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

Section 56(2)(viia) are not applicable on the Assessee Commissioner with respect to both of the aforementioned subject sale transactions. However the assessee has failed to consider that the assessee has also purchased 2323 shares of M/s Neeman Medical International BV (Neeman BV) on 31-03- 2014. The AO has also failed to examine as t how two shares

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) and Section 194LA of the Act makes it abundantly clear that any income which arises or is deemed to arise or accrue in India is chargeable

SHRI DEV BRAT SHARMA,JALANDHAR vs. INCOME TAX OFFICER,WARD 3 (1), JALANDHAR

Bench: Shri. N.K. Saini & Shri. Ravish Soodsh. Dev Brat Sharma, Income Tax Officer, 62, New Rajinder Nagar, Vs. Ward-3(1) Near New Court, Jalandhar. Jalandhar

72,00,000/- which was bad in law. 3. The learned Commissioner of Income Tax (Appeals) has erred in upholding the computation of Long Term Capital Gain at Rs. 74,61,158/- as against the returned figure of Rs. 26,158/-. The legal as well as the factual position has not been appreciated. P a g e | 2 ITA No.493/Asr/2018

THE DY. COMMISSIONER INCOME-TAX, JAMMU vs. M/S. HORIZON BUILDCON PVT. LTD,, JAMMU

In the result, the appeals of the Revenue in I

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

section 69B of the Act. Dy. CIT v. Horizon Buildcon Pvt. Ltd. When the assessee further challenged the same before the Tribunal, it quashed and set aside the order of the Assessing Officer and that of CIT(Appeals) and held the entire addition to have been made on the basis of presumptions and surmises by holding thus: - 14. From

THE DY. COMMISSIONER INCOME-TAX, JAMMU vs. M/S. HORIZON BUILDCON PVT. LTD,, JAMMU

In the result, the appeals of the Revenue in I

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

section 69B of the Act. Dy. CIT v. Horizon Buildcon Pvt. Ltd. When the assessee further challenged the same before the Tribunal, it quashed and set aside the order of the Assessing Officer and that of CIT(Appeals) and held the entire addition to have been made on the basis of presumptions and surmises by holding thus: - 14. From

THE DY. COMMISSIONER INCOME-TAX, JAMMU vs. M/S. HORIZON BUILDCON PVT. LTD,, JAMMU

In the result, the appeals of the Revenue in I

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

section 69B of the Act. Dy. CIT v. Horizon Buildcon Pvt. Ltd. When the assessee further challenged the same before the Tribunal, it quashed and set aside the order of the Assessing Officer and that of CIT(Appeals) and held the entire addition to have been made on the basis of presumptions and surmises by holding thus: - 14. From

ISHAR INFRASTRUCTURE DEVELPOPERS PRIVATE LIMITED,BATHINDA vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1, BATHINDA

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta(Hybrid Hearing) I.T.A. No. 686/Asr/2024 Assessment Year: 2022-23

Capital IQ (India) (P.) Ltd. vs. ACIT, 158 taxmann.com 12 (Hyd. Trib). Nehru Memorial Education Society vs. ITO (Exemp.) 161 taxmann.com 312 (Cochin Trib.). 7. Regarding the claim of unabsorbed depreciation brought forward amounting to Rs.1,50,49,432/- the Ld AR submitted that the first appellate authority has denied the set off observing that no adjustment was made

M/S G G OILS & FATS PVT.LTD ,BATHINDA vs. DEPUTY COMMISSIONER OF INCOME TAX, BATHINDA

In the result, the assessee’s appeal is dismissed

Bench: Sh. Sanjay Arora & Sh. N. K. Choudhryi. T. A. No. 508/Asr/2017 Assessment Year: 2014-15

section 23A company (i.e., a company in which the public is not substantially interested) can be said to have been availed of for his benefit by the shareholder. The matter was referred to the President of the Tribunal, who agreed with the view by the AM. A loan or advance received by a share-holder assumed the character of dividend

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

72 taxmann.com 289 (Gujarat)] wherein 100% of bogus purchases were added to the total income of the assessee. 2. The Ld. CIT(A) has erred in limiting the addition only to the extent of 25% of bogus purchases by arriving at the conclusion that since the corresponding sales have been accepted and so entire alleged purchases cannot be disallowed

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

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

72,000/- Excess Stock : Rs. 50,28,000/- Investment in factory building : Rs. 90,00,000/- In the return of income, the Assessee declared the additional income of Rs.1,50,00,000/-in theProfit &Loss Account but claimed expenses against the same. The Assessing Officer while framing assessment accepted the declared income in spite the fact that the Assessee

SH. GURJINDER SINGH,AMRITSAR vs. PR. COMMISSIONER OF INCOME TAX -1, AMRITSAR

In the result, appeal of the assessee is allowed

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

72,332/- . The AO has failed to make enquiries from Radha Swami Satsang that they have made payment of cash of Rs. 20,000/- everyday to the assessee. (vi) The assessment records shows that the assessee has made payment of Rs. 21,62,937/- in M/s Apex Marketings under the head “Truck Hire Charges'. Similar nature of payment

SMT. SATVIR KAUR W/O SH. SHINDER SINGH,FEROZEPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX-1, AMRITSAR

In the result, the appeal of the assessee is allowed

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

Capital Gain, exemption u/s 10(36) of the Act, deduction u/s 57 of the Act and unsecured loans and the assessees furnished all the relevant documents which were examined by the AO who has taken a possible view. Therefore, it is our considered view that there was a due application of mind on the part

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

72,90,275 from the assessee's reported value of Rs. 41,21,19^626. Ground No. 8 addresses the change in the transfer pricing method from the Transaction Net Margin Method (TNMM) to 527-Asr-2024 Satia Industries, Muktsar 9 the External Comparable Uncontrolled Price (CUP) method, which could affect the determination of the arm's length price

SHRI OM PARKASH LEGAL HEIAR SMT PUSHPA VERMA,JALANDHAR vs. INCOME TAX OFFICER WARD-1(3), JALANDHAR

In the result, the assessee’s appeal is dismissed

Bench: Sh. Sanjay Arorai.T.A. No. 756/Asr/2017 Assessment Year: 2014-15

72 ITR 194 (SC). The ld. counsel, after seeking time, which was allowed, would respond by relying on the decision in CIT v. Aggarwal Engineering Co. [2008] 302 ITR 246 (P&H), to the effect that once the net profit rate is applied for estimating income, no separate addition on account of cash credit, or for payment of purchases, could

THE INCOME TAX OFFICER, AMRITSAR. vs. SH. SHIV RAJ SINGH BAWA, AMRITSAR.

In the result, the Revenue’s appeal is allowed and the assessee’s CO, dismissed

Bench: Sh. Sanjay Arora & Sh. N. K. Choudhryi.T.A. No. 407/Asr/2016 Assessment Year: 2012-13

gain, undertaken together. If the sale fell in dispute, and the matter is sub judice, that would not in any manner alter the assessee’s intent and object in acquiring the land, which in fact gets evident from its’ subsequent sale soon after. Why, the land could subsequently even be regarded as a capital asset, though, given the dispute which

THE DY. COMMISSIONER OF INCOME-TAX,, JAMMU vs. M/S. CONTINENTAL CONSTRUCTION CO,, JAMMU ( J&K)

In the result, the appeal filed by the assessee is allowed as well as the appeal filed the Revenue Department is dismissed and Cross Objection also stands disposed off

Bench: Sh. Sanjay Arora & Sh. N.K.Choudhryita No.38(Asr)/2013 Assessment Year:2009-10

72 ITR 194 (SC)), we find no basis for the said addition in the facts and circumstances of the case. True, the burden of proof u/s. 68 is on the assessee, which has not furnished any material in the assessment proceedings. However, it is not clear if the AO had in any of the notices u/s. 142(1) required

M/S. CONTINENTAL CONSTRUCTION CO.,,JAMMU vs. THE DY. COMMISSIONER OF INCOME-TAX (HQRS), JAMMU

In the result, the appeal filed by the assessee is allowed as well as the appeal filed the Revenue Department is dismissed and Cross Objection also stands disposed off

Bench: Sh. Sanjay Arora & Sh. N.K.Choudhryita No.38(Asr)/2013 Assessment Year:2009-10

72 ITR 194 (SC)), we find no basis for the said addition in the facts and circumstances of the case. True, the burden of proof u/s. 68 is on the assessee, which has not furnished any material in the assessment proceedings. However, it is not clear if the AO had in any of the notices u/s. 142(1) required

M/S GURU RAM DASS EDUCATIONAL SOCIETY,BATHINDA vs. THE COMMISSIONER OF INCOME TAX (EXEMPTION), CHANDIGARH

In the result, the assessee’s appeal is allowed

Bench: Sh. Sanjay Arora & Sh. N. K. Choudhryi. T. A. No. 598/Asr/2016 Assessment Year: N.A.

sections thereof. Running of schools and colleges by charging high fees, accumulating huge assets, could not be regarded as charitable activity. The institutions could not be allowed to grow richer and richer by extending exemption, thereby converting them into tax-exempt organizations. The present case, it was opined by him, was of a society whose activities, though involved education