M/S. SHREE-E-KASHMIR COLLEGE OF EDUCATIONAL,JAMMU vs. THE INCOME-TAX OFFICER, JAMMU

In the result, the captioned four appeals of the Assessee Trust are allowed

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

section 10(23cl of the Act, should have been allowed and there was no justification in assessing the income at Rs. 21,72,081/-. 5. That the Ld. CIT (Appeals) has further grossly erred in confirming the disallowance of interest amounting to Rs. 1,96

M/S. SHREE-E-KASHMIR COLLEGE OF EDUCATIONAL,JAMMU vs. THE INCOME-TAX OFFICER, JAMMU

In the result, the captioned four appeals of the Assessee Trust are allowed

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

section 10(23cl of the Act, should have been allowed and there was no justification in assessing the income at Rs. 21,72,081/-. 5. That the Ld. CIT (Appeals) has further grossly erred in confirming the disallowance of interest amounting to Rs. 1,96

M/S. SHREE-E-KASHMIR COLLEGE OF EDUCATIONAL,JAMMU vs. THE INCOME-TAX OFFICER, JAMMU

In the result, the captioned four appeals of the Assessee Trust are allowed

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

section 10(23cl of the Act, should have been allowed and there was no justification in assessing the income at Rs. 21,72,081/-. 5. That the Ld. CIT (Appeals) has further grossly erred in confirming the disallowance of interest amounting to Rs. 1,96

SH. PUNEET SEHDEV PROP,JAMMU vs. THE INCOME-TAX OFFICER, JAMMU

Bench: Shri L. P. Sahu & Shri Ravish Sood

section 2(24BA) of I.T.Act as under: “Manufacture” with its grammatical variations means a change in non-living physical object or article or thing:- a) Resulting in transformation of the object or article or thing into a new and distinct object or article or thing having a different name, character and use, or b) Bringing into existence

PUNEET SAHDEV,JAMMU vs. THE INCOME TAX OFFICER, JAMMU

Bench: Shri L. P. Sahu & Shri Ravish Sood

section 2(24BA) of I.T.Act as under: “Manufacture” with its grammatical variations means a change in non-living physical object or article or thing:- a) Resulting in transformation of the object or article or thing into a new and distinct object or article or thing having a different name, character and use, or b) Bringing into existence

SH. PUNEET SEHDEV PROP;,JAMMU vs. THE INCOME-TAX OFFICER,, JAMMU

Bench: Shri L. P. Sahu & Shri Ravish Sood

section 2(24BA) of I.T.Act as under: “Manufacture” with its grammatical variations means a change in non-living physical object or article or thing:- a) Resulting in transformation of the object or article or thing into a new and distinct object or article or thing having a different name, character and use, or b) Bringing into existence

INCOME TAX OFFICER, JAMMU vs. SH. PUNEET SEHDEV, PROP., JAMMU

Bench: Shri L. P. Sahu & Shri Ravish Sood

section 2(24BA) of I.T.Act as under: “Manufacture” with its grammatical variations means a change in non-living physical object or article or thing:- a) Resulting in transformation of the object or article or thing into a new and distinct object or article or thing having a different name, character and use, or b) Bringing into existence

M/S GRAND LILLY LIMITED ,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, appeal of the assessee is allowed for statistical purposes

Bench: Shri N.K. Choudhry & Shri O.P.Meenaआ.अ.संसंसंसं././././I.T.A Nos.667 To 669 /Asr/2017 िनधा"रणवष"/A.Ys.:2010-11, 2011-12 & 2012-13 िनधा"रणवष" िनधा"रणवष" िनधा"रणवष" M/S. Grand Lilly Motels Limited, Vs. Assistant Commissioner Of 4, Model Town, Jalandhar Income Tax, Pan: Aabcj 4527 E Circle- Iii, Jalandhar अपीलाथ" अपीलाथ"Appellant अपीलाथ" अपीलाथ" ""यथ" ""यथ"/Respondent ""यथ" ""यथ"

96,262 being disallowance under section 40A (3) of the Act. 13. We have heard the rival submissions and perused

M/S. GRAND LILLY MOTELS LTD,,JALANDHAR vs. THE ADDITIONAL COMMISSIONER OF INCOME-TAX, RANGE-3, JALANDHAR

In the result, appeal of the assessee is allowed for statistical purposes

Bench: Shri N.K. Choudhry & Shri O.P.Meenaआ.अ.संसंसंसं././././I.T.A Nos.667 To 669 /Asr/2017 िनधा"रणवष"/A.Ys.:2010-11, 2011-12 & 2012-13 िनधा"रणवष" िनधा"रणवष" िनधा"रणवष" M/S. Grand Lilly Motels Limited, Vs. Assistant Commissioner Of 4, Model Town, Jalandhar Income Tax, Pan: Aabcj 4527 E Circle- Iii, Jalandhar अपीलाथ" अपीलाथ"Appellant अपीलाथ" अपीलाथ" ""यथ" ""यथ"/Respondent ""यथ" ""यथ"

96,262 being disallowance under section 40A (3) of the Act. 13. We have heard the rival submissions and perused

GLITTERS FOREVER HOUSE KEEPING SERVICE PRIVATE LIMITED,SRINAGAR vs. INCOME TAX OFFICER WARD-1, SRINAGAR

In the result, both the appeals are allowed for statistical purpose

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

disallowance of Rs 34,96,001.00 u/s 36(1) (va) of the Act. it is submitted, that the additions made by CPC will not come under the ambit of provisions of sections

GLITTERS FOREVER HOSE KEEPING SERVICE PRIVATE LIMITED ,SRINAGAR vs. INCOME TAX OFFICER WARD-1, SRINAGAR

In the result, both the appeals are allowed for statistical purpose

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

disallowance of Rs 34,96,001.00 u/s 36(1) (va) of the Act. it is submitted, that the additions made by CPC will not come under the ambit of provisions of sections

THE ASSTT. COMMISSIONER OF INCOME TAX, JAMMU vs. M/S KAISER INDUSTRIES PVT. LTD, SAMBA

In the result, the appeal of the Revenue is dismissed

Bench: Sh. N. S. Saini & Sh. N. K. Choudhryita No. 381/Asr./2016 : Asstt. Year : 2006-07 Asstt. Commissioner Of Income Vs M/S Kaiser Industries Pvt. Ltd., Tax, Circle-1, Jammu Industrial Growth Centre, Sidco, Samba (Appellant) (Respondent) Pan No. Aabck0456G Assessee By : Shri. Vasu Gupta, Ca Revenue By : Sh. Yashender Garg, Dr Date Of Hearing :21.02.2019 Date Of Pronouncement : 22.03.2019 Order Per N. S. Saini: This Is An Appeal Filed By The Revenue Against The Order Of Commissioner Of Income Tax (Appeals), Jammu Dated 31.03.2016. 2. The Sole Issue Involved In This Appeal Is That The Commissioner Of Income Tax (Appeals) Erred In Allowing The Deduction U/S 80Ib(4) Of The Income Tax Act, 1961 In Respect Of Samba Unit As The Same Was Claimed To Inflate The Profit Of Eligible Unit For The Motive Of Availing Deduction U/S 80Ib.

disallowance under Section 80-IB (4) are not violated hence 80-IB (4) deduction should have been allowed. However, the Ld. A.O. in her report has suggested apportionment of common expenditure. Having perused the details placed on records, I observe from the assessment order that common expenses which have been discussed to be debited in Bahadurgarh unit are as under

THE DHAMAI COOPERATIVE AGRICULTURE SERVICE SOCIETY LIMITED,HOSHIARPUR vs. INCOME TAX OFFICER , HOSHIARPUR

In the result, the appeals filed by the appellant are allowed and the order(s) of the Kerala High Court and other authorities to the contrary are set aside

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjeei.T.A. No.273/Asr/2023 Assessment Year: 2017-18

96 Taxman 509 (PUNJ. & HAR.). “6. Section 80P(2)(d) allows whole deduction of an income by way of interest or dividends derived by the co- operative society from its investment with any other co- operative society. This provision does not make any distinction in regard to the source of the investment because this section envisages deduction in respect

THE DHAMAI COOPERATIVE AGRICULTURE SERVICE SOCIETY LIMITED,HOSHIARPUR vs. INCOME TAX OFFICER WARD, HOSHIARPUR

In the result, appeal of the assessee ITA No

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjeei.T.A. No.238/Asr/2023 Assessment Year: 2020-21

96 Taxman 509 (PUNJ. & HAR.). “6. Section 80P(2)(d) allows whole deduction of an income by way of interest or dividends derived by the co- operative society from its investment with any other co- operative society. This provision does not make any distinction in regard to the source of the investment because this section envisages deduction in respect

THE KOT RAM DASS COOP. THIRFT & CREDIT SOCIETY LIMITED,JALANDHAR vs. INCOME TAX OFFICER WARD-2 (4), JALANDHAR

In the result, appeal of the assessee ITA No

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjeei.T.A. No.86/Asr/2021 Assessment Year: 2017-18

disallowed the deduction for violation of Section 80P(2)(d) of the the Act. In relation to restriction u/s 80P(4) of the Act. The interest was added back with the total income as income amount of Rs.21,05,192/- as income from other sources. The Revenue authorities had relied I.T.A. No.86/Asr/2021 3 Assessment Year: 2017-18 on the order

THE INCOME TAX OFFICER, SAMBA vs. SH. ASHOK KUMAR SHARMA, SAMBA

In the result, the appeal of the revenue in Ground nos

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjeei.T.A. No.475/Asr/2016 Assessment Year: 2013-14

disallowance U/s 40A(3) amount to Rs. 8,38,000/-.Being aggrieved the assessee filed the appeal before the ld. CIT(A). The CIT(A) allowed the appeal of the assessee. Being aggrieved revenue filed an appeal before us. Ground No.1 4. In the ground no. 1 of the revenue, the DR vehemently argued and contended that

SATIA INDUSTRIES LIMITED,MUKTSAR vs. DCIT/ACIT CIRCLE I, BATHINDA, BATHINDA

In the result, the appeal of the assessee is partly allowed

Bench: Dr. M. L. Meena & Sh. Udayan Dasgupta

disallowance to the extent of Rs. 51,74,713/- on the ground that the underlying expenditure was not in the nature of a donation, but rather a mandatory contribution towards Corporate Social Responsibility (CSR) as specified under the Companies Act, 2013. That A.O. failed to appreciate that CSR contribution to the registered institutions is permissible under section 80G of Income

M/S NARULA OIL & FATS PRIVATE LIMITED,AHEMDABAD vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR

In the result, the appeals of the revenue are dismissed and appeals of assessee are allowed in the terms indicated above

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

96 taxmann.com 468 (SC) “Section 153A of the Income-tax Act, 1961 - Search and seizure (General principles) - Assessment years 2001-02 to 2003-04 and 2004-05 - High Court in impugned order held that invocation of section 153A to re-open concluded assessments of assessment years earlier to year of search was not justified in absence of incriminating material found