D.CI.T , CENTRAL CIRCLE - II, JALANDHAR vs. SH. SUBASH GANDHI , JALANDHAR

In the result, all the appeals are allowed for statistical purposes

Bench: Shri R.S. Syal & Shri N.K. Choudhry

reassessment under sub-section (3) of section 92CD; (c) an order made under section 154 or section 155 having the effect

D.CI.T , CENTRAL CIRCLE - II, JALANDHAR vs. SH. SUBASH GANDHI , JALANDHAR

In the result, all the appeals are allowed for statistical purposes

Bench: Shri R.S. Syal & Shri N.K. Choudhry

reassessment under sub-section (3) of section 92CD; (c) an order made under section 154 or section 155 having the effect

M/S CITI PLAZA,JALANDHAR vs. INCOME TAX OFFICER , WARD 3(1), JALANDHAR

In the result, the appeal of the assessee bearing ITA No

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

reassessment proceeding in view of Clause (ii) of sub-section (3) of section 153 of the Act. However, this Court

SHRI HARSH VARDHAN ,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, JALANDHAR

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

reassessment proceedings. Apropos the objections filed by the assessee in the course of the assessment proceedings, it was submitted by him that the A.O had failed to dispose off the same by way of a speaking order. Also, it was the claim of the assessee that the impugned assessment order, i.e, u/s 148 r.w.s 143(3), dated 30.03.2016 was passed

SHRIMATI AMARJIT KAUR W/O BUGAR SINGH,MANSA vs. INCOME TAX OFFICER WARD 1(4), MANSA

In the result, the appeal of the assessee is dismissed

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

section 143(3) will not render the Assessing Officer powerless to initiate reassessment proceedings even when intimation under section 143(1) had been

THE BABA NAG RICE & GENRAL MILLS,AMRITSAR. vs. THE COMMISSIONER OF INCOME TAX, AMRITSAR.

In the result, the assessee’s appeal is dismissed

Bench: Sh. Sanjay Arora & Sh. N. K. Choudhryi.T.A. No. 375/Asr/2016 Assessment Year: 1998-99

section 234B(1) in the present case, no additional interest u/s. 234B(3) could have been charged in reassessment, which

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

In the result the appeal of the assessee is allowed on the legal issue as indicated above

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta(Hybrid Hearing) I.T.A. No. 698/Asr/2024 Assessment Year: 2013-14

section 3 of the Taxation and Other Laws (Relaxation and Amendments of Certain Provisions) Act, 2020 - Income Escaping Assessment - Time limit for issuance of notice (Reassessment

POONAM MARWAHA,AMRITSAR vs. ACIT DCIT CEN CIR, AMRITSAR

Bench: Sh. Vikram Singh Yadav & Sh. Udayan Dasgupta

reassessment, Assessing Officer did not invoke section 68, however, Commissioner exercising his revisionary power under section 263 set aside assessment orders directing Assessing Officer to make fresh assessment after conducting detailed enquiry and upon satisfying on genuneness of transaction - Whether order of Commissioner was not based on irrelevant considerations and further in present circumstances, he was not obliged to positively

M/S JAMMU COOPERATIVE WHOLE SALE LIMITED,JAMMU vs. INCOME TAX OFFICER WARD-2 (1), JAMMU

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjeei.T.A. No. 150/Asr/2020 Assessment Year: 2005-06 M/S Jammu Cooperative Whole Sale The Ito Limited (Super Bazar) Old Hospital Ward-2(1) Road, City Chowk, Jammu- Jammu 180001(J&K)-180001

3 5.1 It is seen that in the proceedings under section 147 of the Act, the AO had charged items of income which has escaped assessment other than or in addition to that item or items which have led to the issuance of notice under section 148 and where the assessment is made under section 147 in respect of income

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

section 143(3) will not render the Assessing Officer powerless to initiate reassessment proceedings even when intimation under section 143(1) had been

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

section 143(3) will not render the Assessing Officer powerless to initiate reassessment proceedings even when intimation under section 143(1) had been

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

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

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 on transfer of capital gain, (iv) It has been categorically stated in the reasons for initiating the reassessment

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

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

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 on transfer of capital gain, (iv) It has been categorically stated in the reasons for initiating the reassessment

PANKAJ JINDAL CONTRACTOR,MANSA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-I, BATHINDA, BATHINDA

In the result the appeal of the assessee is allowed

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta(Physical Hearing) I.T.A. No. 695/Asr/2024 Assessment Year: 2014-15 M/S Pankaj Jindal Contractor, Vs. Dcit-Circle-1, Near Vidya Bharti School, Bathinda. Mansa. [Pan:-Aajfp8008L] (Appellant) (Respondent) Appellant By Sh. Sudhir Sehgal, Adv. Respondent By Sh. Charan Dass, Sr. Dr

3 , the Ld AR of the assessee submitted that the reassessment proceedings has been initiated on the basis of change of opinion because both the issues, firstly the issue of disallowance of expenditure being hit by the provisions of section

MESERS SUPERTECH FORGINGS(INDIA) PVT.LTD.,JALANDHAR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE IV, JALANDHAR

In the result, the appeal of the Assessee is allowed

3) of the Act, and the entire transaction of the assessee was examined by the assessing officer, therefore in view of first proviso of section 147, no reopening could be made by the assessing officer. It was submitted that there was no failure on the part of the assessee to disclose either the purchase of goods purchased from the parties

M/S SADHU SINGH HAMDARD TRUST,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeals of the assessee bearing ITA Nos

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

3) in view of explanation 1 (ii) of section 153. In this connection, it is submitted that the section 153 (2) stood as under as on 01/04/1994, the year in which the notice u/s 148 was issued: "[(2) No order of assessment, reassessment

M/S SADHU SINGH HAMDARD TRUST,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeals of the assessee bearing ITA Nos

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

3) in view of explanation 1 (ii) of section 153. In this connection, it is submitted that the section 153 (2) stood as under as on 01/04/1994, the year in which the notice u/s 148 was issued: "[(2) No order of assessment, reassessment

M/S SADHU SINGH HAMDARD TRUST,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeals of the assessee bearing ITA Nos

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

3) in view of explanation 1 (ii) of section 153. In this connection, it is submitted that the section 153 (2) stood as under as on 01/04/1994, the year in which the notice u/s 148 was issued: "[(2) No order of assessment, reassessment

M/S SADHU SINGH HAMDARD TRUST,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeals of the assessee bearing ITA Nos

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

3) in view of explanation 1 (ii) of section 153. In this connection, it is submitted that the section 153 (2) stood as under as on 01/04/1994, the year in which the notice u/s 148 was issued: "[(2) No order of assessment, reassessment