SH. FARUKH JEHAN ZEB ,SRINAGAR vs. INCOME TAX OFFICER, ANANT NAG

In the result, the appeal of the assessee is dismissed

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

reassessment proceedings in this case were only based on presumption/ suspicion and were thus not validly initiated. 4. That having regard to the facts and circumstances of the case, the Ld. CIT (A) has erred by upholding the action of the AO that the reasons recorded by the AO without application of mind to the information available on record

SHRIMATI. HARBHAJAN KAUR,JALANDHAR vs. INCOME TAX OFFICER WARD -1 (20, JALANDHAR

In the result, the appeal of the assessee is allowed

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

u/s 142(1) were served on the assessee. Appellant did not bring any material on record that the said notices were not served on him. Hence these grounds of appeal are dismissed as factually wrong. 6. Per Contra, the learned DR supported the order of the CIT. 7. We have heard the rival contentions, considered relevant material, citations and return

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

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

147 of the I.T. Act, 1961 and also other income chargeable to tax in respect of which assessee is assessable which has escaped assessment and which comes to notice subsequently in the course of the proceedings under this section for the assessment year under consideration.” 6. The AO has issued detailed questionnaire along with the notice issued u/s 142

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

147 on 23.05.2023 is bad in law since, the jurisdictional notice issued u/s 148 on 25.07.2022 is bad in law. 5. That the CIT(A) has erred in not taking cognizance of the details of receipts and expenditure furnished in the return of income filed in response to notice issued u/s 148 whereby it was made clear that receipts

SHRI BARJINDERPAL SINGH BHULLAR,MOHALI vs. INCOME TAX OFFICER WARD- 1 (3), BATHINDA

Accordingly, the appeal filed by the assessee is allowed in terms of our aforesaid observations

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

reassessment or recomputation under section 147, the Assessing Officer shall serve on the assessee a notice requiring him to furnish within such period, [***], as may be specified in the notice, a return of his income or the income of any other person in respect of which he is assessable under this Act during the previous year corresponding to the relevant

SHRI BRIJINDERPAL SINGH BHULLAR,MOHALI vs. INCOME TAX OFFICER WARD- 1 (3), BATHINDA

Accordingly, the appeal filed by the assessee is allowed in terms of our aforesaid observations

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

reassessment or recomputation under section 147, the Assessing Officer shall serve on the assessee a notice requiring him to furnish within such period, [***], as may be specified in the notice, a return of his income or the income of any other person in respect of which he is assessable under this Act during the previous year corresponding to the relevant

INCOME TAX OFFICER, WARD-4(2), JALANDHAR, , CIVIL LINES vs. SH. BARJESH SINGHAL, MODERN COLONY

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

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

Section 147 (a) of the Act the Act. (f) If satisfaction is arrived at on the basis of any relevant material, such satisfaction cannot be assailed. Tilak Raj Bedi vs JCIT (2009) 319 ITR 385-P&11- The power of reassessment can be validly exercised if satisfaction is arrived at after following due procedure that income had escaped assessment. Such

SHRI SHISH PAL SINGH,JALANHDHAR vs. INCOME TAX OFFICER, WARD 1(4) JALANDHAR

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

142(1) of the I.T. Act, 1961.” The counsel of the assessee pointed out the issue that the ld. ITO completed the assessment u/s 147/143(3) of the Act without considering section 153C of the Act. In this respect, the assessee placed the judgment of ITO v. Arun Kumar Kapoor 140 TTJ 0249 [2011], G. Koteswara

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.:

147 is bad in law as the notice under section 148 was issued on 13.04.2021 without adheringto the new procedure applicable from 01.04.2021, specifically without complying with the provisions of section 148A. 5. We have heard both the sides and perused the material on record. We find that the notice u/s 148 dated 28.03.2021, was issued on 13.04.2021, as contended

NASA AGRO INDUSTRIES PRIVATE LIMITED,FAZILKA vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-II, BATHINDA

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

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

142(1) raising various questioner, has been responded to by the assessee through his lawyers and written submissions filed. 6. The assessment was completed u/s 143(3)/ 147 with an addition of Rs.51.57 lakhs by treating the amount transferred by the assessee to the M/s Devinder Kumar Deepesh Kumar ,as an accommodation entry for recording of bogus purchase, because

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

147 of the Act. This is submitted as required. Thanking you, Yours faithfully, M/s DMR Builders Pvt. Ltd. 7.1 Subsequently, in course of assessment proceedings various notices were issued u/s 142(1) , raising various queries and replies to such queries were made by the assessee, necessary directions issued by Additional CIT u/s 144A were considered, and after elaborate discussion

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

147 of the Act. This is submitted as required. Thanking you, Yours faithfully, M/s DMR Builders Pvt. Ltd. 7.1 Subsequently, in course of assessment proceedings various notices were issued u/s 142(1) , raising various queries and replies to such queries were made by the assessee, necessary directions issued by Additional CIT u/s 144A were considered, and after elaborate discussion

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

u/s 148 dated 31-03-2021 received Return of income section 148 filed in response to the notice under section [DIN: TBA/AST/S/148/2020- 21/1032083993(1)] 148 iii 28-06- Notice under section 143(2) issued on Notice under 2021 Objections the 28/06/2021 providing the details of section 143(2) reopening reassessment of proceedings read with section assessment filed by 147

SHRIMATI. LATA NARANG,JALANDHAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX -1, JALANDHAR

In the result, appeal of the assessee is allowed

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

147 of the Income Tax Act, 1961 for the Asstt.Year:2011-12 were initiated in your case as you did not file any information with respect to the source of cash deposited by you at Rs.35,50,000/- in your savings bank during the relevant period. In response to the notice u/s 148 of the Act, you filed the income

SMT. SATVIR KAUR W/O SH. SHINDER SINGH,FEROZEPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX-1, AMRITSAR

In the result, the appeal of the assessee is allowed

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

reassessment proceedings, a notice u/s 142(1) of the Act was issued to the assessee on 06.07.2018. Thereafter, Sh. Shinder Pal Singh (husband of the assessee) attended the proceedings in the case of the assessee and filed various documents as evident from the copy of the order sheet placed in the paper book at page

INCOME TAX OFFICER WARD -2 (1), AMRITSAR vs. MS. SAVITA BANSAL, THROUGH LEGAL HEIR SH. PARVEEN KUMAR BANSAL, AMRITSAR

In the result, the revenue’s appeal stands dismissed

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Udayan Das Gupta, Jm 1. आयकर अपील सं. / Ita No. 240/Asr/2023 (िनधा"रण वष" / Assessment Year: 2016-17) Income Tax Officer Smt. Savita Bansal Ward-2(1) बनाम/ (Through L/H Shri Parveen Kumar Bansal) Amritsar 143001 H.No. 272, Green Avenue Vs. Amritsar-143001. "थायीलेखासं./Pan. Abmpb-3594-K (Assessee) / Acnpk-4131-D (Lh) (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. Cross Objection No. 1/Amritsar/2024 (In Ita No. 240/Asr/2023) (िनधा"रण वष" / Assessment Year: 2016-17) Smt. Savita Bansal Income Tax Officer बनाम/ (Through L/H Shri Parveen Kumar Bansal) Ward-2(1) H.No. 272, Green Avenue Amritsar 143001 Vs. Amritsar-143001. "थायीलेखासं./Pan. Abmpb-3594-K (Assessee) / Acnpk-4131-D (Lh) (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/Appellant By : Dr Rakesh Gupta (Advocate) –Ld. Ar ""थ"कीओरसे/Respondent By : Shri B. Srinivas Kumar (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 10-07-2025 घोषणाकीतारीख /Date Of Pronouncement : 21-08-2025 आदेश / O R D E R Manoj Kumar Aggarwal () Aforesaid Appeal By Revenue For Assessment Year (Ay) 2016- 1. 17 Arises Out Of An Order Of Ld. Commissioner Of Income Tax

142(1) has been issued by same officer on 05-12-2018 which is also in the name of deceased assessee Smt. Savita Bansal (Page 23-24 of the paper-book). Subsequent notices / communications have also been issued in the name of deceased assessee only which is evident from copies thereof as placed on record. The Legal heir

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

u/s 153A was vehemently pressed on account of which ground No.1 in the appeal for assessment year 2004-05 was admitted as additional ground. He also wanted the additional ground to be retained in case of any future contingency." 32. We would be failing in our duty if we do not note the reliance placed by Mr. Pinto

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

u/s 153A was vehemently pressed on account of which ground No.1 in the appeal for assessment year 2004-05 was admitted as additional ground. He also wanted the additional ground to be retained in case of any future contingency." 32. We would be failing in our duty if we do not note the reliance placed by Mr. Pinto