SHRI SATBIR SINGH BHULLAR,AMRITSAR vs. INCOME TAX OFFICER WARD- 5 (4), AMRITSAR

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

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

section 147 r.w.s 144 of the Act, with an addition of Rs. 7,37,948/- by taking into consideration peak amount date 24.12.2017 on account of cash deposited in ICICI bank. Aggrieved assessee filed an appeal before the ld. CIT(A). The ld. CIT(A) uphold the order of assessment. Being dissatisfied the assessee filed an appeal before

SH.SHREE GURU NANAK DEV QUIN-CENTENARY CELEBRATION COMMITTEE,LUDHIANA vs. INCOME TAX OFFICER (EXEMPTION), JALANDHAR

In the result, appeal of the assessee is allowed

Bench: Shri L.P. Sahu, Am & Shri Ravish Sood, Jm आयकर अपील सं./Ita No.238/Asr/2019 आयकर अपील सं आयकर अपील सं आयकर अपील सं (िनधा"रण िनधा"रण वष" वष" / Assessment Year :2010-2011) िनधा"रण िनधा"रण वष" वष" Shree Guru Nanak Dev Vs. Ito(Exemptions) Ward, Quin-Centenary Celebrations Jalandhar Committee, Guru Nanak Bhawan, Ludhiana "थायी लेखा सं./Panno. : Aawfs 2431 F .. (अपीलाथ" /Appellant) (" यथ" / Respondent) : Shri S.K.Mukhi, Advocate िनधा"!रती क" क" क" ओर क" ओर ओर सेसेसेसे /Assessee By ओर ओर सेसेसेसे /Revenue By : Shri M.P.Singh, Cit-Dr राज"व क" क" क" ओर क" ओर ओर सुनवाई क" तार'ख / Date Of Hearing : 06/02/2020 घोषणा क" तार'ख/Date Of Pronouncement : 30/06/2020 आदेश आदेश / O R D E R आदेश आदेश Per L.P.Sahu, Am: This Is An Appeal Filed By The Assessee Against The Order Of Cit(A)-4, Ludhiana, Dated 08.02.2019, On The Following Grounds Of Appeal :- 1. That The Orders Of Ld. Cit(A) Is Illegal, Erroneous & Perverse & Thus Needs To Be Quashed. 2. That The Issuance Of Notice U/S 147/148 Is Bad In Law As No New Material Was There With The Ao To Initiate Action U/S 147 & The Proceedings In Furtherance Of Illegal Notice Are Void Ab-Initio & Deserve To Be Set Aside. 3. That The Addition Made By Ao & Partially Confirmed By Cit (A) Is Devoid Of Proper Appreciation Of Facts On Record & Against Express Provisions Of Law & Deserve To Be Set Aside. 4. That The Appellant Craves Leave To Add, Amend Or Delete Any Of The Grounds Of Appeal On Or Before The Disposal Of The Present Appeal. 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income On 15.06.2010 Declaring Total Income After Claiming Exemption

147 is given hereunder: "On perusal of record it, revealed that dosing balance of capital fund as on 31.03.2009 was Rs. 1,83,63,024/- but opening balance of capital fund as on 31.03.2010 was taken as Rs. 2,81,68,024. This has resulted into overstatement of capital fund to the tune of Rs.9805000/- (28168024-183630324) Capital Fund Details

SHRI RAVINDER SACHDEVA,AMRITSAR vs. INCOME TAX OFFICER WARD -5 (4), AMRITSAR

In the result, the appeal of the assesse is allowed for statistical

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

147 r.w.s.144 of the Act by making addition of an amount of Rs. 16,70,500/- of the cash deposit in his bank account with State Bank of India during the FY 2011-12 relevant to the AY 2012-13 as unexplained income u/s 68 of the act by observing as under: "As would be evident from above that

SH. VIKRANT KANSHAL,BATHINDA vs. THE ICNOMET-AX OFFICER,, BATHINDA

In the result, the assessee’s appeal is partly allowed

Bench: Sh. Sanjay Arora & Sh. N. K. Choudhryi.T.A. No. 367/Asr/2014 Assessment Year: 2008-09

147 were initiated in the case of the assessee to bring the said amount to tax in his hands. He would then take us through the bank account of MM for the period 01.04.2007 to 31.03.2008 (PB pgs. 7-9), seeking to emphasize that the cash deposited from time to time was withdrawn. The said explanation, accepted in the case

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

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

147 of the act. Thus ground number 3 and 4 of the appellant are rejected. Adjudication on merits of the case: In ground nos. 5 to 15, the quantum addition is challenged by spreading in multiple grounds with consequential interest to addition u/s 234A, 234B and 234C of the Act, and hence adjudicated simultaneously in the following paras

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

68 were justified- 4. Suman Poddar Vs ITO Special Leave to Appeal (C) No. 26864 OF 2019, [2019] 112 taxmann.com 330 (SC)- Where High Court upheld Tribunal's order holding that assessee's claim for exemption under section 10(38) could not be allowed because share transactions 19 I.T.A. Nos. 346 & 347/Asr/2024 Assessment Years: 2014-15 & 2015-16 were

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

68 were justified- 4. Suman Poddar Vs ITO Special Leave to Appeal (C) No. 26864 OF 2019, [2019] 112 taxmann.com 330 (SC)- Where High Court upheld Tribunal's order holding that assessee's claim for exemption under section 10(38) could not be allowed because share transactions 19 I.T.A. Nos. 346 & 347/Asr/2024 Assessment Years: 2014-15 & 2015-16 were

M/S. RAJ DEV ,KOTKAPURA vs. INCOME TAX OFFICER WARD-1, FARIDKOT

In the result, the appeal of the assesse is allowed for statistical

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

68 r.w.s. 115BBE of the Act. 4. Aggrieved by the assessment order of the AO, the assessee filed appeal before the CIT(A) and the Worthy CIT(A) passed the appellate order dated 31.01.2023 u/s 250 of the Act wherein, the appeal of the assessee was dismissed by observing that the AO has given his clear finding that opening cash

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 of the Income Tax Act, 1961? 3. On the date of hearing, there was no physical appearance by the assessee or his Ld. AR in the court and there was no appearance by any representative in virtual (on line video) mode either, and a written submission has been filed by the assessee with a prayer to dispose

ABDUL HAFIZ,UDHAMPUR vs. D.C.I.T, CIRCLE-2, JAMMU

In the result, the assessee’s appeal is allowed for statistical purposes

Bench: Sh. Sanjay Arora & Sh. N. K. Choudhryi.T.A. No. 465/(Asr)/2017 Assessment Year: 2013-14

147 Taxman 448 (All). On balance, section 68 is clearly applicable in the facts and circumstances of the case

SHRIMATI JATINDER KAUR ( ALIAS AMRITA),JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2, JALANDHAR

In the result all the appeals of the assessee are allowed

Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meena

section 68. Copy of the decision is enclosed at page no. 91. The view of the Delhi High Court in this case has been endorsed by the Supreme Court as the SLP of the revenue was dismissed and stands reported at 380 ITR 64 (Statute). Copy of the order is enclosed at page no. 92. In view

SHRIMATI JATINDER KAUR(ALIAS AMRITA),JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2, JALANDHAR

In the result all the appeals of the assessee are allowed

Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meena

section 68. Copy of the decision is enclosed at page no. 91. The view of the Delhi High Court in this case has been endorsed by the Supreme Court as the SLP of the revenue was dismissed and stands reported at 380 ITR 64 (Statute). Copy of the order is enclosed at page no. 92. In view

SHRIMATI JATINDER KAUR (ALIAS AMRITA),JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2, JALANDHAR

In the result all the appeals of the assessee are allowed

Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meena

section 68. Copy of the decision is enclosed at page no. 91. The view of the Delhi High Court in this case has been endorsed by the Supreme Court as the SLP of the revenue was dismissed and stands reported at 380 ITR 64 (Statute). Copy of the order is enclosed at page no. 92. In view

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

section 147 and also on the ground that the sanction granted by the JCIT is not in accordance of mandate of law. For this purpose, reliance is placed on the decision in the case of Smt. Prabha Rani Agarwal V. ITO. Copy at pages 1-7 of compendium. 5 6. From the reasons recorded it can be seen that

SHRI SUKHJIT SINGH,HOSHIARPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX-1, JALANDHAR

In the result, appeal of the assessees in ITA Nos

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

68 of the Act had not been discharged by her. 4. That on the facts and circumstances of the case, Learned Pr. Commissioner of Income Tax-1, Jalandhar has grossly erred in law in holding that income declared by the assessee was to be taxed u/s 115BBE of the Act. 5. That the order of the Learned Pr. Commissioner

SMT HARNEET KAUR JUNEJA,JALANDHAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX -1, JALANDHAR

In the result, appeal of the assessees in ITA Nos

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

68 of the Act had not been discharged by her. 4. That on the facts and circumstances of the case, Learned Pr. Commissioner of Income Tax-1, Jalandhar has grossly erred in law in holding that income declared by the assessee was to be taxed u/s 115BBE of the Act. 5. That the order of the Learned Pr. Commissioner

SHRI MANMOHAN SINGH KAPUR,HOSHIARPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX-1, JALANDHAR

In the result, appeal of the assessees in ITA Nos

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

68 of the Act had not been discharged by her. 4. That on the facts and circumstances of the case, Learned Pr. Commissioner of Income Tax-1, Jalandhar has grossly erred in law in holding that income declared by the assessee was to be taxed u/s 115BBE of the Act. 5. That the order of the Learned Pr. Commissioner

SH. KULDEEP SINGH,AMRITSAR vs. INCOME TAX OFFICER, WARD - 5(3), AMRITSAR

In the result, the appeal of the assessee is allowed

Bench: Shri N.K. Choudhry, Jm & Dr. A.L.Saini, Am आयकरअपीलसं./Ita No. 579/Asr/2017 ("नधा"रणवष" / Assessment Year: 2009-10)

section 147 of the Income Tax Act” Objections against reasons recorded 1. The reasons have been recorded on vague information. These reasons are not reasons in the eyes of law since they have recorded merely on vague information which cannot be held in ‘Bir Bahadu Singh Saijwali vs. ITO, Ward-1, Haldwani’ 53 Taxman. Co. 366 (Delhi-Trib