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

reassessment is permissible. Reasons can be even on the basis of particulars of the return without any new material. g) Aditya and Co. Vs CIT 279 ITR 47 P&H In the case of an intimation under section

CHAND JEWELLERS,NAKODAR vs. INCOME TAX OFFICER, JALANDHAR

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

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta(Physical Hearing) I.T.A. No. 574/Asr/2025 Assessment Year: 2017-18 Chand Jewellers, Bazar Sarafan Vs. Ito-Ward Nakodar, Distt. Jalandhar. Jalandhar. [Pan:-Aahfc5908J] (Appellant) (Respondent) Appellant By Sh. Amit Bajaj, Adv. Respondent By Sh. Charan Dass, Sr. Dr

section 69A, ignoring the well- settled principle that only the real income-being the net profit earned from such sales-can be subjected to tax under the provisions of the Income-tax Act. Taxing the entire sale proceeds as income amounts to taxing gross receipts instead of income, which is impermissible in law and leads to double taxation, since

SH. VARINDER KUMAR SOUL,JALANDHAR vs. INCOME TAX OFFICER, WARD - 3(2), JALANDHAR

Bench: Sh. Sanjay Arora & Sh. N. K. Choudhryi.T.A. No. 451(Asr)/2017 Assessment Year: 2012-13 Pan: Cvips 5218R

Section 143(2), per which the law provides for the said verification, and sec. 147, operate in different fields, even as explained in Vipan Khanna v. CIT [2002] 255 ITR 220 (P&H). Be that as it may, there is equally no doubt that the AO had a valid reason to believe escapement from assessment qua rental income. The same

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

47. Just to verify the said aspect the AO issued notice of reassessment proceedings which is equivalent to ‘reason to suspect’ and for his purpose the assessee is placing reliance on the decision of Hon’ble Supreme Court in the case of ITO Vs Lakhmani Mewal Das [1976] 103 ITR 437 (SC)( page 8 to 16) of the case

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

In the result, the appeal filed by assessee is allowed

reassessment, Assessing\nOfficer did not invoke section 68,\nhowever, Commissioner exercising his\nrevisionary power under section 263\nset aside assessment orders directing\nAssessing Officer to make fresh\nassessment after conducting detailed\nenquiry and upon satisfying on\ngenuneness of transaction - Whether\norder of Commissioner was not based\non irrelevant considerations and\nfurther in present circumstances, he\nwas not obliged to positively

JALALABAD SOLVEX PRIVATE LTD,JALALABAD vs. PR COMMISSIONER OF INCOME TAX , AMRITSAR-1, PR COMMISSIONER OF INCOME TAX

In the result, the appeal filed by the assessee is allowed

Bench: Sh. Udayan Dasgupta & Sh. Krinwant Sahay

reassessment of proceedings read with section assessment filed by 147 the assessee 8 I.T.A. No. 117/Asr/2024 Jalalabad Solvex Pvt. Ltd. v. Pr. CIT iv 08-12- Notice under The assessee has 2021 section 142(1) filed the required information in the Notice under section 142(1) issued on 08- 12- reply dated 2021 asking for the information:- 02/01/2022 and 28/02/2022

SH. VISHWA MITTER SEKHRI CHARITABLE SOCIETY,BATALA vs. THE INCOME TAX OFFICER, (EXEMPTION), AMRITSAR.

In the result the 2nd ground raised by the assessee is liable to be allowed

Bench: Sh. Laliet Kumar & Dr. M. L. Meenai.T.A. No. 75/Asr/2016 Assessment Year: 2007-08

reassessment to be framed consequent to notice u/s 148. This makes it very clear that no assessment u/s 147 could be made even though the notice u/s 148 was already issued. Finally, it was submitted that liberal view of the 2nd proviso to section 12A(2) needs to be taken. He relied upon the following decisions :- Shyam Mandir Committee, Khatushyamji

SHRI KASHMIR SINGH S/O SHRI SHINGARA SINGH,AMRITSAR vs. INCOME TAX OFFICER, WARD-5(3), AMRITSAR

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

reassessments are wrong which are subject matter of the reopening of the case for this particular assessment year and he did not conduct his own investigations to satisfy himself about the correctness of particulars before reasons recorded, which is totally erroneous and untenable. The reasons recorded for reopening are vague and there in no live nexus between the reasons recorded

SH. SURINDER SINGH LEGAL HEIR. OF SMT SITA DEVI,BATHINDA vs. INCOME TAX OFFICER WARD-1(1), BATHINDA

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

reassessment or recomputation under section 147 of the Act, any proceeding taken against the deceased before his death shall be deemed to have been taken against the legal representative and may be continued against the legal representative from the stage at which it stood on the date of death of the deceased. 4. It is clarified that the procedural

SHRI PURAN SINGH,SHAHKOT vs. PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL), LUDHIANA

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

reassessment or recomputation under section 147 of the Act, any proceeding taken against the deceased before his death shall be deemed to have been taken against the legal representative and may be continued against the legal representative from the stage at which it stood on the date of death of the deceased. 4. It is clarified that the procedural

SHRI PURAN SINGH ,SHAHKOT vs. PRINICIPAL COMMISSIONER AOF INCOME TAX(CENTRAL), LUDHIANA

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

reassessment or recomputation under section 147 of the Act, any proceeding taken against the deceased before his death shall be deemed to have been taken against the legal representative and may be continued against the legal representative from the stage at which it stood on the date of death of the deceased. 4. It is clarified that the procedural

SHRI PURAN SINGH,SHAHKOT vs. PRINICIPAL COMMISSIONER OF INCOME TAX (CENTRAL) , LUDHIANA

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

reassessment or recomputation under section 147 of the Act, any proceeding taken against the deceased before his death shall be deemed to have been taken against the legal representative and may be continued against the legal representative from the stage at which it stood on the date of death of the deceased. 4. It is clarified that the procedural

SHRI PURAN SINGH,SHAHKOT vs. PRINCIPAL COMMISSIONER OF INCOME TAX(CENTRJAL), LUDHIANA

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

reassessment or recomputation under section 147 of the Act, any proceeding taken against the deceased before his death shall be deemed to have been taken against the legal representative and may be continued against the legal representative from the stage at which it stood on the date of death of the deceased. 4. It is clarified that the procedural

SHRI PURAN SINGH,SHAHKOT vs. PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL), LUDHIANA

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

reassessment or recomputation under section 147 of the Act, any proceeding taken against the deceased before his death shall be deemed to have been taken against the legal representative and may be continued against the legal representative from the stage at which it stood on the date of death of the deceased. 4. It is clarified that the procedural

SHRI PURAN SINGH ,SHAHKOT vs. PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL), LUDHIANA

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

reassessment or recomputation under section 147 of the Act, any proceeding taken against the deceased before his death shall be deemed to have been taken against the legal representative and may be continued against the legal representative from the stage at which it stood on the date of death of the deceased. 4. It is clarified that the procedural

SHRI PURAN SINGH,SHAHKOT vs. PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL), LUDHIANA

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

reassessment or recomputation under section 147 of the Act, any proceeding taken against the deceased before his death shall be deemed to have been taken against the legal representative and may be continued against the legal representative from the stage at which it stood on the date of death of the deceased. 4. It is clarified that the procedural

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

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

47 lac) to his returned income and vide his order passed u/s 147/143(3) of the Act, dated 24/02/2014 assessed his income at an amount of Rs. 44,12,657/-. 3. Aggrieved, the assessee carried the matter in appeal before the CIT(A). However, finding no infirmity in the view taken by the AO the CIT(A) upheld the addition

INCOME TAX OFFICER, FEROZEPUR vs. MS.JATIN AGRO, FORT ROAD

In the result, the appeal of the revenue is dismissed

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta(Physical Hearing) I.T.A. No. 103 & 104/Asr/2024 Assessment Years: 2014-15 & 2017-18 Ito, Ward-3(1), Vs. M/S Jatin Agro Fort Road, Ferozepur. 152-P, Ferozepur. [Pan:-Aarpm5393F] (Appellant) (Respondent) Sh. Ashray Sarna, Ca Appellant By Respondent By Sh. Sunil Gautam, Cit. Dr

47,11,318/- as against claimed by the assessee in respect of expenditure of Rs 77,65,67,171/-. Hence, deduction u/s 35AD of the Act has been claimed by the assessee wrongly. 6. As per the provisions of section 147 of the Income Tax Act, 1961, if the Assessing Officer has reasons to believe that any income may, subject