NASA AGRO INDUSTRIES PRIVATE LIMITED,FAZILKA vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-II, BATHINDA

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

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

Section 147 (a) of the Act the Act. (2) If satisfaction is arrived at on the basis of any relevant material, such satisfaction cannot be assailed, Tilak raj bedi vs JCIT (2009) 319 ITR 385-P&H- The power of reassessment can be validly exercised if satisfaction is arrived at after following due procedure that income had escaped assessment. Such

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

disallowances under section 148 of the Income-tax Act, in the relevant assessment years in terms of section 150(1) read with Explanation 2 of section 153 in respect of deletion of both amounts made in this order." The Assessing Officer relied upon the aforesaid observations to support the notices issued on the ground that there were finding/ directions given

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

section 147 and also on the ground that the sanction granted by the JCIT is not in accordance of mandate of law. For this purpose, reliance is placed on the decision in the case of Smt. Prabha Rani Agarwal V. ITO. Copy at pages 1-7 of compendium. 5 6. From the reasons recorded it can be seen that just

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

147 / 148 , against the assessee, (for which the assessee is not in appeal ), but he has decided the issue in favour of the assessee, on merits of the case allowing the appeal by observing as follows: “Legal contention: I have perused the assessment order and the submission made by the Appellant. The AO has issued notice under section

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

147 / 148 , against the assessee, (for which the assessee is not in appeal ), but he has decided the issue in favour of the assessee, on merits of the case allowing the appeal by observing as follows: “Legal contention: I have perused the assessment order and the submission made by the Appellant. The AO has issued notice under section

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

disallowed the exemption claimed by the appellant under section 10(23C(iiiab) of Rs.4,48,83,790/-. 4. That the appellant craves to add, amend or alter any ground of appeal before or at the time of hearing of appeal, with the permission of the Hon’ble Income Tax Appellate Tribunal, Amritsar.” Grounds of Appeal in ITA 715/ASR/2019 5 I.T.A

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

disallowed the exemption claimed by the appellant under section 10(23C(iiiab) of Rs.4,48,83,790/-. 4. That the appellant craves to add, amend or alter any ground of appeal before or at the time of hearing of appeal, with the permission of the Hon’ble Income Tax Appellate Tribunal, Amritsar.” Grounds of Appeal in ITA 715/ASR/2019 5 I.T.A

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

disallowed the exemption claimed by the appellant under section 10(23C(iiiab) of Rs.4,48,83,790/-. 4. That the appellant craves to add, amend or alter any ground of appeal before or at the time of hearing of appeal, with the permission of the Hon’ble Income Tax Appellate Tribunal, Amritsar.” Grounds of Appeal in ITA 715/ASR/2019 5 I.T.A

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

147 of the Income Tax Act, 1961 (hereinafter referred to as the Act). 4. Facts of the case in brief are that the assessee filed its original return of income on 30.09.2008 declaring an income of Rs.4,63,33,441/-. Thereafter, a search u/s 132 of the Act was carried out on assesse’s group on 22.01.2009. In response

THE ASSTT. COMMISSIONER OF INCOME TAX, JALANDHAR vs. M/S BROADWAY OVERSEAS LTD., JALANDHAR

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

disallowance of exemption u/s 10B of the Income Tax Act claimed on income arising out of export incentives. 2. That Ld. CIT(A) has erred in facts as well as law by ignoring the findings of the TPO and holding that LIBOR rate should be applied on interest advanced to Associate Enterprises in US and thereby deleting the addition

BRODAWAYS OVERSEAS LIMITED,JALANDHAR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, JALANDHAR

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

disallowance of exemption u/s 10B of the Income Tax Act claimed on income arising out of export incentives. 2. That Ld. CIT(A) has erred in facts as well as law by ignoring the findings of the TPO and holding that LIBOR rate should be applied on interest advanced to Associate Enterprises in US and thereby deleting the addition

THE ASSTT. COMMISSIONER OF INCOME TAX, JALANDHAR vs. M/S BROADWAY OVERSEAS LTD., JALANDHAR

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

disallowance of exemption u/s 10B of the Income Tax Act claimed on income arising out of export incentives. 2. That Ld. CIT(A) has erred in facts as well as law by ignoring the findings of the TPO and holding that LIBOR rate should be applied on interest advanced to Associate Enterprises in US and thereby deleting the addition

THE ASSTT. COMMISSIONER OF INCOME TAX, JALANDHAR vs. M/S BROADWAY OVERSEAS LTD., JALANDHAR

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

disallowance of exemption u/s 10B of the Income Tax Act claimed on income arising out of export incentives. 2. That Ld. CIT(A) has erred in facts as well as law by ignoring the findings of the TPO and holding that LIBOR rate should be applied on interest advanced to Associate Enterprises in US and thereby deleting the addition

THE ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR vs. M/S BROADWAYS OVERSEAS LTD, JALANDHAR

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

disallowance of exemption u/s 10B of the Income Tax Act claimed on income arising out of export incentives. 2. That Ld. CIT(A) has erred in facts as well as law by ignoring the findings of the TPO and holding that LIBOR rate should be applied on interest advanced to Associate Enterprises in US and thereby deleting the addition

THE ASSTT. COMMISSIONER OF INCOME TAX, JALANDHAR vs. M/S BROADWAYS OVERSEAS LTD, JALANDHAR

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

disallowance of exemption u/s 10B of the Income Tax Act claimed on income arising out of export incentives. 2. That Ld. CIT(A) has erred in facts as well as law by ignoring the findings of the TPO and holding that LIBOR rate should be applied on interest advanced to Associate Enterprises in US and thereby deleting the addition

THE ASSTT. COMMISSIONER OF INCOME TAX, JALANDHAR vs. M/S BROADWAY OVERSEAS LTD., JALANDHAR

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

disallowance of exemption u/s 10B of the Income Tax Act claimed on income arising out of export incentives. 2. That Ld. CIT(A) has erred in facts as well as law by ignoring the findings of the TPO and holding that LIBOR rate should be applied on interest advanced to Associate Enterprises in US and thereby deleting the addition

SH. MANGAT TREHAN ,HOSHIARPUR vs. ASSISTANT COMMISSIONER OF INCOME -TAX, HOSHIARPUR

In the result, the appeal of the assessee bearing ITA 223/Asr/2019 is 10

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

147 read with section 148 of the Income-tax Act, 1961 by reasons of the failure on the part of the assessee to disclose fully and truly all material facts necessary' for his assessment for the assessment year 2007-08. Therefore, notice u/s 148 is issued to bring to tax the income of Rs.27,28,351/- and any other income

M/S. SATIA INDUSTRIES LIMITED,MUKTSAR vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1, BATHINDA

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

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

147, or section 148, or even section 263 of the Act if requisite conditions are fulfilled. It is inconceivable, according to Sardari Lal, that in the presence of such specific provisions, a similar power is available to the I.T.A. No.193/Asr/2022 38 Assessment Year: 2018-19 first appellate authority. Eventually, Sardari Lal upheld the decision in Union Tyres