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

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 to the provisions of sections 148 to 153, assess or reassess such income and also any other income chargeable

INCOME TAX OFFICER, WARD-3(1),FEROZEPUR, 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

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 to the provisions of sections 148 to 153, assess or reassess such income and also any other income chargeable

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

u/s 69/69A. There is, at any rate, complete non-substantiation of his case by the assessee. As explained in CIT vs. P. Mohan Kala [2007] 291 ITR 278 (SC), an explanation means a reasonable and acceptable explanation. The Apex Court in that case was considering the applicability of section 68, and its said observations were in the context

KUNDAN JEWELLERS PRIVATE LIMITED,GANDHI CHOWK, SADAR BAZAR, MUKTSAR vs. THE INCOME TAX OFFICER, WARD-2(2), MUKTSAR, MUKTSAR

In the result, the appeal of the assessee is allowed

Bench: Sh. Udayan Dasgupta & Sh. Krinwant Sahay

147 being void ab-initio, the reassessment being initiated on the basis of information received in the portal , which has neither been examined or corroborated by the AO , before recording his satisfaction, which indicates non application of mind by the AO to the facts on record , the same just reasons to suspect and the assessee has also challenged the addition

SHIVAM ENTERPRISES HARBILAS,HOSHIARPUR vs. INCOME TAX OFICER WARD-4, HOSHIARPUR

In the result, the assessee’s appeal is allowed

Bench: Sh. Sanjay Arorai.T.A. No. 194/Asr/2018 Assessment Year: 2011-12

147 of the Income Tax Act, 1961 ('the Act' hereinafter) dated 21.12.2016 for the Assessment Year (AY) 2011-12. 2. The principal issue arising in the instant appeal is the validity reopening of assessment vide notice u/s. 148 dated 08.02.2016. The assessee assails the same on the basis of it being a ‘change of opinion’. Depreciation on trucks and tempos

SH.SHREE GURU NANAK DEV QUIN-CENTENARY CELEBRATION COMMITTEE,LUDHIANA vs. INCOME TAX OFFICER (EXEMPTION), JALANDHAR

In the result, appeal of the assessee is allowed

Bench: Shri L.P. Sahu, Am & Shri Ravish Sood, Jm आयकर अपील सं./Ita No.238/Asr/2019 आयकर अपील सं आयकर अपील सं आयकर अपील सं (िनधा"रण िनधा"रण वष" वष" / Assessment Year :2010-2011) िनधा"रण िनधा"रण वष" वष" Shree Guru Nanak Dev Vs. Ito(Exemptions) Ward, Quin-Centenary Celebrations Jalandhar Committee, Guru Nanak Bhawan, Ludhiana "थायी लेखा सं./Panno. : Aawfs 2431 F .. (अपीलाथ" /Appellant) (" यथ" / Respondent) : Shri S.K.Mukhi, Advocate िनधा"!रती क" क" क" ओर क" ओर ओर सेसेसेसे /Assessee By ओर ओर सेसेसेसे /Revenue By : Shri M.P.Singh, Cit-Dr राज"व क" क" क" ओर क" ओर ओर सुनवाई क" तार'ख / Date Of Hearing : 06/02/2020 घोषणा क" तार'ख/Date Of Pronouncement : 30/06/2020 आदेश आदेश / O R D E R आदेश आदेश Per L.P.Sahu, Am: This Is An Appeal Filed By The Assessee Against The Order Of Cit(A)-4, Ludhiana, Dated 08.02.2019, On The Following Grounds Of Appeal :- 1. That The Orders Of Ld. Cit(A) Is Illegal, Erroneous & Perverse & Thus Needs To Be Quashed. 2. That The Issuance Of Notice U/S 147/148 Is Bad In Law As No New Material Was There With The Ao To Initiate Action U/S 147 & The Proceedings In Furtherance Of Illegal Notice Are Void Ab-Initio & Deserve To Be Set Aside. 3. That The Addition Made By Ao & Partially Confirmed By Cit (A) Is Devoid Of Proper Appreciation Of Facts On Record & Against Express Provisions Of Law & Deserve To Be Set Aside. 4. That The Appellant Craves Leave To Add, Amend Or Delete Any Of The Grounds Of Appeal On Or Before The Disposal Of The Present Appeal. 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income On 15.06.2010 Declaring Total Income After Claiming Exemption

u/s 147 is given hereunder: "On perusal of record it, revealed that dosing balance of capital fund as on 31.03.2009 was Rs. 1,83,63,024/- but opening balance of capital fund as on 31.03.2010 was taken as Rs. 2,81,68,024. This has resulted into overstatement of capital fund to the tune of Rs.9805000/- (28168024-183630324) Capital Fund

SMT. BHARTI SINGH ,AMRITSAR vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-3, AMRITSAR

Appeals of the appellant are disposed of in the terms indicated as above

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

reassessment framed by the AO was not justified, hence quashed.” Bharti Singh v. Asstt.CIT 5. Per Contra, the learned additional CIT (DR) supported the impugned order, however he failed to rebut the contentions of the Ld. counsel. 6. We have heard both the sides, perused the record and impugned orders. Admittedly, the appellant’s case was reopened u/s 148 r.w.s.147

SMT. BHARTI SINGH,AMRITSAR vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-3, AMRITSAR

Appeals of the appellant are disposed of in the terms indicated as above

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

reassessment framed by the AO was not justified, hence quashed.” Bharti Singh v. Asstt.CIT 5. Per Contra, the learned additional CIT (DR) supported the impugned order, however he failed to rebut the contentions of the Ld. counsel. 6. We have heard both the sides, perused the record and impugned orders. Admittedly, the appellant’s case was reopened u/s 148 r.w.s.147

SMT. BHARTI SINGH ,AMRITSAR vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-3, AMRITSAR

Appeals of the appellant are disposed of in the terms indicated as above

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

reassessment framed by the AO was not justified, hence quashed.” Bharti Singh v. Asstt.CIT 5. Per Contra, the learned additional CIT (DR) supported the impugned order, however he failed to rebut the contentions of the Ld. counsel. 6. We have heard both the sides, perused the record and impugned orders. Admittedly, the appellant’s case was reopened u/s 148 r.w.s.147

M/S NARULA OIL & FATS PRIVATE LIMITED,AHEMDABAD vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR

In the result, the appeals of the revenue are dismissed and appeals of assessee are allowed in the terms indicated above

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

depreciation claimed on new Plant & Machinery. ii) Addition on account of unaccounted investment in the capital to the tune of Rs. 15,00,000/-. During the course of assessment proceedings, the then AO had given various opportunities to the assessee to furnish its submissions on the above mentioned issues and other issues, as well. However, the assessee did not furnish

MEASAGE NARULA SOLVEX PRIVATE LIMITED,MOGA vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR

In the result, the appeals of the revenue are dismissed and appeals of assessee are allowed in the terms indicated above

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

depreciation claimed on new Plant & Machinery. ii) Addition on account of unaccounted investment in the capital to the tune of Rs. 15,00,000/-. During the course of assessment proceedings, the then AO had given various opportunities to the assessee to furnish its submissions on the above mentioned issues and other issues, as well. However, the assessee did not furnish

M/S NARULA FOODS PRIVATE LIMITED,FEROZEPUR vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR

In the result, the appeals of the revenue are dismissed and appeals of assessee are allowed in the terms indicated above

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

depreciation claimed on new Plant & Machinery. ii) Addition on account of unaccounted investment in the capital to the tune of Rs. 15,00,000/-. During the course of assessment proceedings, the then AO had given various opportunities to the assessee to furnish its submissions on the above mentioned issues and other issues, as well. However, the assessee did not furnish

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR vs. M/S NARULA OIL & FATS PRIVTE LIMITED, AHMEDABAD

In the result, the appeals of the revenue are dismissed and appeals of assessee are allowed in the terms indicated above

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

depreciation claimed on new Plant & Machinery. ii) Addition on account of unaccounted investment in the capital to the tune of Rs. 15,00,000/-. During the course of assessment proceedings, the then AO had given various opportunities to the assessee to furnish its submissions on the above mentioned issues and other issues, as well. However, the assessee did not furnish

M/S NARULA OIL & FATS PRIVATE LIMITED,AHEMDABAD vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR

In the result, the appeals of the revenue are dismissed and appeals of assessee are allowed in the terms indicated above

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

depreciation claimed on new Plant & Machinery. ii) Addition on account of unaccounted investment in the capital to the tune of Rs. 15,00,000/-. During the course of assessment proceedings, the then AO had given various opportunities to the assessee to furnish its submissions on the above mentioned issues and other issues, as well. However, the assessee did not furnish

MEASAGE SAT KARTAR SOLVEX PRIVATE LIMITED,FEROZEPUR vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR

In the result, the appeals of the revenue are dismissed and appeals of assessee are allowed in the terms indicated above

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

depreciation claimed on new Plant & Machinery. ii) Addition on account of unaccounted investment in the capital to the tune of Rs. 15,00,000/-. During the course of assessment proceedings, the then AO had given various opportunities to the assessee to furnish its submissions on the above mentioned issues and other issues, as well. However, the assessee did not furnish

MEASAGE NARULA SOLVEX PRIVATE LIMITED,MOGA vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE , AMRITSAR

In the result, the appeals of the revenue are dismissed and appeals of assessee are allowed in the terms indicated above

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

depreciation claimed on new Plant & Machinery. ii) Addition on account of unaccounted investment in the capital to the tune of Rs. 15,00,000/-. During the course of assessment proceedings, the then AO had given various opportunities to the assessee to furnish its submissions on the above mentioned issues and other issues, as well. However, the assessee did not furnish

M/S NARULA OIL & FATS PRIVATE LIMITED,AHEMDABAD vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR

In the result, the appeals of the revenue are dismissed and appeals of assessee are allowed in the terms indicated above

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

depreciation claimed on new Plant & Machinery. ii) Addition on account of unaccounted investment in the capital to the tune of Rs. 15,00,000/-. During the course of assessment proceedings, the then AO had given various opportunities to the assessee to furnish its submissions on the above mentioned issues and other issues, as well. However, the assessee did not furnish

M/S NARULA FOODS PRIVATE LIMITED,FEROZEPUR vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR

In the result, the appeals of the revenue are dismissed and appeals of assessee are allowed in the terms indicated above

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

depreciation claimed on new Plant & Machinery. ii) Addition on account of unaccounted investment in the capital to the tune of Rs. 15,00,000/-. During the course of assessment proceedings, the then AO had given various opportunities to the assessee to furnish its submissions on the above mentioned issues and other issues, as well. However, the assessee did not furnish