SHRI SANTOKH SINGH ,AMRITSAR vs. INCOME TAX OFFICER WARD - 2 (1), AMRITSAR

The appeals of the assessees are disposed of in the terms indicated as above

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

54 which contains Board’s Circular No. 452, dated 17-3-1986 which has been issued in connection with section 44AB of the Income-tax Act, 1961. Reliance was placed on para 4 of the said circular according to which the Board were advised that so far as kachha arahatias were concerned, the turnover did not include sales effected

SHRI SANTOKH SINGH ,AMRITSAR vs. INCOME TAX OFFICER WARD- 2 (1), AMRITSAR

The appeals of the assessees are disposed of in the terms indicated as above

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

54 which contains Board’s Circular No. 452, dated 17-3-1986 which has been issued in connection with section 44AB of the Income-tax Act, 1961. Reliance was placed on para 4 of the said circular according to which the Board were advised that so far as kachha arahatias were concerned, the turnover did not include sales effected

SHRI CHANDAN BHARDWAJ,TARN TARAN vs. ASSISTANT COMMISSIONER OF INCOME TAX,CIRCLE-1, AMRITSAR

Bench: Dr. M. L. Meena & Sh. Ravish Sood

271(1)(c) could be levied as the proceedings initiated were not valid and in accordance with the Act. 3. That on merits also no penalty is called for. AO made an addition of Rs. 42,54,123/- on the basis of Form 26AS and applied the rate of 10%. CIT(A) reduced the addition

SH. JINDER PAL,AMRITSAR vs. INCOME TAX OFFICER, WARD - 4(2), AMRITSAR

Bench: Dr. M. L. Meena & Sh. Ravish Sood

271(1)(c) could be levied as the proceedings initiated were not valid and in accordance with the Act. 3. That on merits also no penalty is called for. AO made an addition of Rs. 42,54,123/- on the basis of Form 26AS and applied the rate of 10%. CIT(A) reduced the addition

SH. SARWAN SINGH PHILLAUR,JALANDHAR vs. THE INCOME TAX OFFICER, JALANDHAR

In the result, the appeal of the Revenue is dismissed and appeal filed by the assessee stands allowed

Bench: Sh. N. S. Saini & Sh. N. K. Choudhryi. T. A. No. 562/(Asr)/2015 Assessment Year: 2007-08

penalty levied u/s 271(1)(c) of the Act at Rs. 1,17,75,000/- (Rs. 1,50,75,000 - Rs. 33,00,000 ) . 3. constituting 95 persons and Ex.MLA of Punjab Legislative Assembly was formed which was the owner of 21.2 acres of land in Village Kansal, Distt. Mohali on 25.2.2007. The society named as Punjabi Co-operative Housing

THE INCOME TAX OFFICER, JALANDHAR vs. SH. SARWAN SINGH PHILLAUR, JALANDHAR

In the result, the appeal of the Revenue is dismissed and appeal filed by the assessee stands allowed

Bench: Sh. N. S. Saini & Sh. N. K. Choudhryi. T. A. No. 562/(Asr)/2015 Assessment Year: 2007-08

penalty levied u/s 271(1)(c) of the Act at Rs. 1,17,75,000/- (Rs. 1,50,75,000 - Rs. 33,00,000 ) . 3. constituting 95 persons and Ex.MLA of Punjab Legislative Assembly was formed which was the owner of 21.2 acres of land in Village Kansal, Distt. Mohali on 25.2.2007. The society named as Punjabi Co-operative Housing

SH. ARSPREET SINGH . S/O. LATE. SH. GURMAIL SINGH ,MUKTSAR vs. DY. COMMISSIONER OF INCOME TAX CIRCLE .II, BATHINDA

Appeals are disposed of in the terms and observation made as above

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

54,50,000 27,25,000 27,25,000 2013-14 37,50,000 18,75,000 18,75,000 Total 1,40,65000 70,32,500 70,32,500 Late Sh. Gurmail Singh v. Dy. CIT & Ors 17. The theory of working of peak credit based on noting’s of the debits and credits entries of both sides written

SH. ARASHPREET SINGH S/O LATE SH. GURMAIL SINGH,SHRI MUKATSAR vs. DY. COMMISSIONER OF INCOME TAX CIRCLE-II, BATHINDA

Appeals are disposed of in the terms and observation made as above

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

54,50,000 27,25,000 27,25,000 2013-14 37,50,000 18,75,000 18,75,000 Total 1,40,65000 70,32,500 70,32,500 Late Sh. Gurmail Singh v. Dy. CIT & Ors 17. The theory of working of peak credit based on noting’s of the debits and credits entries of both sides written

LATE. SH. GURMAIL SINGH S/O. SH. LAL SINGH,SRI MUKATSAR vs. DY.COMMISSIONER OF INCOME TAX CIRCLE -II, BATHINDA

Appeals are disposed of in the terms and observation made as above

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

54,50,000 27,25,000 27,25,000 2013-14 37,50,000 18,75,000 18,75,000 Total 1,40,65000 70,32,500 70,32,500 Late Sh. Gurmail Singh v. Dy. CIT & Ors 17. The theory of working of peak credit based on noting’s of the debits and credits entries of both sides written

LATE. SH. GURMAIL. SINGH. S/O. SH. LAL SINGH,SRI MUKATSAR vs. DY.COMMISSIONER OF INCOME TAX CIRCLE -II, BATHINDA

Appeals are disposed of in the terms and observation made as above

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

54,50,000 27,25,000 27,25,000 2013-14 37,50,000 18,75,000 18,75,000 Total 1,40,65000 70,32,500 70,32,500 Late Sh. Gurmail Singh v. Dy. CIT & Ors 17. The theory of working of peak credit based on noting’s of the debits and credits entries of both sides written

LATE. SH. GURMAIL. SINGH S/O. SH. LAL SINGH,SHRI MUKAT SAR vs. DY. COMMISSIONER OF 9INCOME TAX. CIRCLE -II, BATHINDA

Appeals are disposed of in the terms and observation made as above

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

54,50,000 27,25,000 27,25,000 2013-14 37,50,000 18,75,000 18,75,000 Total 1,40,65000 70,32,500 70,32,500 Late Sh. Gurmail Singh v. Dy. CIT & Ors 17. The theory of working of peak credit based on noting’s of the debits and credits entries of both sides written

SH. ARASHPREET SINGH S/O. LATE SH. GURMAIL SINGH,MUKTSAR vs. DY. COMMISSIONER OF INCOME TAX CERCLE- II, BATHINDA

Appeals are disposed of in the terms and observation made as above

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

54,50,000 27,25,000 27,25,000 2013-14 37,50,000 18,75,000 18,75,000 Total 1,40,65000 70,32,500 70,32,500 Late Sh. Gurmail Singh v. Dy. CIT & Ors 17. The theory of working of peak credit based on noting’s of the debits and credits entries of both sides written

LATE. SH. GUMAIL SINGH . S/O. SH. LAL SINGH,MUKTSAR vs. DY. COMMISSIONER OF INCOME TAX CIRCLE -II, BATHINDA

Appeals are disposed of in the terms and observation made as above

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

54,50,000 27,25,000 27,25,000 2013-14 37,50,000 18,75,000 18,75,000 Total 1,40,65000 70,32,500 70,32,500 Late Sh. Gurmail Singh v. Dy. CIT & Ors 17. The theory of working of peak credit based on noting’s of the debits and credits entries of both sides written

SH. ARASHPREET SINGH. S/O.LATE.SH. GURMAIL SINGH,MUKTSAR vs. DY. COMMISSIONER OF INCOME TAX .CIRCLE-II, BATHINDA

Appeals are disposed of in the terms and observation made as above

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

54,50,000 27,25,000 27,25,000 2013-14 37,50,000 18,75,000 18,75,000 Total 1,40,65000 70,32,500 70,32,500 Late Sh. Gurmail Singh v. Dy. CIT & Ors 17. The theory of working of peak credit based on noting’s of the debits and credits entries of both sides written

SH. ARASHPREET SINGH S/O. LATE SH. GURMAIL SINGH,MUKTSAR vs. DY. COMMISSIONER OF INCOME TAX CIRCLE-II, BATHINDA

Appeals are disposed of in the terms and observation made as above

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

54,50,000 27,25,000 27,25,000 2013-14 37,50,000 18,75,000 18,75,000 Total 1,40,65000 70,32,500 70,32,500 Late Sh. Gurmail Singh v. Dy. CIT & Ors 17. The theory of working of peak credit based on noting’s of the debits and credits entries of both sides written

LATE. SH. GURMAIL SINGH.S/O. LATE SH. LAL SINGH,SRI MUKTSAR vs. DY. COMMISSIONER OF INCOME TAX CIRCLE -II, BATHINDA

Appeals are disposed of in the terms and observation made as above

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

54,50,000 27,25,000 27,25,000 2013-14 37,50,000 18,75,000 18,75,000 Total 1,40,65000 70,32,500 70,32,500 Late Sh. Gurmail Singh v. Dy. CIT & Ors 17. The theory of working of peak credit based on noting’s of the debits and credits entries of both sides written

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

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

Penalty order u/s 271(1)(c), (Revenue) dated 11/03/2014. As the issues involved in the abovementioned appeals are inextricably interlinked or in fact interwoven, therefore, the same are being taken up and disposed off together by way of a common order. We shall first advert to the appeal of the assessee for A.Y 2008-09, wherein the impugned order

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

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

Penalty order u/s 271(1)(c), (Revenue) dated 11/03/2014. As the issues involved in the abovementioned appeals are inextricably interlinked or in fact interwoven, therefore, the same are being taken up and disposed off together by way of a common order. We shall first advert to the appeal of the assessee for A.Y 2008-09, wherein the impugned order