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

148 is issued for the A.Y. 2011-12." 21. Thereafter he further relied on the jurisdictional High Court in the case of Gurera Gas Cylinders P Ltd vs CIT [2002] 258 ITR 170 ( P & H ) to submit that the reasons recorded shows clearly that the AO has further investigated and has applied his mind to the information received

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

148 as well as repudiation of the claim of earlier year losses to be carried forward for adjustment against income of the assessment year under consideration are rejected. 7. The next grievance of the assesse is that the Ld. CIT(A)/NFAC, Delhi erred in confirming the addition of Rs. 27,500/- under section 40A(3) of the Act, against

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

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

section 143(3) of the Income Tax Act, 1961 (‘the Act’ hereinafter) dated 30.03.2014 for Assessment Year (A.Y.) 2008-09. 2. The appeal challenges the impugned order on the twin aspects on which the ld. CIT(A) has quashed the assessment, i.e., (i) that the reopening is invalid as a notice u/s. 148(1), issued

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

148 of the Act. Hence, it is held that the notice issued and reassessment complete is valid and the Appellants ground is dismissed. Issue on merits: I have gone through the submission made by the Appellant, the Appellant is an Association of Person which has been formed with the object of setting up and I.T.A. No. 103 & 104/Asr/202 1 Assessment

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

148 of the Act. Hence, it is held that the notice issued and reassessment complete is valid and the Appellants ground is dismissed. Issue on merits: I have gone through the submission made by the Appellant, the Appellant is an Association of Person which has been formed with the object of setting up and I.T.A. No. 103 & 104/Asr/202 1 Assessment

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

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

disallowing Rs. 2663573/ on account of alleged violation of the provisions of Section 40A(3) of the Act by making payment exceeding Rs. 20,000/- in cash without appreciating the submissions of the assessee. 8. The Ld. CIT(A) NFAC has erred on facts and lawwhile confirming the action of the AO of making the addition

THE INCOME TAX OFFICER, FEROZEPUR vs. M/S REHMAT TRADERS, FEROZEPUR CANTT.

In the result, the Revenue’s appeal is partly allowed

Bench: Sh. Sanjay Arora & Sh. N. K. Choudhryi.T.A. No. 454/Asr/2016 Assessment Year: 2010-11

disallowance was called for. For the aforesaid proposition, heavy reliance was placed on a recent judgement of the Hon’ble jurisdictional High Court in Gurdas Garg v. CIT (supra). In the said judgment, he averred, it stands held that once the transactions and the genuineness thereof is not questioned, a case is clearly made out for business expediency

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

148 iii 28-06- Notice under section 143(2) issued on Notice under 2021 Objections the 28/06/2021 providing the details of section 143(2) reopening reassessment of proceedings read with section assessment filed by 147 the assessee 8 I.T.A. No. 117/Asr/2024 Jalalabad Solvex Pvt. Ltd. v. Pr. CIT iv 08-12- Notice under The assessee has 2021 section

MESERS SUPERTECH FORGINGS(INDIA) PVT.LTD.,JALANDHAR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE IV, JALANDHAR

In the result, the appeal of the Assessee is allowed

148 could not be sustained”. What is explicit from the above discussion is that the so called ‘reasons recorded’ are merely the ipsi dixit of ADIT (Inv) Ludhiana, simply rewritten by the AO, without application of his own independent mind, as to facts and the information/material in his possession, if any. For all purposes, the report received from

SHRI VIJAY KUMAR AGGARWAL,JALANDHAR vs. INCOME TAX OFICER,WARD II(4), JALANDHAR

In the result, the appeals of the assessee are dismissed

Bench: Sh. N. S. Saini & Sh. N. K. Choudhryita No. 38/Asr./2017 : Asstt. Year : 2013-14 Ita No. 77/Asr./2017 : Asstt. Year : 2012-13

148/- in assessment years 2014- 15. 4. The brief facts are that in the assessment year 2013-14, the Assessing Officer observed that the assessee has debited interest of Rs.32,47,463/- paid to State Bank of Patiala. Since, the assessee had not paid the interest during the financial year, therefore, he disallowed the deduction for the same by invoking

SH. VIJAY KUMAR AGGARWAL, PROP.,JALANDHAR vs. INCOME TAX OFFICER, JALANDHAR

In the result, the appeals of the assessee are dismissed

Bench: Sh. N. S. Saini & Sh. N. K. Choudhryita No. 38/Asr./2017 : Asstt. Year : 2013-14 Ita No. 77/Asr./2017 : Asstt. Year : 2012-13

148/- in assessment years 2014- 15. 4. The brief facts are that in the assessment year 2013-14, the Assessing Officer observed that the assessee has debited interest of Rs.32,47,463/- paid to State Bank of Patiala. Since, the assessee had not paid the interest during the financial year, therefore, he disallowed the deduction for the same by invoking

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

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.” The ld AR mentioned that

THE INCOME TAX OFFICER, AMRITSAR. vs. SH. SHIV RAJ SINGH BAWA, AMRITSAR.

In the result, the Revenue’s appeal is allowed and the assessee’s CO, dismissed

Bench: Sh. Sanjay Arora & Sh. N. K. Choudhryi.T.A. No. 407/Asr/2016 Assessment Year: 2012-13

section. The expenditure for purchasing stock- in-trade is one of such outgoings. The value of the stock-in-trade has to be taken into account while determining the gross profits under s. 28 on principles of commercial accounting. The payments made for purchases would also be covered by the word "expenditure" and such payments can be disallowed if they

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

148 and relevant approval was received 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

MESERS SHREE BHAGWATI COTTON TRADERS,BATHINDA vs. INCOME TAX OFFICER,WARD 1 (2), BATHINDA

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

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

148, the ld. AO has erred to issue the notice by mentioning Rs.10 lac paid by the assessee. The said notice has no relevance with the observation in factual aspect. The reasons recorded in fact there is no live nexus related to this payment of Rs.10 lac and assessee’s books of account. Recorded reasons itself erroneous and the notice

INCOME TAX OFFICER,WARD 1 (2), BATHINDA vs. MESERS SHREE BHAGWATI COTTON TRADERS ,, BATHINDA

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

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

148, the ld. AO has erred to issue the notice by mentioning Rs.10 lac paid by the assessee. The said notice has no relevance with the observation in factual aspect. The reasons recorded in fact there is no live nexus related to this payment of Rs.10 lac and assessee’s books of account. Recorded reasons itself erroneous and the notice