SHRI NAROTAM SINGH,MANSA vs. INCOME TAX OFFICER WARD -1(4), MANSA

In the result, both the appeals of the assessees are allowed

151(2), has not been recorded in accordance with the procedure laid down under the Act. (iii) The provisions of Section 45(3) are also not applicable because it is only a deeming provision which creates fiction only to fix the, year of transfer and consideration on transfer but there is no fiction regarding accrual of profits and gains

SHRI TARLOCHAN SINGH,MANSA vs. INCOME TAX OFFICER WARD-1(4), MANSA

In the result, both the appeals of the assessees are allowed

151(2), has not been recorded in accordance with the procedure laid down under the Act. (iii) The provisions of Section 45(3) are also not applicable because it is only a deeming provision which creates fiction only to fix the, year of transfer and consideration on transfer but there is no fiction regarding accrual of profits and gains

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

reassessment proceedings is bad in law on the ground that the satisfaction recorded by JCIT is not in accordance with mandate of law and the requirements of section 151 have not been fulfilled.” Accordingly the ld. AR of the assessee submitted that the additional ground filed by the assessee, being legal in nature, goes to the root of the matter

SOM RAJ,PATHANKOT vs. THE INCOME TAX OFFICER, PATHANKOT

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

reassessment proceedings under section 147 r.w.s 148 of the Act, it is not in dispute that the A.O. is required to get the approval of the competent authority i.e; JCIT in the present case. Copy of the form for recording the reasons for initiating the proceedings under section 148 of ITA No. 628/Asr/2016

SHRI HARJINDER SINGH ,BATHINDA vs. INCOME TAX OFFICER, WARD-2(1), BATHINDA

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

reassessment proceedings under section 147 r.w.s 148 of the Act, it is not in dispute that the A.O. is required to get the approval of the competent authority i.e; JCIT in the present case. Copy of the form for recording the reasons for initiating the proceedings under section 148 of the Act and for obtaining the approval of the JCIT

SHRI NACHHATER SINGH S/O SHRI GURBAKSH SINGH,BATHINDA vs. INCOME TAX OFFICEER , BATHINDA

In the result all the appeals of the assessee are allowed for statistical purposes

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

2. Sh. Tek Chand 34-42 40 & 41 3. Sh. Chhugamal Rajpal 110-115 110 4. Omkam Developers Ltd. 116-140 127,128, 133 & 137 5. N.C. Cables Ltd. 141-145 141 d). Thus, on the basis of above said judgments, it was submitted that the reassessment proceedings are void abinitio on account of ‘mechanical ITA Nos. 162 to 164/Asr/2019

SHRI.BOOTA SINGH S/O. SH. NACHATER SINGH, BATHINDA vs. INCOME TAX OFFICER WARD-2(1), BATHINDA

In the result all the appeals of the assessee are allowed for statistical purposes

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

2. Sh. Tek Chand 34-42 40 & 41 3. Sh. Chhugamal Rajpal 110-115 110 4. Omkam Developers Ltd. 116-140 127,128, 133 & 137 5. N.C. Cables Ltd. 141-145 141 d). Thus, on the basis of above said judgments, it was submitted that the reassessment proceedings are void abinitio on account of ‘mechanical ITA Nos. 162 to 164/Asr/2019

SHRI BABBU SINGH S/O SHRI NACHHATER SINGH,BATHINDA vs. INCOME TAX OFFICEER WARD-2(1), BATHINDA

In the result all the appeals of the assessee are allowed for statistical purposes

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

2. Sh. Tek Chand 34-42 40 & 41 3. Sh. Chhugamal Rajpal 110-115 110 4. Omkam Developers Ltd. 116-140 127,128, 133 & 137 5. N.C. Cables Ltd. 141-145 141 d). Thus, on the basis of above said judgments, it was submitted that the reassessment proceedings are void abinitio on account of ‘mechanical ITA Nos. 162 to 164/Asr/2019

SHRI BALJINDER SINGH ,BATHINDA vs. INCOME TAX OFFICER, WARD 2(1), BATHINDA

In the result, both the appeals are disposed off in the terms indicated as above

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

2 of appellant assessee are dismissed. 10. The next issue is that the PCIT Bhatinda, has granted approval under section 151 of the act, without application of mind and that non service of Notice. 11. The Ld. Counsel submitted that the appellants cases have been reopened beyond 4 years and therefore, the PCIT’s sanction were taken in these cases

SHRIMATI MANJIT KAUR,BATHINDA vs. INCOME TAX OFFICER, WARD 2 (1), BATHINDA

In the result, both the appeals are disposed off in the terms indicated as above

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

2 of appellant assessee are dismissed. 10. The next issue is that the PCIT Bhatinda, has granted approval under section 151 of the act, without application of mind and that non service of Notice. 11. The Ld. Counsel submitted that the appellants cases have been reopened beyond 4 years and therefore, the PCIT’s sanction were taken in these cases

KHURSHID AHMAD DAR,JAMMU AND KASHMIR, INDIA vs. ITO WARD, UDHAMPUR, UDHAMPUR

In the result, the appeal of the assessee is allowed

Bench: Dr. Mitha Lalmeena, Hon'Ble & Shri Udayan Das Gupta, Hon'Blekhurshid Ahmad Dar Vs. Ito, Ward, Nully Poshwari Turkawangam, Udhampur Shopia, 192305, Jammu & Kashmir, India.Pin 192305. Pan No. Awmpd5664K Assessee By Shri Rohit Kapoor, Adv. & Shri V.S. Aggarwal, Itp. Revenue By Mrs. Roshanta Kumari Meena, Cit Dr. Date Of Hearing 23.09.2025. Date Of Pronouncement To. [1 .2025. Order Dr. Mitha Lal Meena, A.M.:

2. That the assessment framed under section 147 is bad in law as the notice under section 148 was issued on 13.04.2021 without adhering to the new procedure applicable from 01.04.2021, specifically without complying with the provisions of section 148A. 3. That the CIT(E) has erred in upholding the addition made by the AO without appreciating the fact that

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

151 by simply writing "Yes, I am Satisfied" is also invalid; reopening of assessment and consequent reassessment are quashed. 11. 426 ITR 228 (Bom) Gateway Leasing Pvt Ltd vs ACIT & Others REASSESSMENT-NOTICE-ONLY REASONS RECORDED BY ASSESSING OFFICER TO BE CONSIDERED-INFORMATION RECEIVED FROM INVESTIGATION WING SHOWING THAT ASSESSEE HAD TRADED IN SHARES WITH BENEFICIARY OF SEARCHED BOGUS COMPANY

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

151(2) of the Act, and one Late Sh. Gurmail Singh v. Dy. CIT & Ors additional legal ground that Notice u/s 143(2) issued on the same day of filing of lTR in response to notice u/s 148, has rendered the impugned assessment as invalid since issuance of such notice u/s 143(2) on same day is invalid. 27. Since

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

151(2) of the Act, and one Late Sh. Gurmail Singh v. Dy. CIT & Ors additional legal ground that Notice u/s 143(2) issued on the same day of filing of lTR in response to notice u/s 148, has rendered the impugned assessment as invalid since issuance of such notice u/s 143(2) on same day is invalid. 27. Since

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

151(2) of the Act, and one Late Sh. Gurmail Singh v. Dy. CIT & Ors additional legal ground that Notice u/s 143(2) issued on the same day of filing of lTR in response to notice u/s 148, has rendered the impugned assessment as invalid since issuance of such notice u/s 143(2) on same day is invalid. 27. Since

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

151(2) of the Act, and one Late Sh. Gurmail Singh v. Dy. CIT & Ors additional legal ground that Notice u/s 143(2) issued on the same day of filing of lTR in response to notice u/s 148, has rendered the impugned assessment as invalid since issuance of such notice u/s 143(2) on same day is invalid. 27. Since

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

151(2) of the Act, and one Late Sh. Gurmail Singh v. Dy. CIT & Ors additional legal ground that Notice u/s 143(2) issued on the same day of filing of lTR in response to notice u/s 148, has rendered the impugned assessment as invalid since issuance of such notice u/s 143(2) on same day is invalid. 27. Since

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

151(2) of the Act, and one Late Sh. Gurmail Singh v. Dy. CIT & Ors additional legal ground that Notice u/s 143(2) issued on the same day of filing of lTR in response to notice u/s 148, has rendered the impugned assessment as invalid since issuance of such notice u/s 143(2) on same day is invalid. 27. Since