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

147 [except an order passed in pursuance of directions of the Dispute Resolution Panel or an order referred to in sub-section (12) of section 144BA]] or section 150; (ba) an order of assessment or reassessment under section 153A [except an order passed in pursuance of directions of the Dispute Resolution Panel or an order referred to in sub-section

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

147 [except an order passed in pursuance of directions of the Dispute Resolution Panel or an order referred to in sub-section (12) of section 144BA]] or section 150; (ba) an order of assessment or reassessment under section 153A [except an order passed in pursuance of directions of the Dispute Resolution Panel or an order referred to in sub-section

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

147 [except an order passed in pursuance of directions of the Dispute Resolution Panel or an order referred to in sub-section (12) of section 144BA]] or section 150; (ba) an order of assessment or reassessment under section 153A [except an order passed in pursuance of directions of the Dispute Resolution Panel or an order referred to in sub-section

SHRI ARUN NARULA ,FEROZEPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR

Appeals are disposed of in the terms and observation made as above

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

150(1) of the Act and not of the Assessing Officer u/s 147 of the Act. He contended that such reason are no reasons under the provisions of section 148 of the Income Tax Act, 1961. Accordingly, he prayed that the assessment order passed by the AO on the basis of invalid reasons is without jurisdiction and hence 6 I.T.A

SHRI ARUN NARULA,FEROZEPUR vs. ASSISTANT COMMISSIONER OFD INCOME TAX CENTRAL CIRCLE, AMRITSAR

Appeals are disposed of in the terms and observation made as above

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

150(1) of the Act and not of the Assessing Officer u/s 147 of the Act. He contended that such reason are no reasons under the provisions of section 148 of the Income Tax Act, 1961. Accordingly, he prayed that the assessment order passed by the AO on the basis of invalid reasons is without jurisdiction and hence 6 I.T.A

SHRI ARUN NARULA,FROZEPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR

Appeals are disposed of in the terms and observation made as above

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

150(1) of the Act and not of the Assessing Officer u/s 147 of the Act. He contended that such reason are no reasons under the provisions of section 148 of the Income Tax Act, 1961. Accordingly, he prayed that the assessment order passed by the AO on the basis of invalid reasons is without jurisdiction and hence 6 I.T.A

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

THE DY. COMMISSIONER OF INCOME TAX, AMRITSAR. vs. SH. JAIMAL SINGH, L/H. SH. PREM CHAND,, TARN TARAN

In the result, the appeal bearing ITA No

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

reassessment u/s 147 on the ground of AIR Information not being reflected in the return of Income, ignoring the clear position of the law that section 139(9) can only be used to rectify defects, if any in the return of income. 7. The Learned CIT(A) has erred in law and facts and circumstances of the case

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 147 / 148 , against the assessee, (for which the assessee is not in appeal ), but he has decided the issue in favour of the assessee, on merits of the case allowing the appeal by observing as follows: “Legal contention: I have perused the assessment order and the submission made by the Appellant. The AO has issued notice under section

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 147 / 148 , against the assessee, (for which the assessee is not in appeal ), but he has decided the issue in favour of the assessee, on merits of the case allowing the appeal by observing as follows: “Legal contention: I have perused the assessment order and the submission made by the Appellant. The AO has issued notice under section

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

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

150 TTJ 640 (Agra), P.amballabh Gupta v. 4 Shish Pal Singh v. ITO ACIT & Ors. 288 ITR 347 (M.P.) and Cargo Clearing Agency Gujrat v. JCIT, 307 ITR 1 (Guj.) 5. The Ld. Senior Departmental Representative (in brevity Sr. DR) vehemently argued in this issue he mentioned that this particular issue of additional ground was never raised before

SHRI RAVINDER SINGH,JALANDHAR vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1, JALANDHAR

In the result, the appeals of the assessee are allowed

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

147 taxmann.com 305 Hon’ble Allahabad High Court observed as under: ‘‘18. The careful and conjoint reading of section 153A(1) and section 153D leave no room for doubt that approval with respect to "each assessment year" is to be obtained by the Assessing Officer on the draft assessment order before passing the assessment orders under section 153A

SHRI RAVINDER SINGH ,JALANDHAR vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1, JALANDHAR

In the result, the appeals of the assessee are allowed

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

147 taxmann.com 305 Hon’ble Allahabad High Court observed as under: ‘‘18. The careful and conjoint reading of section 153A(1) and section 153D leave no room for doubt that approval with respect to "each assessment year" is to be obtained by the Assessing Officer on the draft assessment order before passing the assessment orders under section 153A

SHRI RAVINDER SINGH,JALANDHAR vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1, JALANDHAR

In the result, the appeals of the assessee are allowed

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

147 taxmann.com 305 Hon’ble Allahabad High Court observed as under: ‘‘18. The careful and conjoint reading of section 153A(1) and section 153D leave no room for doubt that approval with respect to "each assessment year" is to be obtained by the Assessing Officer on the draft assessment order before passing the assessment orders under section 153A

SHRI RAVINDER SINGH,JALANDHAR vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1, JALANDHAR

In the result, the appeals of the assessee are allowed

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

147 taxmann.com 305 Hon’ble Allahabad High Court observed as under: ‘‘18. The careful and conjoint reading of section 153A(1) and section 153D leave no room for doubt that approval with respect to "each assessment year" is to be obtained by the Assessing Officer on the draft assessment order before passing the assessment orders under section 153A

SHRI RAVINDER SINGH,JALANDHAR vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1, JALANDHAR

In the result, the appeals of the assessee are allowed

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

147 taxmann.com 305 Hon’ble Allahabad High Court observed as under: ‘‘18. The careful and conjoint reading of section 153A(1) and section 153D leave no room for doubt that approval with respect to "each assessment year" is to be obtained by the Assessing Officer on the draft assessment order before passing the assessment orders under section 153A

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

SHRI MURLI MANOHAR,JALANDHAR vs. ASSISTANT COMMISSIONEER OF INCOME TAX CENTRAL CIRCLE-2, JALANDHAR

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

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

147 taxmann.com 305 Hon’ble Allahabad High Court observed as under: Murli Manohar v. Asstt. CIT ITA Nos.555 & 556/Asr/2019 ‘‘18. The careful and conjoint reading of section 153A(1) and section 153D leaveno room for doubt that approval with respect to "each assessment year" is to beobtained by the Assessing Officer on the draft assessment order before passing theassessment orders