, without appreciating the detailed facts that the has increased the value

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

INCOME TAX OFFICER, 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

36 are as follows: “1. That on the facts and circumstances of the case, the CIT(A) has erred on facts and law in holding that the income of the assessee from letting out its godown is chargeable under the head 'income from Business' and not under the head 'Income from House Property". 2. That on the facts and circumstances

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

36 are as follows: “1. That on the facts and circumstances of the case, the CIT(A) has erred on facts and law in holding that the income of the assessee from letting out its godown is chargeable under the head 'income from Business' and not under the head 'Income from House Property". 2. That on the facts and circumstances

GURU NANAK MILK PRODUCTS ,FEROZEPUR 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 Banerjee

section 36(1)(iii) of the Act and required to be capitalised with the cost of immovable properties. Therefore an addition of Rs. 41,44,372/- being 50% of the interest claimed is hereby added of total income of the assessee .…….” Sir, in this regard it submitted as under: 1. That modus operandi of assessee’s business model is that