SMT. SATYAWATI MARWAHA THROUGH LEGAL HEIR SH, CHANDER SHEIKHAR MARWAHA,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeal for Asstt

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

147 as envisaged under the Income Tax Act, 1961. 3. That having regard to the facts and circumstances of the case, Hon'ble CIT(A) has erred in law and on facts in confirming the action of Ld. AO in framing the impugned assessment order u/s 144r.w.s 147of the Income tax Act and without complying with the mandatory conditions u/s

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR vs. M/S PUNJAB RICE LAND PRIVATE LIMITED, TARN TARAN

In the result, both the appeals of the revenue are dismissed and

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

147 for reopening of assessment is required to be issued in this case. In this case more than four years have lapsed from the end of assessment year under consideration. Hence, necessary sanction to issue notice u/s 148 has been obtained separately from Pr. CIT (Central) as per the provisions of section 151 of the Act." Notice u/s

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR vs. M/S PUNJAB RICE LAND PRIVATE LIMITED , TARN TARAN

In the result, both the appeals of the revenue are dismissed and

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

147 for reopening of assessment is required to be issued in this case. In this case more than four years have lapsed from the end of assessment year under consideration. Hence, necessary sanction to issue notice u/s 148 has been obtained separately from Pr. CIT (Central) as per the provisions of section 151 of the Act." Notice u/s

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

natural justice. The ld.CIT(A), not only erred in not holding the impugned order bad on this score, but also committed a grave legal error to shift the onus on assessee to produce the said person. 5.That when neither the stock tally, nor the sales made were disputed, holding the purchases bogus was prime facie uncalled for, which the ld.CIT

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

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

reassessment proceedings, if the twin conditions prescribed under section 147 of the Act are satisfied. The grounds of appeal are dismissed. 7. Now the assessee is in appeal. 8. Ld. Counsel for the assessee reiterated the submissions made before the authorities below and also moved an application for admission of additional evidences stating therein as under: Sub: Assessment Year

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

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

reassessment proceedings, if the twin conditions prescribed under section 147 of the Act are satisfied. The grounds of appeal are dismissed. 7. Now the assessee is in appeal. 8. Ld. Counsel for the assessee reiterated the submissions made before the authorities below and also moved an application for admission of additional evidences stating therein as under: Sub: Assessment Year

M/S HOLY FAITH INTERNATIONAL PVT. LTD,JALANDHAR vs. THE DY COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeal of the assessee is allowed

Bench: Sh. N. K. Saini, Hon’Ble & Sh. Ravish Soodita No.181/Asr./2017 : Asstt. Year : 2008-09 M/S Holy Faith International Vs Deputy Commissioner Of Income Tax, Pvt. Ltd., Mbd House, Central Circle-Ii, Railway Road, Jalandhar Jalandhar (Appellant) (Respondent) Pan No. Aaach6111J Assessee By : Sh. Sudhir Sehgal, Adv. Revenue By : Sh. Bhawani Shankar, Dr Date Of Hearing : 07.01.2019 Date Of Pronouncement : 15.01.2019 Order Per N. K. Saini: This Is An Appeal By The Assessee Against The Order Dated 20.03.2017 Of Ld. Cit(A)-I, Jalandhar. 2. Following Grounds Have Been Raised In This Appeal: “1. That The Worthy Commissioner Of Income Tax (A)-1, Jalandhar Has Erred In Dismissing The Appeal Filed By The Assessee. 2. That The Ld. Cit(A) Has Erred In Confirming The Contention Of The Assessing Officer In Reopening The Case U/S 148 Of The Income Tax Act And, Thus, Framing Of Assessment U/S 147 R.W.S.143(3)/153C At An Income Of Rs. 4,95,13,441/- Against The Returned Income Of Rs. 4,63,33,441/-. 3. That The Ld. Cit(A) Has Erred In Not Considering That There Was No Reason To Believe That The Income Of The

justice. It was further submitted as under: “(i) The Ld. AO has applied his mind while framing the original assessment order u/s 153C and no discrepancy with regard to the unsecured loan was noticed. (ii) Reasons recorded by the Ld. AO is merely based on the information received from the investigation wing of the department without any independent application

SHRI GAURAV JOSHI,JALANDHAR vs. INCOME TAX OFICER WARD-1(5), JALANDHAR

In the result, the appeal of the assessee is allowed

Bench: Sh. N. K. Saini, Hon’Ble & Sh. Ravish Soodita No.274/Asr./2018 : Asstt. Year : 2010-11 Sh. Gaurav Joshi, Vs Income Tax Officer, C/O Sh. Ashray Sarna, Adv., B- Ward-1(5), 18, Vakil Building, Model Jalandhar Town Road, Jalandhar (Appellant) (Respondent) Pan No. Amjpj3603P Assessee By : Sh. Ashray Sarna, Ca. Revenue By : Sh. Bhawani Shankar, Dr Date Of Hearing : 10.01.2019 Date Of Pronouncement : 16.01.2019

natural justice. 4. That the appellant craves the leave to add, modify, amend or delete any of the grounds of appeal at the time of hearing and all the above grounds are without prejudice to each other.” 3. The main grievance of the assessee vide ground no. 2 relates to the jurisdiction of the AO in reopening the assessment u/s

SH. KARAMJIT SINGH RAI,HOSHIARPUR vs. INCOME TAX OFFICER , HOSHIARPUR

In the result, appeal filed by the Assessee is allowed

Bench: Sh. N.K.Choudhry & Dr. A.L.Saini

justice. 4. That the appellant craves the leave to add, modify, amend or delete any of the grounds of appeal at the time of hearing and all the above grounds are without prejudice to each other.” 3. Having heard the parties at length and perused the material available on record. The grounds no. 1 and 3 are based upon

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

natural justices specially when all other required information ie. details of project including location and scope of work, copies of the work allocation order from the Govt department was submitted. 4.2 This is misstated facts that the assessee company has not provided the detail of work performed whereas the information called for u/s 133(6) was duly furnished vide letter

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

natural justices specially when all other required information ie. details of project including location and scope of work, copies of the work allocation order from the Govt department was submitted. 4.2 This is misstated facts that the assessee company has not provided the detail of work performed whereas the information called for u/s 133(6) was duly furnished vide letter

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.:

natural justice 5. That on the facts and in the circumstances of the case, the CIT(A) failed to appreciate that the reopening under section 148 was initiated solely based on Information available in AIMS module of ITBA Portal, without any independent application of mind by the Assessing Officer. 6. That on the facts and in the circumstances

IMRAN MAJEED,SRINAGAR vs. ITO, WARD 1, SRINAGAR, SRINAGAR

In the result, the appeal for the Asstt

Bench: Dr. M. L. Meena & Sh. Udayan Dasgupta

reassessment proceedings are also vitiated and quashed. 25. Since the appeal is allowed on this legal ground all other grounds on merits are not adjudicated upon. 26. In the result, the appeal of the assessee for Asstt. Year 2018-19 is allowed. 15 I.T.A. Nos. 585 & 586/Asr/2024 Assessment Years: 2018-19 & 2019-20 Grounds of appeal in ITA No. 586/Asr/2024

IMRAN MAJEED,SRINAGAR vs. ITO WARD 1, SRINAGAR, SRINAGAR

In the result, the appeal for the Asstt

Bench: Dr. M. L. Meena & Sh. Udayan Dasgupta

reassessment proceedings are also vitiated and quashed. 25. Since the appeal is allowed on this legal ground all other grounds on merits are not adjudicated upon. 26. In the result, the appeal of the assessee for Asstt. Year 2018-19 is allowed. 15 I.T.A. Nos. 585 & 586/Asr/2024 Assessment Years: 2018-19 & 2019-20 Grounds of appeal in ITA No. 586/Asr/2024

NEERAJ KUMAR SETHI,DELHI vs. ITO, NATIONAL FACELESS APPEAL CENTRE (NFAC)

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

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

147 r.w.s. 144 and section 144B of the Act, 1961 dated 29.03.2022. 2 I.T.A. No. 9/Asr/2024 Assessment Year: 2014-15 2. The grounds of appeal preferred by the assessee in form 36 has been subsequently revised and the revised grounds are as follows: “1. That the assessment order framed by the AO is void ab-initio having been framed without

SH GAUTAM SETH,BATALA vs. THE INCOME TAX OFFICER, BATALA

In the result, the Ground Nos

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

natural justice and without granting a proper opportunity to the appellant to be heard. 4. That in the view of the facts and circumstances of the case, the CIT(A) has erred on facts and in law in uploading the addition of Rs. 2,97,65,273/-invoking provisions of Section 40A(3) without appreciating the fact that the provision

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

u/s 143(3) of the Income-Tax Act,1961 and sustained by the Ld. CIT(Appeals), Bathinda to the extent of Rs.3368497.00 are absolutely illegal, unwarranted and bad in law and the same may kindly be quashed. 2. That the CIT (Appeals) decided the case in a very hurried manner without listening the request of the appellant to file documents

AMBEY CONSTRUCTION COMPANY,BATHINDA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, BATHINDA

In the result, the appeal of the assessee is allowed

Bench: Sh. N. S. Saini & Sh. N. K. Choudhryita No. 121/Asr./2017 : Asstt. Year : 2011-12 Ambey Construction Company, Vs Asstt. Commissioner Of #21605, Street No. 7, Power House Income Tax, Circle-1, Road, Bathinda Bathinda (Appellant) (Respondent) Pan No. Aanfa7199K

natural justice and binding judgment of the Hon’ble Supreme Court in the case of Andaman Timber Industries as reported in 281 CTR 241. 5. The Ld. CIT(A) erred on facts and law while directing the AO to assess the work contract receipts amounting to Rs. 15,00,00,000/-, assessed by the AO as income from other sources

SMT. NIRMAL KAUR,AMRITSAR vs. INCOME TAX OFFICER, WARD 1(2), AMRITSAR

In the result, the assessee’s appeal is dismissed

Bench: Sh. Sanjay Arorai.T.A. No. 700/Asr/2017 Assessment Year: 2009-10

147 of the Income Tax Act, 1961 ('the Act' hereinafter) dated 08.12.2016 for the Assessment Year (AY) 2009-10. 2.1 The facts of the case in brief are that the assessee was issued a notice u/s. 148 on 30.3.2016 on the basis of the Annual Information Report (AIR) with the Revenue as to the assessee having made purchase/sale transaction