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

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

159, ACIT vs Vidit Kumar Agarwal (2012) 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

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

147 of the Act. The want of valid notice affects the jurisdiction of the Assessing Officer to proceed with the assessment and thus, affects the validity of the proceedings for assessment or reassessment. A notice issued under section 148 of the Act against a dead person is invalid, unless the legal representative submits to the jurisdiction of the Assessing Officer

SHRI GURBINDER SINGH MAHAL,AMRITSAR vs. INCOME TAX OFFICER WARD-IV ( 2), AMRITSAR

In the result, the appeal of the assessee bearing ITA No

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

159. (1) Where a person dies, his legal representative shall be liable to pay any sum which the deceased would have been liable to pay if he had not died, in the like manner and to the same extent as the deceased. (2) For the purpose of making an assessment (including an assessment, reassessment or recomputation under section 147

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

147 is bad in law as the jurisdictional notice issued u/s 148 and proceedings completed u/s 148A(d) were made by the jurisdictional AO which is in violation with the provisions of section 151A read with notification no S.O. 1466 (E) No 18/2022 dated 29.03.2022. 6. That the information uploaded on the insight portal is nowhere corroborated with any independent

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

147 is bad in law as the jurisdictional notice issued u/s 148 and proceedings completed u/s 148A(d) were made by the jurisdictional AO which is in violation with the provisions of section 151A read with notification no S.O. 1466 (E) No 18/2022 dated 29.03.2022. 6. That the information uploaded on the insight portal is nowhere corroborated with any independent

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

159(1) and on perusal of assessment record, I have reasons to believe that income of Rs.29,99,972/- has escaped assessment for the A.Y. 2012-13. Thus, the AO has not applied independent mind rather he has acted in the direction of the ld. CIT(A)-5, Ludhiana issued u/s 150(1) of the Act to reopen the assessments

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

159(1) and on perusal of assessment record, I have reasons to believe that income of Rs.29,99,972/- has escaped assessment for the A.Y. 2012-13. Thus, the AO has not applied independent mind rather he has acted in the direction of the ld. CIT(A)-5, Ludhiana issued u/s 150(1) of the Act to reopen the assessments

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

159(1) and on perusal of assessment record, I have reasons to believe that income of Rs.29,99,972/- has escaped assessment for the A.Y. 2012-13. Thus, the AO has not applied independent mind rather he has acted in the direction of the ld. CIT(A)-5, Ludhiana issued u/s 150(1) of the Act to reopen the assessments

SMT. DHANWANTI DEVI (DECEASED),JAMMU vs. ASSISTANT COMMISSIONER OF INCOME TAX, JAMMU

In the result, all the appeals of the assessees bearing ITA Nos

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

reassessment proceedings were started in 1991. At that time army had converted into cantonment with military oriented constructions. Kindly refer to page 4, last para of CIT (A) in case of Dhanwanti Devi which refers to statement of Patwari Sh. Mohammad Nawaz. So this report is not contextual to 1949 when the Army requisitioned the lands. Page

SMT. ANURADHA MAHAJAN,,JAMMU vs. ASSISTANT COMMISSIONER OF INCOME TAX, JAMMU

In the result, all the appeals of the assessees bearing ITA Nos

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

reassessment proceedings were started in 1991. At that time army had converted into cantonment with military oriented constructions. Kindly refer to page 4, last para of CIT (A) in case of Dhanwanti Devi which refers to statement of Patwari Sh. Mohammad Nawaz. So this report is not contextual to 1949 when the Army requisitioned the lands. Page

SH. SUNIL GUPTA,JAMMU vs. ASSISTANT COMMISSIONER OF INCOME TAX, JAMMU

In the result, all the appeals of the assessees bearing ITA Nos

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

reassessment proceedings were started in 1991. At that time army had converted into cantonment with military oriented constructions. Kindly refer to page 4, last para of CIT (A) in case of Dhanwanti Devi which refers to statement of Patwari Sh. Mohammad Nawaz. So this report is not contextual to 1949 when the Army requisitioned the lands. Page

LAKHVIR SINGH 810, VPO MALLAH TEHSIL JAGRAON DISTRICT LUDHIANA,PUNJAB vs. THE ASSESSMENT UNIT NFAC DELHI JAO INCOME TAX OFFICER WARD-1, MOGA, PUNJAB

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

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

147 on the basis of wrong reasons recorded and also agitated the issue that reassessment in this case has been done after three years where the income escaped assessment is less than 50 lacs (fifty lakhs). 5 I.T.A. No. 541/Asr/2024 Assessment Year: 2015-16 10. Ground nos. 1, 2 & 3 relates to the issue where the ld. first appellate authority

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

section 147 of the act. Since, no addition made on the ground of reasons recorded, hence, the additions would not sustain.In support, he placed reliance on the judgement of the coordinate Amritsar Bench in the case of Gaurav Joshi versus Income Tax Officer in ITA No.274 ASR 2018 order dated Jan.16, 2019; [2019] 174 DTR 0353(Asr)Trib) where

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

section 147 of the act. Since, no addition made on the ground of reasons recorded, hence, the additions would not sustain.In support, he placed reliance on the judgement of the coordinate Amritsar Bench in the case of Gaurav Joshi versus Income Tax Officer in ITA No.274 ASR 2018 order dated Jan.16, 2019; [2019] 174 DTR 0353(Asr)Trib) where

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

section 147 of the act. Since, no addition made on the ground of reasons recorded, hence, the additions would not sustain.In support, he placed reliance on the judgement of the coordinate Amritsar Bench in the case of Gaurav Joshi versus Income Tax Officer in ITA No.274 ASR 2018 order dated Jan.16, 2019; [2019] 174 DTR 0353(Asr)Trib) where