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

b) That the surrender was made by the appellant in the Assessment Year 2014-15 on the directions of the department. 7. That in the facts and circumstances of the case, the Ld. Commissioner of Income Tax (Appeals) gravelly erred in upholding the proceedings under section 147/148 of the Income Tax Act, 1961 as valid, though proceedings under section

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

b) That the surrender was made by the appellant in the Assessment Year 2014-15 on the directions of the department. 7. That in the facts and circumstances of the case, the Ld. Commissioner of Income Tax (Appeals) gravelly erred in upholding the proceedings under section 147/148 of the Income Tax Act, 1961 as valid, though proceedings under section

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

b) That the surrender was made by the appellant in the Assessment Year 2014-15 on the directions of the department. 7. That in the facts and circumstances of the case, the Ld. Commissioner of Income Tax (Appeals) gravelly erred in upholding the proceedings under section 147/148 of the Income Tax Act, 1961 as valid, though proceedings under section

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

b) That the surrender was made by the appellant in the Assessment Year 2014-15 on the directions of the department. 7. That in the facts and circumstances of the case, the Ld. Commissioner of Income Tax (Appeals) gravelly erred in upholding the proceedings under section 147/148 of the Income Tax Act, 1961 as valid, though proceedings under section

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

b) That the surrender was made by the appellant in the Assessment Year 2014-15 on the directions of the department. 7. That in the facts and circumstances of the case, the Ld. Commissioner of Income Tax (Appeals) gravelly erred in upholding the proceedings under section 147/148 of the Income Tax Act, 1961 as valid, though proceedings under section

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

b) That the surrender was made by the appellant in the Assessment Year 2014-15 on the directions of the department. 7. That in the facts and circumstances of the case, the Ld. Commissioner of Income Tax (Appeals) gravelly erred in upholding the proceedings under section 147/148 of the Income Tax Act, 1961 as valid, though proceedings under section

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

b) That the surrender was made by the appellant in the Assessment Year 2014-15 on the directions of the department. 7. That in the facts and circumstances of the case, the Ld. Commissioner of Income Tax (Appeals) gravelly erred in upholding the proceedings under section 147/148 of the Income Tax Act, 1961 as valid, though proceedings under section

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

b) That the surrender was made by the appellant in the Assessment Year 2014-15 on the directions of the department. 7. That in the facts and circumstances of the case, the Ld. Commissioner of Income Tax (Appeals) gravelly erred in upholding the proceedings under section 147/148 of the Income Tax Act, 1961 as valid, though proceedings under section

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

b) That the surrender was made by the appellant in the Assessment Year 2014-15 on the directions of the department. 7. That in the facts and circumstances of the case, the Ld. Commissioner of Income Tax (Appeals) gravelly erred in upholding the proceedings under section 147/148 of the Income Tax Act, 1961 as valid, though proceedings under section

M/S BLUE CITY TOWNSHIP & COLONIZERS,AMRITSAR. vs. THE INCOME TAX OFFICER,, AMRITSAR.

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

reassessment are held to be devoid of any merits and substance and therefore, same are as such rejected. 12. In ground no. 3 & 4, the assessee has challenged approval granted by the CIT u/s 151 for issuing notice u/s 147 as bad in law. This issue of approval granted u/s 151 of the Income

HIMANI GOYA SHARMA,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1, BATHINDA

The appeal stand allowed

Bench: HON’BLE SHRI MANOJ KUMAR AGGARWAL (Accountant Member), SHRI UDAYAN DAS GUPTA (Judicial Member)

B (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : अपीलाथीकीओरसे/ Appellant by : Sh. Devang Gargieya (Advocate) – Ld. AR प्रत्यथीकीओरसे/Respondent by : Sh. Charan Dass (Addl. CIT) – Ld. Sr. DR सुनवाईकीतारीख/Date of Hearing : 20-01-2026 घोषणाकीतारीख /Date of Pronouncement 20-01-2026 : आदेश / O R D E R 1. Aforesaid appeals by assessee for Assessment Years (AY) 2011- 12 to 2015-16 have

HIMANI GOYAL SHARMA,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1, BATHINDA

The appeal stand allowed

Bench: HON’BLE SHRI MANOJ KUMAR AGGARWAL (Accountant Member), SHRI UDAYAN DAS GUPTA (Judicial Member)

B (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : अपीलाथीकीओरसे/ Appellant by : Sh. Devang Gargieya (Advocate) – Ld. AR प्रत्यथीकीओरसे/Respondent by : Sh. Charan Dass (Addl. CIT) – Ld. Sr. DR सुनवाईकीतारीख/Date of Hearing : 20-01-2026 घोषणाकीतारीख /Date of Pronouncement 20-01-2026 : आदेश / O R D E R 1. Aforesaid appeals by assessee for Assessment Years (AY) 2011- 12 to 2015-16 have

HIMANI GOYAL SHARMA,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1, BATHINDA

The appeal stand allowed

Bench: HON’BLE SHRI MANOJ KUMAR AGGARWAL (Accountant Member), SHRI UDAYAN DAS GUPTA (Judicial Member)

B (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : अपीलाथीकीओरसे/ Appellant by : Sh. Devang Gargieya (Advocate) – Ld. AR प्रत्यथीकीओरसे/Respondent by : Sh. Charan Dass (Addl. CIT) – Ld. Sr. DR सुनवाईकीतारीख/Date of Hearing : 20-01-2026 घोषणाकीतारीख /Date of Pronouncement 20-01-2026 : आदेश / O R D E R 1. Aforesaid appeals by assessee for Assessment Years (AY) 2011- 12 to 2015-16 have

HIMANI GOYAL SHARMA,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1, BATHINDA

The appeal stand allowed

Bench: HON’BLE SHRI MANOJ KUMAR AGGARWAL (Accountant Member), SHRI UDAYAN DAS GUPTA (Judicial Member)

B (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : अपीलाथीकीओरसे/ Appellant by : Sh. Devang Gargieya (Advocate) – Ld. AR प्रत्यथीकीओरसे/Respondent by : Sh. Charan Dass (Addl. CIT) – Ld. Sr. DR सुनवाईकीतारीख/Date of Hearing : 20-01-2026 घोषणाकीतारीख /Date of Pronouncement 20-01-2026 : आदेश / O R D E R 1. Aforesaid appeals by assessee for Assessment Years (AY) 2011- 12 to 2015-16 have

HIMANI GOYAL SHARMA,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1, BATHINDA

The appeal stand allowed

Bench: HON’BLE SHRI MANOJ KUMAR AGGARWAL (Accountant Member), SHRI UDAYAN DAS GUPTA (Judicial Member)

B (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : अपीलाथीकीओरसे/ Appellant by : Sh. Devang Gargieya (Advocate) – Ld. AR प्रत्यथीकीओरसे/Respondent by : Sh. Charan Dass (Addl. CIT) – Ld. Sr. DR सुनवाईकीतारीख/Date of Hearing : 20-01-2026 घोषणाकीतारीख /Date of Pronouncement 20-01-2026 : आदेश / O R D E R 1. Aforesaid appeals by assessee for Assessment Years (AY) 2011- 12 to 2015-16 have

SAINIK CO-OPERATIVE HOUSE BUILDING SOCIETY LTD,JAMMU AND KASHMIR vs. ITO WARD 1(1), JAMMU, JAMMU AND KASHMIR

In the result, the appeal filed by the assessee is allowed for statistical purpose

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

section 149(1)(b) stands violated in this case. In support of his contention, he relied on the following decisions of 5 I.T.A. Nos. 701 & 406/Asr/2024 Assessment Year: 2015-16 various courts and Tribunals to argue that if more than three years have lapsed, then the notice u/s 148 can be issued only if value of income escaping is more

SAINIK COOPERATIVE HOUSE BUILDING SOCIETY LIMITED,SAINIK COLONY vs. INCOME TAX OFFICER - WARD-1, JAMMU

In the result, the appeal filed by the assessee is allowed for statistical purpose

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

section 149(1)(b) stands violated in this case. In support of his contention, he relied on the following decisions of 5 I.T.A. Nos. 701 & 406/Asr/2024 Assessment Year: 2015-16 various courts and Tribunals to argue that if more than three years have lapsed, then the notice u/s 148 can be issued only if value of income escaping is more

DCIT, CIRCLE-1, BATHINDA vs. DMR BUILDERS PVT LTD, BATHINDA

In the result the appeal of the revenue is dismissed being devoid of merits

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta(Hybrid Hearing) I.T.A. Nos. 292 & 293/Asr/2024 Assessment Years: 2016-17 & 2017-18

271 (1)(c) of the Act for concealing particulars of income are simultaneously initiated.” 8. The matter was carried in appeal before the first appellate authority and the Ld. CIT (A), has considered all materials on record and has arrived at the conclusion that in absence of any material brought on record there is not even a single evidence

DCIT, CIRCLE-1, BATHINDA vs. DMR BUILDERS PVT LTD, BATHINDA

In the result the appeal of the revenue is dismissed being devoid of merits

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta(Hybrid Hearing) I.T.A. Nos. 292 & 293/Asr/2024 Assessment Years: 2016-17 & 2017-18

271 (1)(c) of the Act for concealing particulars of income are simultaneously initiated.” 8. The matter was carried in appeal before the first appellate authority and the Ld. CIT (A), has considered all materials on record and has arrived at the conclusion that in absence of any material brought on record there is not even a single evidence