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 10(38) merely by relying on statements of accommodation entry providers which were recorded much before date of survey.” 27 I.T.A. Nos. 346 & 347/Asr/2024 Assessment Years: 2014-15 & 2015-16 26. Relying on the above decisions of various courts the tribunal decided the issue in favour of the assessee in the case of Rama Mittal in ITA 26/ASR/2024

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 of Rs. 26,62,987/-. Thereafter, the assessee revised the ITR on 27.05.2017 showing total income at Rs.3,39,360/- under the head income from other sources. 1.2 The assessee claimed the above stated amount of Rs.27,96,629/- i.e., Compensation of Rs. 21,51,253/- and Solatium @ 30% of Rs.6,45,376/- in the revised return

SHRI BABBU SINGH S/O SHRI NACHHATER SINGH,BATHINDA vs. INCOME TAX OFFICEER WARD-2(1), BATHINDA

In the result all the appeals of the assessee are allowed for statistical purposes

Bench: Sh. Laliet Kumar & Dr. M. L. Meena

section 148 on the issue of ‘mechanical application of mind’ by the Ld. PCIT and also there was no ‘Reason to Believe’ that the income of assessee has escaped assessment as per concise ‘grounds of appeal,’ the following submissions may, please, be considered: - a). In all the three cases, since the assessments were sought to be reopened beyond four years

SHRI NACHHATER SINGH S/O SHRI GURBAKSH SINGH,BATHINDA vs. INCOME TAX OFFICEER , BATHINDA

In the result all the appeals of the assessee are allowed for statistical purposes

Bench: Sh. Laliet Kumar & Dr. M. L. Meena

section 148 on the issue of ‘mechanical application of mind’ by the Ld. PCIT and also there was no ‘Reason to Believe’ that the income of assessee has escaped assessment as per concise ‘grounds of appeal,’ the following submissions may, please, be considered: - a). In all the three cases, since the assessments were sought to be reopened beyond four years

SHRI.BOOTA SINGH S/O. SH. NACHATER SINGH, BATHINDA vs. INCOME TAX OFFICER WARD-2(1), BATHINDA

In the result all the appeals of the assessee are allowed for statistical purposes

Bench: Sh. Laliet Kumar & Dr. M. L. Meena

section 148 on the issue of ‘mechanical application of mind’ by the Ld. PCIT and also there was no ‘Reason to Believe’ that the income of assessee has escaped assessment as per concise ‘grounds of appeal,’ the following submissions may, please, be considered: - a). In all the three cases, since the assessments were sought to be reopened beyond four years

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)

section 50C (2) of the IT Act. The AO is being directed to re-compute the quantum of long term capital gains on sale of property by taking the sale consideration at Rs.2,03,00,000 and workout the amount of capital gains accordingly.” We note that aggrieved by the order of AO, the assessee filed appeal before

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

section (4A) of Sec. 132 of the Act. As is discernible from the records, we find that the A.O in his ‘remand report’ that was filed in the course of the proceedings before the CIT(A), had fairly admitted that he had only received a copy of the “agreement to sell”, dated 25.02.2008 from the Dy. DIT (Inv.), Ludhiana

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

section (4A) of Sec. 132 of the Act. As is discernible from the records, we find that the A.O in his ‘remand report’ that was filed in the course of the proceedings before the CIT(A), had fairly admitted that he had only received a copy of the “agreement to sell”, dated 25.02.2008 from the Dy. DIT (Inv.), Ludhiana

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

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 AY 2015-16 Deb Brat Sharma Vs. ITO, Ward 3(1) 2. Briefly stated, the assessee had e-filed his return of income

SHRI AMAR NATH CHOUDHARY,JAMMU vs. DEPUTY CMMISSIONER OF INCOME TAX CENTRAL CIRCLE, JAMMU

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

section 250(6) of the Income tax Act, 1961 merely on assumptions, presumptions, surmises and conjectures, without appreciating the factual, legal and statutory position of the Law and facts of the case. Amar Nath Choudhary v. Dy. CIT 2. That on the facts and circumstances of the case, the Ld. CIT(A) has erred in confirming 10% of the total

SHRI AMAR NATH CHOUDHARY,JAMMU vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, JAMMU

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

section 250(6) of the Income tax Act, 1961 merely on assumptions, presumptions, surmises and conjectures, without appreciating the factual, legal and statutory position of the Law and facts of the case. Amar Nath Choudhary v. Dy. CIT 2. That on the facts and circumstances of the case, the Ld. CIT(A) has erred in confirming 10% of the total

SHRI AMAR NATH CHOUDHARY,JAMMU vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRA L CIRCLE, JAMMU

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

section 250(6) of the Income tax Act, 1961 merely on assumptions, presumptions, surmises and conjectures, without appreciating the factual, legal and statutory position of the Law and facts of the case. Amar Nath Choudhary v. Dy. CIT 2. That on the facts and circumstances of the case, the Ld. CIT(A) has erred in confirming 10% of the total

DY . C.I.T, CENTRAL CIRCLE -1,, JALANDHAR vs. SH. RANJIT SINGH , JALANDHAR

In the result, the appeal is allowed

Bench: Sh. N. K. Saini, Hon’Ble & Sh. Ravish Soodita No.241/Asr./2017 : Asstt. Year : 2009-10 Dy. Commissioner Of Income Vs Sh. Ranjit Singh, Tax, Central Circle-I, Jalandhar S/O Sh. Mehnga Singh, Vpo-Beas Pind, District-Jalandhar (Appellant) (Respondent) Pan No. Ctjps4497P Co No.23/Asr./2017 : Asstt. Year : 2009-10 Sh. Ranjit Singh, Vs Dy. Commissioner Of Income Tax, S/O Sh. Mehnga Singh, Vpo- Central Circle-I, Jalandhar Beas Pind, District-Jalandhar (Appellant) (Respondent) Pan No. Ctjps4497P Ita No.242/Asr./2017 : Asstt. Year : 2009-10 Dy. Commissioner Of Income Vs Sh. Charan Singh Urf Gurcharan Tax, Central Circle-I, Jalandhar Singh, S/O Sh. Dhanna Singh, Vpo- Sarmastpur, Jalandhar (Appellant) (Respondent) Pan No. Fifps1985G Co No.25/Asr./2017 : Asstt. Year : 2009-10 Sh. Charan Singh Urf Gurcharan Vs Dy. Commissioner Of Income Tax, Singh, S/O Sh. Dhanna Singh, Central Circle-I, Jalandhar Vpo-Sarmastpur, Jalandhar (Appellant) (Respondent) Pan No. Fifps1985G Assessee By : Sh. S. S. Kalra, Adv. Revenue By : Sh. Bhawani Shankar, Dr Date Of Hearing : 07.01.2019 Date Of Pronouncement : 07.01.2019

capital gain income of Rs.1,74,01,064/-. Since, there was no compliance by the assessee on the notices issued by the AO, the assessment was framed u/s 144 of the Income Tax Act, 1961 (hereinafter referred to as the Act) by making the addition of Rs.1,74,01,064/-. 6. Being aggrieved the assessee carried the matter

D.C.I.T, CENTRAL CIRCLE-1,, JALANDHAR vs. SH. CHARAN SINGH, JALANDHAR

In the result, the appeal is allowed

Bench: Sh. N. K. Saini, Hon’Ble & Sh. Ravish Soodita No.241/Asr./2017 : Asstt. Year : 2009-10 Dy. Commissioner Of Income Vs Sh. Ranjit Singh, Tax, Central Circle-I, Jalandhar S/O Sh. Mehnga Singh, Vpo-Beas Pind, District-Jalandhar (Appellant) (Respondent) Pan No. Ctjps4497P Co No.23/Asr./2017 : Asstt. Year : 2009-10 Sh. Ranjit Singh, Vs Dy. Commissioner Of Income Tax, S/O Sh. Mehnga Singh, Vpo- Central Circle-I, Jalandhar Beas Pind, District-Jalandhar (Appellant) (Respondent) Pan No. Ctjps4497P Ita No.242/Asr./2017 : Asstt. Year : 2009-10 Dy. Commissioner Of Income Vs Sh. Charan Singh Urf Gurcharan Tax, Central Circle-I, Jalandhar Singh, S/O Sh. Dhanna Singh, Vpo- Sarmastpur, Jalandhar (Appellant) (Respondent) Pan No. Fifps1985G Co No.25/Asr./2017 : Asstt. Year : 2009-10 Sh. Charan Singh Urf Gurcharan Vs Dy. Commissioner Of Income Tax, Singh, S/O Sh. Dhanna Singh, Central Circle-I, Jalandhar Vpo-Sarmastpur, Jalandhar (Appellant) (Respondent) Pan No. Fifps1985G Assessee By : Sh. S. S. Kalra, Adv. Revenue By : Sh. Bhawani Shankar, Dr Date Of Hearing : 07.01.2019 Date Of Pronouncement : 07.01.2019

capital gain income of Rs.1,74,01,064/-. Since, there was no compliance by the assessee on the notices issued by the AO, the assessment was framed u/s 144 of the Income Tax Act, 1961 (hereinafter referred to as the Act) by making the addition of Rs.1,74,01,064/-. 6. Being aggrieved the assessee carried the matter

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

SHRI NIRVAIR SINGH,AMRITSAR vs. INCOME TAX OFFICER WARD-4(3), AMRITSAR

In the result, the appeal filed by the assessee is allowed for statistical purposes

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

74,661/- by forcibly creating negative cash flow statement and inserting payments made through bank account as made in cash and also not following the rationale of peak credit and telescoping. 5. That the order passed by the Ld. Assessing officer and further upheld by worthy CIT (Appeals) is infructuous and bad in law as the Ld. Assessing officer

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

74,82,93,51. The AR also provided a comparison between the method adopted by the DRP and the method applied by the assessee, as detailed below: 527-Asr-2024 Satia Industries, Muktsar 15 Particul Units of Rate Rate per Differen Difference ars electricity per unit unit ce (Rs.) produced conside considere (per r-ed by d by DRP unit