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

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

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

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 assessee contributed ancestral agriculture land along-with his brother as their share in the capital in the books of M/s G.S. Chahal & Associates at the time of constituting the partnership firm. 2. The A.O. invoked the provisions of section 45(3) of the IT Act, 1961 and assessed the long term capital gain

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 assessee contributed ancestral agriculture land along-with his brother as their share in the capital in the books of M/s G.S. Chahal & Associates at the time of constituting the partnership firm. 2. The A.O. invoked the provisions of section 45(3) of the IT Act, 1961 and assessed the long term capital gain

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

section is very wide, but at the same time it cannot be stated to be a plenary power. The AO can assume jurisdiction under the said provision provided there is sufficient material before him. He cannot act on the basis of his whim and fancy, and the existence of material must be real. Further, there must be nexus between

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

section is very wide, but at the same time it cannot be stated to be a plenary power. The AO can assume jurisdiction under the said provision provided there is sufficient material before him. He cannot act on the basis of his whim and fancy, and the existence of material must be real. Further, there must be nexus between

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

capital gains. (iv) A conjoint reading of Section 2(24), Section 2(28A), Section 4, Section 10(37), Section 14, Section 45(5), Section 56(2)(viii), Section 145B(1

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

Capital Gains’ u/s 45(5)(a) of the Act and added to the income of the appellant. Ranjeet Singhv. ITO & Ors. 6. The Ld. CIT (A) has confirmed the addition by observing that Notification dated 31.12.2014 was issued by Ministry of Law & Justice wherein sub section (3) of section 105 of the RFCTLAAR Act was substituted by providing that

INCOME TAX OFFICER, WARD-2 , PHAGWARA vs. SH. SUCHA SINGH, PHILLAUR

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

Bench: Shrilaliet Kumar & Dr. Mitha Lal Meena

1-12-16, verified the record of village Kutbewal, Tehsil- Phillaur, District- Jalandhar in which the ownership lies with Sucha Singh s/o Birak Singh s/o Nand Singh bearing No.489/ 414 , 490/414. Ownership transferred vide Intkaal No.882 to National Highway authority bearing Khasra No. 489/2 (0-4), 490(4-14) 18 ITA No.702/Asr/2017& C.O. 07/Asr/2018 Having area

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

capital gains on such sale as per provision of section 54B(1)(ii). He further relied on the judgment of jurisdictional High Court in the case of CIT vs. Gurnam Singh in ITA 616/2007 order dated 01/04/2008 reported in 327 ITR 278 where it has been held by the Hon’ble Court that purchase of another piece of land

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

1 Km. on either side of Mohali Kharar Road up to a distance of 6 Km. from Municipal Limit on that road. 18. From the above, it is evident that any land situated within these limbs would not be treated as exempt agricultural land for the purpose of capital gain u/s 2(14) of the Act and thus any sale

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

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

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

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

1)(c) for the alleged non disclosure of capital, gain on transfer of land by the MLA’s Housing Society to TATA Housing Development Co. 2 Sh. Raghunath Sahai Puri v. D.C.I.T. 2. That without having impleaded all the legal heirs of the deceased, the impugned order of ld. AO on a single legal heir, was not sustainable. 3. That