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

Section 147 (a) of the Act the Act. (2) 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&H- 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

90 (DCIT vs Narendra Mohan Bagrev) The Honorable Bench has held that AO did not have sufficient material in forming the belief that income has escaped assessment, hence reopening is bad. 104 TTJ (ASR) 353 (Pyramid Software & Technologies vs DCIT) The jurisdictional Amritsar Bench has held that the reason to belief u/s 147 has special significance. It does not mean

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

reassessment proceedings provided he has reasons to believe but the same cannot be taken recourse to on the basis of reasons to suspect-ITO & Ors, vs. Lakhmani Mewal Das 1976 CTR (SC) 220 (1976) 103 ITR 437 (SC) relied on". Therefore, the very assumption of jurisdiction u/s 147 on the basis of the "reason" recorded is vitiated. Thus, the reasons

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

reassessment proceedings provided he has reasons to believe but the same cannot be taken recourse to on the basis of reasons to suspect-ITO & Ors, vs. Lakhmani Mewal Das 1976 CTR (SC) 220 (1976) 103 ITR 437 (SC) relied on". Therefore, the very assumption of jurisdiction u/s 147 on the basis of the "reason" recorded is vitiated. Thus, the reasons

M/S PARADISE MULTIPLEX CUM VILLAS. PVT. LTD,ABOHAR vs. INCOME TAX OFFICER WARD-II(3), ABOHAR

In the result, the appeals of assessee bearing ITA No

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

reassessment proceedings: I.T.A. No.628/Asr/2018 10 I.T.A. No.138/Asr/2019 “As per information available with this office that the above noted assessee has credited in the bank account no. 65030336634 with SBOP, Abohar amounting to Rs.7,37,60,500/- and also purchased properties for a consideration of Rs. 1,72,88,000/-. The above noted assessee has filed its income tax return

M/S PARADIES MULTIPLEXS CUM VILLAS PVT LTD ,ABHOAR vs. INCOME TAX OFFICER WARD 2(3) , ABOHAR

In the result, the appeals of assessee bearing ITA No

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

reassessment proceedings: I.T.A. No.628/Asr/2018 10 I.T.A. No.138/Asr/2019 “As per information available with this office that the above noted assessee has credited in the bank account no. 65030336634 with SBOP, Abohar amounting to Rs.7,37,60,500/- and also purchased properties for a consideration of Rs. 1,72,88,000/-. The above noted assessee has filed its income tax return

CHAND JEWELLERS,NAKODAR vs. INCOME TAX OFFICER, JALANDHAR

In the result the appeal of the assessee is allowed for statistical purposes

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta(Physical Hearing) I.T.A. No. 574/Asr/2025 Assessment Year: 2017-18 Chand Jewellers, Bazar Sarafan Vs. Ito-Ward Nakodar, Distt. Jalandhar. Jalandhar. [Pan:-Aahfc5908J] (Appellant) (Respondent) Appellant By Sh. Amit Bajaj, Adv. Respondent By Sh. Charan Dass, Sr. Dr

u/s 147 r.w.s 144B of the Act, vide order dated 29.03.2022. 2. Grounds of appeal taken by the assessee in form 36 are as under: I.T.A. No. 574/Asr/2025 2 Assessment Year: 2017-18 “1. That the impugned appellate order passed under section 250 of the Income-tax Act, 1961, upholding the assessment order passed under section 147 r.w.s. 144B

MEASAGE BHAI INDUSTRIES PRIVATE LIMITED,MOGA vs. INCOME TAX OFFICER WARD-1, MOGA

Appeal of the assessee is allowed

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

u/s 148 of the Act only on the basis of information received from the Investigation Wing was not valid. Accordingly, the reassessment framed by the AO is quashed.” 22. In the case of ‘Principal Commissioner of Income Tax-4 vs. G & G Pharma Ltd.’, reported in 384 ITR 147 of Hon’ble Delhi High Court (CLPB

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

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

90,78,000/- upheld by Sir, it is submitted that cash of cash deposit in bank. the worthy CIT(A) deposit in bank duly recorded in the books of assessee company and all the bank account duly reflected in the balance sheet of assessee company filed before the department at the time of filing of return of income. Moreover

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

90,78,000/- upheld by Sir, it is submitted that cash of cash deposit in bank. the worthy CIT(A) deposit in bank duly recorded in the books of assessee company and all the bank account duly reflected in the balance sheet of assessee company filed before the department at the time of filing of return of income. Moreover

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

90,78,000/- upheld by Sir, it is submitted that cash of cash deposit in bank. the worthy CIT(A) deposit in bank duly recorded in the books of assessee company and all the bank account duly reflected in the balance sheet of assessee company filed before the department at the time of filing of return of income. Moreover

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

90,78,000/- upheld by Sir, it is submitted that cash of cash deposit in bank. the worthy CIT(A) deposit in bank duly recorded in the books of assessee company and all the bank account duly reflected in the balance sheet of assessee company filed before the department at the time of filing of return of income. Moreover

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

90,78,000/- upheld by Sir, it is submitted that cash of cash deposit in bank. the worthy CIT(A) deposit in bank duly recorded in the books of assessee company and all the bank account duly reflected in the balance sheet of assessee company filed before the department at the time of filing of return of income. Moreover

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

90,78,000/- upheld by Sir, it is submitted that cash of cash deposit in bank. the worthy CIT(A) deposit in bank duly recorded in the books of assessee company and all the bank account duly reflected in the balance sheet of assessee company filed before the department at the time of filing of return of income. Moreover

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

90,78,000/- upheld by Sir, it is submitted that cash of cash deposit in bank. the worthy CIT(A) deposit in bank duly recorded in the books of assessee company and all the bank account duly reflected in the balance sheet of assessee company filed before the department at the time of filing of return of income. Moreover

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

90,78,000/- upheld by Sir, it is submitted that cash of cash deposit in bank. the worthy CIT(A) deposit in bank duly recorded in the books of assessee company and all the bank account duly reflected in the balance sheet of assessee company filed before the department at the time of filing of return of income. Moreover