SHRI ARUN NARULA,FEROZEPUR vs. ASSISTANT COMMISSIONER OFD INCOME TAX CENTRAL CIRCLE, AMRITSAR

Appeals are disposed of in the terms and observation made as above

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

reopening 3 I.T.A. Nos. 12 to 14/Asr/2022 Arun Narula v. Asstt. CIT the assessment. He has merely reproduced the observation of the ld. CIT(A) as per the appellate order passed in respect of Assessment Year 2011-12 being made while adjudicating the appeal arising out of the assessment order passed u/s 144 r.w.s. 153A of the income

SHRI ARUN NARULA,FROZEPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR

Appeals are disposed of in the terms and observation made as above

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

reopening 3 I.T.A. Nos. 12 to 14/Asr/2022 Arun Narula v. Asstt. CIT the assessment. He has merely reproduced the observation of the ld. CIT(A) as per the appellate order passed in respect of Assessment Year 2011-12 being made while adjudicating the appeal arising out of the assessment order passed u/s 144 r.w.s. 153A of the income

SHRI ARUN NARULA ,FEROZEPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR

Appeals are disposed of in the terms and observation made as above

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

reopening 3 I.T.A. Nos. 12 to 14/Asr/2022 Arun Narula v. Asstt. CIT the assessment. He has merely reproduced the observation of the ld. CIT(A) as per the appellate order passed in respect of Assessment Year 2011-12 being made while adjudicating the appeal arising out of the assessment order passed u/s 144 r.w.s. 153A of the income

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

Assessing Officer, based on sworn statement recorded from one directors of assessee-company. disallowed claim of expenditure made by assessee towards special salary etc. and brought same to tax, since impugned addition was made merely on basis of statement and without any credible evidence. same was to be deleted Thus, the reopening

M/S HOLY FAITH INTERNATIONAL PVT. LTD,JALANDHAR vs. THE DY COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeal of the assessee is allowed

Bench: Sh. N. K. Saini, Hon’Ble & Sh. Ravish Soodita No.181/Asr./2017 : Asstt. Year : 2008-09 M/S Holy Faith International Vs Deputy Commissioner Of Income Tax, Pvt. Ltd., Mbd House, Central Circle-Ii, Railway Road, Jalandhar Jalandhar (Appellant) (Respondent) Pan No. Aaach6111J Assessee By : Sh. Sudhir Sehgal, Adv. Revenue By : Sh. Bhawani Shankar, Dr Date Of Hearing : 07.01.2019 Date Of Pronouncement : 15.01.2019 Order Per N. K. Saini: This Is An Appeal By The Assessee Against The Order Dated 20.03.2017 Of Ld. Cit(A)-I, Jalandhar. 2. Following Grounds Have Been Raised In This Appeal: “1. That The Worthy Commissioner Of Income Tax (A)-1, Jalandhar Has Erred In Dismissing The Appeal Filed By The Assessee. 2. That The Ld. Cit(A) Has Erred In Confirming The Contention Of The Assessing Officer In Reopening The Case U/S 148 Of The Income Tax Act And, Thus, Framing Of Assessment U/S 147 R.W.S.143(3)/153C At An Income Of Rs. 4,95,13,441/- Against The Returned Income Of Rs. 4,63,33,441/-. 3. That The Ld. Cit(A) Has Erred In Not Considering That There Was No Reason To Believe That The Income Of The

disallowance which was earlier made u/s 153C of the Act at Rs.1,00,000/- but was restricted by the ld. CIT(A) to Rs.30,000/-. 5. Being aggrieved the assessee carried the matter to the ld. CIT(A) and challenged the jurisdiction of the AO in reopening the assessment

KUNDAN JEWELLERS PRIVATE LIMITED,GANDHI CHOWK, SADAR BAZAR, MUKTSAR vs. THE INCOME TAX OFFICER, WARD-2(2), MUKTSAR, MUKTSAR

In the result, the appeal of the assessee is allowed

Bench: Sh. Udayan Dasgupta & Sh. Krinwant Sahay

reopening of the assessment in the present case was not valid, accordingly, the same is quashed. Fortune Metaliks Limited vs. DCIT, ITA No. 1090/Chd/2019 dated 12.01.2021-CHD Trib "7. We have heard both the parties. We find merit in the contention of the Id. counsel for the assessee that the reassessment proceedings undertaken by the AO in the present case

M/S CITI PLAZA,JALANDHAR vs. INCOME TAX OFFICER , WARD 3(1), JALANDHAR

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

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

reopening were for 1948-49 on 5th December 1957. The assessee therefore filed a Petition under Article 226 of the Constitution of India on the ground that the notice dated 5th December 1957 seeking to re-open the assessment for Assessment Year 1948-49 is time barred under Section 34 of the Income Tax Act, 1922. The revenue contended that

SHRIMATI NEETIMA GOYAL,FEROZPUR CANTT. vs. INCOME TAX OFFICER,3(2), FEROZPUR

In the result, appeal of the assessee is allowed on legal ground

Bench: Shri L.P. Sahu, Am & Shri Ravish Sood, Jm आयकर अऩीऱ सं./Ita No.184/Asr/2018 (ननधाारण वषा / Assessment Year :2011-2012) Neetima Goyal, Vs. Ito, Ward-3(2), Ferozepur Prop. Raghav Sales, G.T.Road, Ferozepur Cantt., Pin-152001 स्थायी ऱेखा सं./ Panno. : Aicpg 3586 H (अऩीऱाथी /Appellant) .. (प्रत्यथी / Respondent) ननधााररती की ओर से /Assessee By : Shri I.P.Bansal, Advocate राजस्व की ओर से /Revenue By : Shri Charan Dass, Dr

disallowance is bad in law. Addition of Rs. 17,40,000/- 10. This addition is on account of unexplained investment in agricultural land. It is already submitted that this case is no account case. To explain the investment in agricultural land the assessee submitted that a sum of Rs. 8.82 lakh was from current year income

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

reopen assessment, though wide, are not plenary-Interest allowed as deduction in original assessment subsequently ITO found that creditors were name-lenders-Confession from creditors There was nothing to show that the confession related to a loan advanced to assessee-The live link or close nexus between material before ITO and belief he was to form regarding escapement of income

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

reopen assessment, though wide, are not plenary-Interest allowed as deduction in original assessment subsequently ITO found that creditors were name-lenders-Confession from creditors There was nothing to show that the confession related to a loan advanced to assessee-The live link or close nexus between material before ITO and belief he was to form regarding escapement of income

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR vs. M/S PUNJAB RICE LAND PRIVATE LIMITED, TARN TARAN

In the result, both the appeals of the revenue are dismissed and

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

disallowed. Under the facts & circumstances of the case and after looking the bill filed by the AR and enquiries done in the presence of AR during the appellate proceedings, the addition of Rs. 18,15,000/- made by the AO is found sustainable and hence confirmed. Bogus accommodation entry with the help of Sh. Raman Arora Regarding M/s. Dashmesh Agro

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR vs. M/S PUNJAB RICE LAND PRIVATE LIMITED , TARN TARAN

In the result, both the appeals of the revenue are dismissed and

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

disallowed. Under the facts & circumstances of the case and after looking the bill filed by the AR and enquiries done in the presence of AR during the appellate proceedings, the addition of Rs. 18,15,000/- made by the AO is found sustainable and hence confirmed. Bogus accommodation entry with the help of Sh. Raman Arora Regarding M/s. Dashmesh Agro

PANKAJ JINDAL CONTRACTOR,MANSA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-I, BATHINDA, BATHINDA

In the result the appeal of the assessee is allowed

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta(Physical Hearing) I.T.A. No. 695/Asr/2024 Assessment Year: 2014-15 M/S Pankaj Jindal Contractor, Vs. Dcit-Circle-1, Near Vidya Bharti School, Bathinda. Mansa. [Pan:-Aajfp8008L] (Appellant) (Respondent) Appellant By Sh. Sudhir Sehgal, Adv. Respondent By Sh. Charan Dass, Sr. Dr

reopening is after four years from the end of the assessment year, and it is to be seen whether there was a failure on the part of the assessee to disclose fully and truly all material facts necessary for the assessment for the relevant assessment year. On perusal of the factual position we find that full set of books

THE ASSTT. COMMISSIONER OF INCOME TAX, AMRITSAR. vs. M/S KHOSLA INTERNATIONAL, BATALA

Bench: Sh. Sanjay Arora & Sh. N. K. Choudhryi.T.A. No. 307/Asr/2016 Assessment Year: 2008-09

reopening of the assessment, framed in the first instance u/s. 143(3) (vide order dated 13.04.2009/copy on record), viz. disallowance

SHIVAM ENTERPRISES HARBILAS,HOSHIARPUR vs. INCOME TAX OFICER WARD-4, HOSHIARPUR

In the result, the assessee’s appeal is allowed

Bench: Sh. Sanjay Arorai.T.A. No. 194/Asr/2018 Assessment Year: 2011-12

reopening of assessment vide notice u/s. 148 dated 08.02.2016. The assessee assails the same on the basis of it being a ‘change of opinion’. Depreciation on trucks and tempos had been allowed in the original assessment u/s. 143(3) dated 25.02.2014 at the rate of 40% (on WDV), i.e., as claimed, on being satisfied that the said vehicles, used

M/S.PUNJAB INSTITURE OF MEDICAL SCIENCE,JALANDHAR vs. DEPUTY COMMISSIONER OF INCOME TAX , JALANDHAR

In the result, the ITA No

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

reopened the assessment years by persuasion of notice u/s 148 of the Act, had treated the assessee as an AOPand had disallowed

M/S PUNJAB INSTITUTE OF MEDICAL SCIENCES,,JALANDHAR vs. THE DY COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the ITA No

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

reopened the assessment years by persuasion of notice u/s 148 of the Act, had treated the assessee as an AOPand had disallowed

M/S.PUNJAB INSTITUTE OF MEDICAL SCIENCE,JALANDHAR vs. DEPUTY COMMISSIONER OF INCOME TAX , JALANDHAR

In the result, the ITA No

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

reopened the assessment years by persuasion of notice u/s 148 of the Act, had treated the assessee as an AOPand had disallowed