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

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 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 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

SH. RAGHUNATH SAHAI PURI(DECD),PATHANKOT vs. THE DEPTY COMMISSIONER OF INCOME TAX, PATHANKOT

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

Bench: Sh. N. K. Choudhry & Sh. O. P. Meenai.T.A. No. 633/Asr/2014 Assessment Year: 2007-08

36,744/- was not declared. Since, in the present case the assessment of long term capital gain has been upheld by the jurisdictional bench of the Hon’ble ITAT and the appellant filed belated revised return of income declaring long term capital gain, the action of the AO in 5 Sh. Raghunath Sahai Puri v. D.C.I.T. imposing penalty

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

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

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)

vi).KSS Petron Pvt. Ltd. Vs. ACIT ITA No. 224/Mum/2014 (referred to page 3 para 8-11) vii).PCIT Vs. Tupperware India Pvt. Ltd. (2016) 236 Taxman 494 (referred to page 3 para 6 and 9) viii).DCIT Vs. National Bank for Agriculture and Rural Development ITA No.4964/Mum/2014 (referred to page 10- 13 para 12) 7. We note that

SH. SURAJ PRAKASH,AMRTITSAR vs. INCOME TAX OFFICER, WARD - 5(5),, AMRITSAR

In the result, the assessee’s appeal is partly allowed

Bench: Sh. Sanjay Arorai.T.A. No. 638/Asr/2017 Assessment Year: 2014-15

vi) r/w s. 45 of the Act in the hands of the assessee. The assessee received a 2 Suraj Parkash v. ITO compensation of Rs.19,57,791/- on the acquisition of his land by the Central Government, i.e., after deducting tax at source thereon at the rate of 10%. The corresponding long-term capital gain (LTCG), returned at Rs.6

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

vi). Shri. Krishan Gopal, Prop. M/s Kay Pee Lock Inds. Vs. ITO, Ward 39(1), New Delhi, ITA No. 3249/Delhi/2015. On the basis of our aforesaid deliberations, we are unable to subscribe to the standalone reliance placed by the lower authorities on the contents of the uncertified copy of the “agreement to sell”, dated 25.02.2008. At this stage

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

vi). Shri. Krishan Gopal, Prop. M/s Kay Pee Lock Inds. Vs. ITO, Ward 39(1), New Delhi, ITA No. 3249/Delhi/2015. On the basis of our aforesaid deliberations, we are unable to subscribe to the standalone reliance placed by the lower authorities on the contents of the uncertified copy of the “agreement to sell”, dated 25.02.2008. At this stage

SHRI NITIN AIMA,SHRINAGAR vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-3, SRINAGAR

The appeal of the assessee is dismissed

VI-\nA.\n7.\nThe provisions of section 10AA, as stated earlier, provide for\ndeduction from the profits and gains derived from export of articles or\nthings or from services. Another relevant word to be noted here is\n\"derived\", which has been successively and categorically held by\nvarious judicial fora including the Apex Court, to be different from\n\"attributable

SATIA INDUSTRIES LIMITED,MUKTSAR, PUNJAB vs. DCIT, ACIT CIRCLE 1, BATHINDA

In the result, the appeal is partly allowed

Bench: Shri Udayan Das Gupta & Shri Krinwant Sahayआयकरअपीलसं./Ita No. 527/Asr/2024 िनधा"रणवष" / Assessment Year : 2020-21

vi. CIT Vs. Gujarat Alkalies and Chemicalsreported in[2017] 395 ITR 247HIGH COURT OFGUJARAT vii. Tamilnadu Petro Products Ltd. vs. ACIT [2011] 13 taxmann.com 139 (Madras)[2011]202 Taxman 31 (Madras) 527-Asr-2024 Satia Industries, Muktsar 27 viii) PR. COMMISSIONER OF lNCOME TAX -6 VERSUS NALWA STEEL & POWE reported in 2024 (3) TMI 952 10. After going through

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

vi) the transfer of the undertaking is on a going concern basis; (vii) the demerger is in accordance with the conditions, if any, notified under sub-section (5) of section 72A by the Central Government in this behalf. Explanation 1.—For the purposes of this clause, "undertaking" shall include any part of an undertaking, or a unit or division

MESERS AMARNARTH AGGARWAL BUILDERS PVT. LTD.,BATHINDA vs. DEPUTY COMMISSIONER OF INCOME TAX , CIRCLE-1, BATHINDA

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

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

section 36(2)(i) no deduction of bad 4 Amarnath Aggarwal B. P Ltd v. Dy.CIT doubtful debts. The assessee’s contention is that the assessee wanted to purchase the land in anticipation for financial gain in Panchkula and paid the amount accordingly. The assessee denied that he never claimed this amount u/s 36

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