SATIA INDUSTRIES LIMITED,MUKTSAR, PUNJAB vs. DCIT, ACIT CIRCLE 1, BATHINDA

In the result, the appeal is partly allowed

Bench: Shri Udayan Das Gupta & Shri Krinwant Sahayआयकरअपीलसं./Ita No. 527/Asr/2024 िनधा"रणवष" / Assessment Year : 2020-21

disallowance of deduction of Rs. 3,97,500 claimed under section 80G of the Act, being 50% of the eligible amount of donations made during the relevant previous year. 10. That the AO erred in confirming the deemed income of Rs 12,50,000 under section 41(1). That the addition is made solely based on information available

M/S GAUTAM ENGINEERING COMPANY,SRINAGAR vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-3, SRINAGAR

In the result the appeal of the assessee is dismissed

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

275/-. The CIT (A) failed to consider this aspect that in original assessment order framed u/s 143(3) dated 27.03.2015, the Ld A.O has already made an adhoc disallowance of 10% of expenses for want of vouchers on expenses. It is change of opinion and worthy CIT (A) is not lawful in his action in confirming the addition in order

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

275/(Asr)/2018 Assessment Year: 2013-14 The NBI Employees Co-op Vs. Pr. CIT-2, Jalandhar. Non-Agricultural Thrift & Credit Society Ltd., 328, Defence Colony, Jalandhar. [PAN: AADAT2684F] (Appellant) (Respondent) Appellant by : Sh. Ashray Sarna, CA. Respondent by: Shri Sunil Gautam, CIT-DR Date of Hearing: 20.12.2021 Date of Pronouncement: 21.02.2022 ORDER Per Dr. M. L. Meena

SHRI MADAL LAL,JALANDHAR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, JALANDHAR

In the result, all the appeals of the Assessee are allowed

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

275 ITR 294 has held that - “accordingly, the Tribunal held that notice u/s 148 of the Act was issued before recording the reasons u/s 148 (2) and therefore, initiation of proceedings u/s 148 assessment made in pursuance thereof were bad in law”. A similar view was taken by Hon’ble Punjab & Haryana High Court Baldev Gyan 248 ITR 266 wherein

MESRES ATHOULA CO-OP AGRICULTURE MULTIPURPOSE SERVICE SOCIETY LTD,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4, JALANDHAR

In the result, both the appeal filed by the assessee are dismissed

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

disallowance are rightly endorsed by the Ld CIT(A). The appellant ground that the Ld CIT(A) erred in not setting aside the bifurcation of balance sheet of the assessee (duly audited by its auditors) done by the Ld AO on the basis of interest bearing funds and non interest bearing funds, since the funds has no colour

M/S ATHOULA CO-OP AGRICLUTURE MULTIPURPOSE SERVICE SOCIETY LTD,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4, JALANDHAR

In the result, both the appeal filed by the assessee are dismissed

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

disallowance are rightly endorsed by the Ld CIT(A). The appellant ground that the Ld CIT(A) erred in not setting aside the bifurcation of balance sheet of the assessee (duly audited by its auditors) done by the Ld AO on the basis of interest bearing funds and non interest bearing funds, since the funds has no colour

THE DY. COMMISSIONER OF INCOME-TAX, JALANDHAR vs. M/S. MBD PRINTOGRAPHICS P.LTD,, JALANDHAR

In the result, all the appeals of department and that of assessee stand dismissed

Bench: Sh. Laliet Kumar & Dr. M. L. Meena

disallowed 80% of the claim made by the assessee u/s 80IC and relied upon the arguments as advanced by the Ld. CIT (DR) in the original proceedings before 17 I.T.A. No. 506/Asr/2011 and others the Hon’ble ITAT at the time of hearing of the appeal, which was decided by the Tribunal on 28.12.2012 for the same years

THE DY. COMMISSIONER OF INCOME-TAX, JALANDHAR vs. M/S. MBD PRINTOGRAPHICS PVT. LTD,, JALANDHAR

In the result, all the appeals of department and that of assessee stand dismissed

Bench: Sh. Laliet Kumar & Dr. M. L. Meena

disallowed 80% of the claim made by the assessee u/s 80IC and relied upon the arguments as advanced by the Ld. CIT (DR) in the original proceedings before 17 I.T.A. No. 506/Asr/2011 and others the Hon’ble ITAT at the time of hearing of the appeal, which was decided by the Tribunal on 28.12.2012 for the same years

M/S. MBD PRINTOGRAPHICS PVT LTD,JALANDHAR vs. THE DY. COMMISSIONER OF INCOME-TAX, JALANDHAR

In the result, all the appeals of department and that of assessee stand dismissed

Bench: Sh. Laliet Kumar & Dr. M. L. Meena

disallowed 80% of the claim made by the assessee u/s 80IC and relied upon the arguments as advanced by the Ld. CIT (DR) in the original proceedings before 17 I.T.A. No. 506/Asr/2011 and others the Hon’ble ITAT at the time of hearing of the appeal, which was decided by the Tribunal on 28.12.2012 for the same years

THE DY. COMMISSIONER OF INCOME-TAX, JALANDHAR vs. M/S. MBD PRINTOGRAPHICS PVT. LTD,, JALANDHAR

In the result, all the appeals of department and that of assessee stand dismissed

Bench: Sh. Laliet Kumar & Dr. M. L. Meena

disallowed 80% of the claim made by the assessee u/s 80IC and relied upon the arguments as advanced by the Ld. CIT (DR) in the original proceedings before 17 I.T.A. No. 506/Asr/2011 and others the Hon’ble ITAT at the time of hearing of the appeal, which was decided by the Tribunal on 28.12.2012 for the same years

THE DY. COMMISSIONER OF INCOME-TAX,, JALANDHAR vs. M/S. MBD. PRINTOGRAPHICS P.LTD,, JALANDHAR

In the result, all the appeals of department and that of assessee stand dismissed

Bench: Sh. Laliet Kumar & Dr. M. L. Meena

disallowed 80% of the claim made by the assessee u/s 80IC and relied upon the arguments as advanced by the Ld. CIT (DR) in the original proceedings before 17 I.T.A. No. 506/Asr/2011 and others the Hon’ble ITAT at the time of hearing of the appeal, which was decided by the Tribunal on 28.12.2012 for the same years

THE DEPUTY COMMISSIONER OF INCOME TAX, JALANDHAR vs. M/S. MBD PRINTOGRAPHICS P.LTD.,, JALANDHAR

In the result, all the appeals of department and that of assessee stand dismissed

Bench: Sh. Laliet Kumar & Dr. M. L. Meena

disallowed 80% of the claim made by the assessee u/s 80IC and relied upon the arguments as advanced by the Ld. CIT (DR) in the original proceedings before 17 I.T.A. No. 506/Asr/2011 and others the Hon’ble ITAT at the time of hearing of the appeal, which was decided by the Tribunal on 28.12.2012 for the same years

THE DY. COMMISSIONER OF INCOME-TAX, JALANDHAR vs. M/S. MBD. PRINTOGRAPHICS P.LTD,, JALANDHAR

In the result, all the appeals of department and that of assessee stand dismissed

Bench: Sh. Laliet Kumar & Dr. M. L. Meena

disallowed 80% of the claim made by the assessee u/s 80IC and relied upon the arguments as advanced by the Ld. CIT (DR) in the original proceedings before 17 I.T.A. No. 506/Asr/2011 and others the Hon’ble ITAT at the time of hearing of the appeal, which was decided by the Tribunal on 28.12.2012 for the same years

THE DY. COMMISSIONER OF INCOME-TAX, JALANDHAR vs. M/S. MBD. PRINTOGRAPHICS P.LTD,, JALANDHAR

In the result, all the appeals of department and that of assessee stand dismissed

Bench: Sh. Laliet Kumar & Dr. M. L. Meena

disallowed 80% of the claim made by the assessee u/s 80IC and relied upon the arguments as advanced by the Ld. CIT (DR) in the original proceedings before 17 I.T.A. No. 506/Asr/2011 and others the Hon’ble ITAT at the time of hearing of the appeal, which was decided by the Tribunal on 28.12.2012 for the same years

SHRI SWARAN SINGH,JALANDHAR vs. INCOME TAX OFFICER WARD-4(1), JALANDHAR

The appeal of the assesse is allowed in the terms indicated as above

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

275 ITR 124 (AT) (TM) “It is also true that the principles of res judicata do not apply to income tax proceedings but equally important, is the rule of consistency, which has been held to be applicable in tax proceedings. If the facts and circumstances of the earlier year are similar, the same view should ordinarily be followed