M/S. SADHU SINGH HAMDARD TRUST,JALANDHAR vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

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

disallow the expenditure under Section 40A(2). 12. Burden of proof lies on the Revenue to prove that the salary/rental payments made were excessive/unreasonable and that provisions of section 13 apply: Section 13 starts with a non-obstante clause and hence by virtue of the said provisions, exception to the exemption provided by section 11, is carved

M/S SADHU SINGH HAMDARD TRUST,JALANDHAR vs. THE ADDL. COMMISSIONER OF INCOME TAX, JALANDHAR

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

disallow the expenditure under Section 40A(2). 12. Burden of proof lies on the Revenue to prove that the salary/rental payments made were excessive/unreasonable and that provisions of section 13 apply: Section 13 starts with a non-obstante clause and hence by virtue of the said provisions, exception to the exemption provided by section 11, is carved

M/S. SADHU SINGH HAMDARD TRUST,JALANDHAR vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

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

disallow the expenditure under Section 40A(2). 12. Burden of proof lies on the Revenue to prove that the salary/rental payments made were excessive/unreasonable and that provisions of section 13 apply: Section 13 starts with a non-obstante clause and hence by virtue of the said provisions, exception to the exemption provided by section 11, is carved

THE DCIT, JALANDHAR vs. M/S. SADHU SINGH HAMDARD TRUST, JALANDHAR

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

disallow the expenditure under Section 40A(2). 12. Burden of proof lies on the Revenue to prove that the salary/rental payments made were excessive/unreasonable and that provisions of section 13 apply: Section 13 starts with a non-obstante clause and hence by virtue of the said provisions, exception to the exemption provided by section 11, is carved

DCIT, JALANDHAR vs. M/S. SADHU SINGH HAMDARD TRUST, JALANDHAR

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

disallow the expenditure under Section 40A(2). 12. Burden of proof lies on the Revenue to prove that the salary/rental payments made were excessive/unreasonable and that provisions of section 13 apply: Section 13 starts with a non-obstante clause and hence by virtue of the said provisions, exception to the exemption provided by section 11, is carved

THE ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR vs. M/S. SADHU SINGH HAMDARD TRUST, JALANDHAR

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

disallow the expenditure under Section 40A(2). 12. Burden of proof lies on the Revenue to prove that the salary/rental payments made were excessive/unreasonable and that provisions of section 13 apply: Section 13 starts with a non-obstante clause and hence by virtue of the said provisions, exception to the exemption provided by section 11, is carved

THE ASSISTANT COMMISSIONER OF INCOME TAX,JALANDHAR vs. M/S. SADHU SINGH HAMDARD TRUST, JALANDHAR

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

disallow the expenditure under Section 40A(2). 12. Burden of proof lies on the Revenue to prove that the salary/rental payments made were excessive/unreasonable and that provisions of section 13 apply: Section 13 starts with a non-obstante clause and hence by virtue of the said provisions, exception to the exemption provided by section 11, is carved

THE ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR vs. M/S. SADHU SINGH HAMDARD TRUST, JALANDHAR

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

disallow the expenditure under Section 40A(2). 12. Burden of proof lies on the Revenue to prove that the salary/rental payments made were excessive/unreasonable and that provisions of section 13 apply: Section 13 starts with a non-obstante clause and hence by virtue of the said provisions, exception to the exemption provided by section 11, is carved

THE ASSISTANT COMMISSIONER OF INCOME TAX,JALANDHAR vs. M/S. SADHU SINGH HAMDARD TRUST, JALANDHAR

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

disallow the expenditure under Section 40A(2). 12. Burden of proof lies on the Revenue to prove that the salary/rental payments made were excessive/unreasonable and that provisions of section 13 apply: Section 13 starts with a non-obstante clause and hence by virtue of the said provisions, exception to the exemption provided by section 11, is carved

DEPUTY COMMISSIONER OF INCOME TAX, JALANDHAR vs. M/S. SADHU SINGH HAMDARD TRUST,, JALANDHAR

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

disallow the expenditure under Section 40A(2). 12. Burden of proof lies on the Revenue to prove that the salary/rental payments made were excessive/unreasonable and that provisions of section 13 apply: Section 13 starts with a non-obstante clause and hence by virtue of the said provisions, exception to the exemption provided by section 11, is carved

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

17. The issue of what is a 'finding' in an adjudicatory/ appellate order is no longer res integra. The Supreme Court while dealing with a provision similar to Section 150 of the Act found in Section 34(3) of the Income Tax Act, 1922 in ITO v/s. Murlidar Bhagwan Das 52 ITR 335 has explained the meaning of finding' thus

M. K HOTEL & RESORTS LIMITED,AMRITSAR vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1, AMRITSAR

In the result, the appeal of the assessee bearing ITA 192/Asr/2022 is

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjeei.T.A. No.23/Asr/2023 Assessment Year: 2019-20 Ess Ess Kay Engineering Co. Vs. Nfac, Delhi/C/O Asstt. Pvt. Ltd. Factory Area, Commissioner Of Income Jalandhar. Tax Circle-4, Jalandhar. [Pan: Aaace5057G] (Respondent) (Appellant)

3(b), section 2(24) - which defines various kinds of "income" - inserted clause (x). This is a significant amendment, because Parliament intended that amounts not earned by the assessee, but received by it, - whether in the form of deductions, or otherwise, as receipts, were to be treated as income. The inclusion of a class of receipt, i.e., amounts received

ESS ESS KAY ENGINEERING COMPAY PRIVATE LIMITED ,KAPURTHALA vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-4, JALANDHAR

In the result, the appeal of the assessee bearing ITA 192/Asr/2022 is

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjeei.T.A. No.23/Asr/2023 Assessment Year: 2019-20 Ess Ess Kay Engineering Co. Vs. Nfac, Delhi/C/O Asstt. Pvt. Ltd. Factory Area, Commissioner Of Income Jalandhar. Tax Circle-4, Jalandhar. [Pan: Aaace5057G] (Respondent) (Appellant)

3(b), section 2(24) - which defines various kinds of "income" - inserted clause (x). This is a significant amendment, because Parliament intended that amounts not earned by the assessee, but received by it, - whether in the form of deductions, or otherwise, as receipts, were to be treated as income. The inclusion of a class of receipt, i.e., amounts received

KAY SWITCGEARS INDIA PRIVATE LIMITED,KAPURTHALA vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-4, JALANDHAR

In the result, the appeal of the assessee bearing ITA 192/Asr/2022 is

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjeei.T.A. No.23/Asr/2023 Assessment Year: 2019-20 Ess Ess Kay Engineering Co. Vs. Nfac, Delhi/C/O Asstt. Pvt. Ltd. Factory Area, Commissioner Of Income Jalandhar. Tax Circle-4, Jalandhar. [Pan: Aaace5057G] (Respondent) (Appellant)

3(b), section 2(24) - which defines various kinds of "income" - inserted clause (x). This is a significant amendment, because Parliament intended that amounts not earned by the assessee, but received by it, - whether in the form of deductions, or otherwise, as receipts, were to be treated as income. The inclusion of a class of receipt, i.e., amounts received

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, he placed reliance on Apex Court Judgement in the case of M/s. Saraf Exports Vs. Commissioner of Income Tax-III, in Civil Appeal No. 4822 of 2022 [@SLP (C) No.17539 of 2016] rendered on the provisions of section 80IB, affirming their view

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, he placed reliance on Apex Court Judgement in the case of M/s. Saraf Exports Vs. Commissioner of Income Tax-III, in Civil Appeal No. 4822 of 2022 [@SLP (C) No.17539 of 2016] rendered on the provisions of section 80IB, affirming their view

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, he placed reliance on Apex Court Judgement in the case of M/s. Saraf Exports Vs. Commissioner of Income Tax-III, in Civil Appeal No. 4822 of 2022 [@SLP (C) No.17539 of 2016] rendered on the provisions of section 80IB, affirming their view

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, he placed reliance on Apex Court Judgement in the case of M/s. Saraf Exports Vs. Commissioner of Income Tax-III, in Civil Appeal No. 4822 of 2022 [@SLP (C) No.17539 of 2016] rendered on the provisions of section 80IB, affirming their view

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, he placed reliance on Apex Court Judgement in the case of M/s. Saraf Exports Vs. Commissioner of Income Tax-III, in Civil Appeal No. 4822 of 2022 [@SLP (C) No.17539 of 2016] rendered on the provisions of section 80IB, affirming their view