POONAM MARWAHA,AMRITSAR vs. ACIT DCIT CEN CIR, AMRITSAR

Bench: Sh. Vikram Singh Yadav & Sh. Udayan Dasgupta

u/s 143(3) without making any addition by stating that the appellant had duly considered the amount surrendered in the return of income filed. That the same facts were presented before the PCIT and it was submitted that even if the correct excess stock amounting to Rs. 1777416/- is considered and tax is calculated as per the provisions of section

SHRI SUKHJINDER SINGH,JALANDHAR vs. PRINICPAL COMMISSIONER OF INCOME TAX -1, JALANDHAR

In the result, appeal of the assessee is allowed

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

u/s 69A is concerned, could not be taken as an unexplained amount particularly when no defect whatsoever has been pointed out in the said bank statement and evidences filed by the appellant in support of its claim. In our view, the decision of Ld. PCIT proposing disallowance of entire amount of Rs. 12,38,000/- is not justified

SHRI GAGANDEEP GARG. PROP,BATHINDA 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

revised u/s 263 of the Act. The Ld. PCIT being not satisfied with the explanation furnished by the appellant assessee held the assessment order dated 31.03.2015 passed by the ITO, Ward-1(1), Bathinda in present case for the A.Y. 2015- 16 as erroneous and prejudicial to the interest of revenue u/s 263

SHRI AMRITPAL SINGH (PROP),JALANDHAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX- 1, JALANDHAR

In the result, appeal of the assessee ITA No

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

disallowed.” I.T.A. No. 425/Asr/2019 22 Assessment Year: 2014-15 6. The ld. DR vehemently argued and fully relied on the order of the ld. PCIT u/s 263. The relevant paragraph 3 of the said order is reproduced as below: “3. I have carefully considered written submissions and documents filed by the counsel of the assessee during the proceeding u/s 263

JALALABAD SOLVEX PRIVATE LTD,JALALABAD vs. PR COMMISSIONER OF INCOME TAX , AMRITSAR-1, PR COMMISSIONER OF INCOME TAX

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

Bench: Sh. Udayan Dasgupta & Sh. Krinwant Sahay

263 of the Act’61 , on the ground that the proper investigation and enquiry has not been made 5 I.T.A. No. 117/Asr/2024 Jalalabad Solvex Pvt. Ltd. v. Pr. CIT by the Assessing Officer, which has resulted in the order passed being erroneous and prejudicial to the interest of Revenue. The relevant portion of the shows cause notice is reproduced

THE NBI EMPLOYEES CO-OP NON-AGRICULTURAL THRIFT & CREDIT SOCIETY LIMITED ,JALANDHAR vs. PRINCIPAL COMMISIONER OF INCOME TAX-2, JALANDHAR

Bench: Sh. Ravish Sood & Dr. M. L. Meena

263 holding the assessment order erroneous and prejudicial to the interest of the revenue in view of the Hon’ble Juridiction High Court and the Apex Court (Supra), and directing the Assessing Officer so. 7. We have heard both the sides and perused the impugned orders, and the case law cited. It is admitted fact that the assessee society

WALIA CONSTRUCATION COMPANY ,PATHANKOT vs. PRINCIPAL COMMISSIONER OF INCOME TAX -1, AMRITSAR

In the result, appeal of the assessee ITA No

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

263 the assessee filed the submission before the ld. PCIT which was duly ignored. 5.1 The ld. AR invited our attention in the order of the ld. PCIT in pages 2 to 3 paragraphs 3 to 5 which are duly reproduced as below: “03. On 21-03-2022 the reply of the assessee received through ITBA which is reproduced

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

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

revision disallowing the special deduction was not valid." 9. The Hon,ble Chandigarh Tribunal in the case of Khushi Ram & Sons Pvt. Ltd. (supra) has decided similar issue wherein the assessee had surrendered an amount of Rs. 80 lacs during the course of survey on account of building renovation, office equipment and sundry receivables and claimed set off of unabsorbed

M/S TORRENT ROOFING SYSTEM,HOSHIARPUR vs. INCOME TAX OFFICER WARD-4, HOSHIARPUR

In the result, the appeal of the assesse is allowed for statistical

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

Disallowed the expanses to the tune of Rs 676050/- 25% of the total royalty paid in view of the Judgment of M/s Southern Switch Gear Ltd (232 ITR 359) But the facts of our case are entirety different from the facts of the case law relied on by the Pr CIT and A.O. We submitted many case law decided

LALLY MOTORS INDIA PVT. LTD,JALANDHAR vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX-2, JALANDHAR

In the result, the assessee’s appeal is dismissed

Bench: Sh. Sanjay Arora & Sh. N. K. Choudhryi.T.A. No. 218(Asr)/2017 Assessment Year: 2012-13

revision of the assessee’s assessment u/s. 143(3) of the Income Tax ('the Act' hereinafter) for Assessment Year (AY) 2012- 13 vide order dated 31.12.2014. 2. The question arising in the instant appeal is if the provision of section 263 of the Act stands rightly invoked in the facts and circumstances of the case. 2 ITA No.218 (Asr)/2017

OSAKA ALLOYS & STEEL PRIVATE LIMITED,JALANDHAR vs. DCIT/ACIT, CIRCLE-1, JLD, JALANDHAR

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

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

revision u/s 263 of the Act, and ultimately the issue travelled to the tribunal, and in ITA No. 257/Asr/2019 dated 26.06.2024the Hon’ble bench opined against assumption of jurisdiction u/s 263 by the Ld PCIT . 14. It is further argued by the ld. AR of the assessee that only mistakes which are apparent from the record can be rectified

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

Revision of orders prejudicial to revenue. 263.(1) The [Principal Commissioner or] Commissioner may call for and examine the record of any proceeding under this Act, and if he considers that any order passed therein by the Assessing] Officer is erroneous in so far as it is prejudicial to the interests of the revenue, he, may, after giving the assessee

SHRI SWAMI GANGA GIRI JANTA GIRLS COLLEGE,RAIKOOT vs. DEPUTY COMMISSIONER OF INCOME TAX (CPC), BANGALORE

In the result,the appeal of the assessee ITA No

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

U/s 263 & 250(6) of Income Tax Act, 1961(in brevity the Act) respectively. The assessment orders were framed by the ld. CPC & ITO, Exemption, Jalandhar (in brevity the AO). ITA 87/ASR/2022 2. The assessee has taken the following grounds: “1. That the order dated 29.03.2022 passed under section 263 of the Income Tax Act, 1961 by the Ld. Commissioner

SWAMI GANGA GIRI JANTA GIRLS COLLEGE,RAIKOT vs. INCOME TAX OFFICER (EXEMPTIONS) WARD, JALANDHAR

In the result,the appeal of the assessee ITA No

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

U/s 263 & 250(6) of Income Tax Act, 1961(in brevity the Act) respectively. The assessment orders were framed by the ld. CPC & ITO, Exemption, Jalandhar (in brevity the AO). ITA 87/ASR/2022 2. The assessee has taken the following grounds: “1. That the order dated 29.03.2022 passed under section 263 of the Income Tax Act, 1961 by the Ld. Commissioner

SWAMI GANGA GIRI JANTA GIRLS COLLEGE ,RAIKOT vs. COMMISSIONER OF INCOME TAX (EXEMPTIONS), CHANDIGARH

In the result,the appeal of the assessee ITA No

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

U/s 263 & 250(6) of Income Tax Act, 1961(in brevity the Act) respectively. The assessment orders were framed by the ld. CPC & ITO, Exemption, Jalandhar (in brevity the AO). ITA 87/ASR/2022 2. The assessee has taken the following grounds: “1. That the order dated 29.03.2022 passed under section 263 of the Income Tax Act, 1961 by the Ld. Commissioner

MEASAGE.OSAKA ALLOYS AND STEEL (P) LTD,JALANDHAR vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-II, JALANDHAR

The appeal stand dismissed

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Shri Udayan Dasgupta, Jm आयकर अपील सं. / Ita No.347/Asr/2019 (िनधा"रण वष" / Assessment Year: 2013-14) M/S Osaka Alloys & Steel (P) Ltd. Dcit Circle - Ii बनाम/ 428, Mota Singh Nagar, Jalandhar Jalandhar Punjab - 144001 C/O Bhagat & Co. (Ca) Vs. 16 Brij Nagar, Jalandhar, Punjab - 144001 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aaaco-7097-G (अपीलाथ"/Appellant) (" थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Adjournment Request " थ"कीओरसे/Respondent By : Sh. Farhat Khan (Cit) - Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 03-02-2026 घोषणाकीतारीख /Date Of Pronouncement 20.02.2026 : आदेश / O R D E R

disallowances and framed an assessment. Subsequently, Ld. Pr. CIT, upon perusal of case records, observed that the assessee worked out book profits of Rs.1,716/- after claiming deduction u/s 80IB for Rs.3,11,72,422/- which was not permissible deduction u/s 115JB. Such omission resulted in short computation of book profit. The Ld. AO failed to work out correct book

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

u/s 151 of the Act. During hearing before he ld. PCIT, the ld. AR submitted the following details which are enclosed in APB page 1 to 16. The relevant paragraph of assessee’s submission is extracted as below: 13. Now coming to the issues raised in the SCN as regards the alleged bogus purchases of Rs.1,97,93,175/- from

SHRI SATISH KUMAR. S/O. SH. HANS RAJ ,HOSHIARPUR vs. INCOME TAX OFFICER WARD-4, HOSHIARPUR

In the result, the appeal of the assessee stands allowed

Bench: Shri N.K. Choudhry & Shri O.P.Meenaआ.अ.संसंसंसं././././I.T.A No.258/Asr/2019 िनधा"रणवष"/A.Y.:2014-15 िनधा"रणवष" िनधा"रणवष" िनधा"रणवष" Shri Satish Kumar S/O Hans Raj, Vs. Principal Commissioner Of B-12, Mch-366/13, Billa Income-Tax-1, Jalandhar House, New Jagatpura, Hoshiarpur Pan: Aawpk 0932 D अपीलाथ" Appellant अपीलाथ" ""यथ"/Respondent ""यथ" अपीलाथ" अपीलाथ" ""यथ" ""यथ"

disallowed. The AO was require to make enquiry for recovery suit claim of Rs.2,26,53,638 and why these were not reflected in balance sheet. Satish Kumar v. Pr.CIT- Jalandhar/I.T.A.No. 258/ASR/2019/A.Y. 14-15 Page 6 of 20 Regarding Ahatas income the assessee has only filed a ledger account showing income received as Ahatas income but details of same