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 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 ,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 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

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

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

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

M/S. PUNJAB INSTITUTE OF MEDICAL SCIENCES ,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 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 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 JAMMU COOPERATIVE WHOLE SALE LIMITED,JAMMU vs. INCOME TAX OFFICER WARD-2 (1), JAMMU

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjeei.T.A. No. 150/Asr/2020 Assessment Year: 2005-06 M/S Jammu Cooperative Whole Sale The Ito Limited (Super Bazar) Old Hospital Ward-2(1) Road, City Chowk, Jammu- Jammu 180001(J&K)-180001

reopen matters concluded by an order under sections 154, 155, 260, 262, or 263. I.T.A. No. 150/Asr/2020 Assessment Year: 2005-06 5 6.2 We are of the considered view that the CIT(A) has been justified in observing that the grievance against the AO for not having invoked the provisions of section 152 to drop the re-assessment proceedings cannot

SHRI SHAM SUNDER AGGARWAL,KAPURTHALA vs. PRINCIPAL COMMISSIONER OF INCOME TAX -1, JALANDHAR

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

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

disallowed. ii) Firstly, for reopening of this case, when it had already been assessed u/s.143(3), in which the trading

INCOME TAX OFFICER, FEROZEPUR vs. MS.JATIN AGRO, FORT ROAD

In the result, the appeal of the revenue is dismissed

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta(Physical Hearing) I.T.A. No. 103 & 104/Asr/2024 Assessment Years: 2014-15 & 2017-18 Ito, Ward-3(1), Vs. M/S Jatin Agro Fort Road, Ferozepur. 152-P, Ferozepur. [Pan:-Aarpm5393F] (Appellant) (Respondent) Sh. Ashray Sarna, Ca Appellant By Respondent By Sh. Sunil Gautam, Cit. Dr

reopened u/s 148 vide notice dated 29.03.2019 (after necessary approval from higher authorities), mainly on the issue regarding availability of deduction claimed u/s 35AD(8)(c)(ii) of the Act. I.T.A. No. 103 & 104/Asr/202 Assessment Years: 2014-15 and 2017-18 4 The relevant portion of the recorded reasons are reproduced below for ready reference: “2. The assessee has constructed

INCOME TAX OFFICER, WARD-3(1),FEROZEPUR, FEROZEPUR vs. MS.JATIN AGRO, FORT ROAD

In the result, the appeal of the revenue is dismissed

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta(Physical Hearing) I.T.A. No. 103 & 104/Asr/2024 Assessment Years: 2014-15 & 2017-18 Ito, Ward-3(1), Vs. M/S Jatin Agro Fort Road, Ferozepur. 152-P, Ferozepur. [Pan:-Aarpm5393F] (Appellant) (Respondent) Sh. Ashray Sarna, Ca Appellant By Respondent By Sh. Sunil Gautam, Cit. Dr

reopened u/s 148 vide notice dated 29.03.2019 (after necessary approval from higher authorities), mainly on the issue regarding availability of deduction claimed u/s 35AD(8)(c)(ii) of the Act. I.T.A. No. 103 & 104/Asr/202 Assessment Years: 2014-15 and 2017-18 4 The relevant portion of the recorded reasons are reproduced below for ready reference: “2. The assessee has constructed

SHRI AMRIK SINGH,AMRITSAR vs. INCOME TAX OFFICER WARD-4 (1), AMRITSAR

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

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

disallowance of interest u/s 36(l)(iii) 2. The Learned CIT (A) has erred in law and facts and circumstances of the case by making addition on grounds entirely different from grounds on which assessment was reopened

NEERAJ KUMAR SETHI,DELHI vs. ITO, NATIONAL FACELESS APPEAL CENTRE (NFAC)

In the result, the appeal filed by the assessee is allowed

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

assessment completed u/s 143(3) dated 24/10/2016, on a total income of Rs.5.09 lakhs, with a minor estimated disallowance of Rs. 60,000/- on account of unvouched expenses. 5. Subsequently, the case was reopened