BHUPENDRA FLOUR MILLS PVT LTD,BATHINDA vs. ITO, WARD 1(1), BATHINDA, BATHINDA

The appeal stands partly allowed in terms of out above order

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Shri Udayandasgupta, Jm आयकरअपीलसं. / Ita No.54/Asr/2025 (िनधा"रणवष" / Assessment Year: 2017-18) M/S Bhupendra Flour Mills Pvt Ltd. Ito Ward - 1(1) बनाम/ Railway Road Central Revenue Building Bhatinda, Punjab – 151001 Civil Lines, Bhatinda Vs. Punjab - 151001 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aaccb-6192-P (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Sudhir Sehgal (Advocate) - Ld. Ar " थ"कीओरसे/Respondent By : Sh. Farhat Khan (Cit) – Ld. Dr (Virtual) सुनवाईकीतारीख/Date Of Hearing : 05-02-2026 घोषणाकीतारीख /Date Of Pronouncement 20.02.2026 : आदेश / O R D E R

19-12-2019. In the assessment order, Ld. AO made twin additions of Rs.258.46 Lacs and Rs.233 Lacs which is subject matter of present appeal before us. Having heard rival submissions, the appeal is disposed-off as under. 2. The first addition as made by Ld. AO was for Rs.2,58,46,372/-. The same stem from the fact that

MEASAGE G. G OILS & FATS PRIVATE LIMITED,BATHINDA vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE- 1 , BATHINDA

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

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjeei.T.A. No.189/Asr/2018 Assessment Years: 2014-15

19 Assessment Years: 2014-15& 2016-17 was deducted, and the Certificate was also duly annexed with APB. The entire amount was transacted by both the companies for business exigencies. 12. The ld. DR vehemently argued and fully relied on the order of the ld. CIT(A) and also placed that the issue was not covered by the order

MESERS G.G CONTINEENTAL TRADES PVT.LTD,BATHINDA vs. DEPUTY COMMISSIONER OF INCOME TAX , CIRCLE-I, BATHINDA

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

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjeei.T.A. No.189/Asr/2018 Assessment Years: 2014-15

19 Assessment Years: 2014-15& 2016-17 was deducted, and the Certificate was also duly annexed with APB. The entire amount was transacted by both the companies for business exigencies. 12. The ld. DR vehemently argued and fully relied on the order of the ld. CIT(A) and also placed that the issue was not covered by the order

SHRI RAJ KUMAR ( M/S RADHIKA SALES CORP ), AMRITSAR vs. INCOME TAX OFFICER WARD- 3 (3), AMRITSAR

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

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

2,3,& 7 relate to the addition of " 27400000/- on account of cash deposit during demonetization , presuming the same as ‘inflated cash in hand’ from ‘inflated sales’ and such addition is based on conjectures and surmises and hence the addition made is against the facts and circumstances of the case. d) It is submitted that year after year, the assessee

HOSHIARPUR TRADERS ,HOSHIARPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX -1, JALANDHAR

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

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

19 Assessment Year: 2017-18 543 to 544. 2. That during proceedings under section 263 the assessee had furnished the copy of affidavit regarding capital contribution made by partner Gautam Aggarwal. (Refer page no. 542 of the paper book) 3. Furthermore, the assessee also submitted copy of cash book of GautamAggarwalto substantiate the source of capital investment made

M/S SANT BABA BHAG SINGH MEMORIAL CHARITABLE SOCIETY,JALANDHAR vs. D.C.I.T, CIRCLE - 1 (EXEMPTION), CHANDIGARH

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

Bench: Sh. Sanjay Arora & Sh. N. K. Choudhryi.T.A. No. 432/(Asr)/2017 Assessment Year: 2014-15

2(24)(iia) – defining income to include voluntary contribution received by a charitable trust or institution, and section 68. Where a receipt is admitted as income, where, pray, and even as afore-stated, is the need to travel to section 68 which, as afore-noted, requires proving the nature and source of the receipt lest

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

19 Assessment Year: 2008-09 letter dated 13/02/2021 which is enclosed at page 1-4 of APB. The Jamabandi/Girdawari represents the nature of income of assessee as agriculturist. Further, the assessee properly raised the ground related addition U/s 68 of the Act without maintaining the books of accounts. The assessee confirmed that as an agriculturist is not maintain books

MAX FINANCIAL SERVICE LIMITED ,NAWANSHAHR vs. PRINCIPAL COMMISSIONER OF INCOME TAX -1, JALANDHAR

In the result, the appeal of the assessee is therefore partly allowed

19 A.Y.2015-16 the decision of the Hon'ble Apex Court in the case of Raj Dadarkar & Associates Vs. ACIT (supra) is, we find, based on incorrect application of law to the facts of the case. 24. In view of the above we set aside the findings of the Ld. Pr.CIT of the order being erroneous and prejudicial to the interest

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

19. In the present case, in the assessment proceedings the queries were raised specifically in relation to section 69 of the Act. The queries were raised generally only to ascertain the facts. If for instance, it had been found in the assessment proceedings that the amounts deposited/received in Bank account by the assessee which had not been recorded

DR. HARPRIT SINGH ,JALANDHAR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-II, JALANDHAR

In the result, the appeal of the assessee stands allowed

Bench: Shri N.K. Choudhry & Shri O.P.Meenaआ.अ.संसंसंसं././././I.T.A No.195/Asr/2018 िनधा"रणवष"/A.Y.:2011-12 िनधा"रणवष" िनधा"रणवष" िनधा"रणवष" Dr. Harprit Singh, C/O M/S. Vs. Deputy Commissioner Of Orthonova Hospital, Near Nari Income-Tax, Niketan, Nakoddar Road, Central Circle –Ii, Jalandhar Jalandhar(Pb) (Pb) Pan: Acmps 7237 F अपीलाथ"Appellant अपीलाथ" ""यथ"/Respondent ""यथ" अपीलाथ" अपीलाथ" ""यथ" ""यथ"

68 it cannot be taxed under section 69 of the Act nor can be brought to tax as deemed dividend u/s. 2(22)(e) of the Act. 10. In the light of ratio laid down in above decision we hold that the CIT (A) was not justified in sustaining the addition, when the AO was not certain under which

MESERS P.D SEKHSARIA TRADING COMPANY ,BATHINDA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, BATHINDA

In the result, the appeal of the assessee is allowed and the Stay Petition of the assessee is dismissed

Bench: Sh. N. S. Saini & Sh. N. K. Choudhryita No. 331/Asr./2018 : Asstt. Year : 2014-15 M/S P. D. Sekhsaria Trading Vs Dy. Commissioner Of Income Company Pvt. Ltd., 4242, Tax, Circle-I, Ground Floor, Gurudwara Singh Bathinda, Punjab Sabha Street, Bathinda, Punjab (Appellant) (Respondent) Pan No. Aabcp1720E Sa No. 03/Asr./2019 (In Ita No. 331/Asr./2018: Asstt. Year : 2014-15) M/S P. D. Sekhsaria Trading Vs Dy. Commissioner Of Income Company Pvt. Ltd., 4242, Tax, Circle-I, Ground Floor, Gurudwara Singh Bathinda, Punjab Sabha Street, Bathinda, Punjab (Appellant) (Respondent) Pan No. Aabcp1720E Assessee By : Shri. Salil Kapoor, Adv. & Shri. Sanat Kapoor, Adv. Revenue By : Shri. M. P. Singh, Cit Dr Date Of Hearing :20.02.2019 Date Of Pronouncement : 19.03.2019 Order Per N. S. Saini: This Is An Appeal Filed By The Assessee Against The Order Of Cit(A), Bathinda Dated 26.03.2018. 2. The Assessee Has Raised Following Grounds Of Appeal: “1. That On The Facts & Circumstances Of The Case The Addition/Disallowance Of Rs.4,69,47,808/- Made

19 SA No. 03/Asr./2019 P.D. Sekhsaria Trading Company Pvt. Ltd. 28. Case of the Appellant is identical to above situation, even this time condition and procedure for applying were announced vide Notification no. 51 on 4-7-2013 vide Rule 6DDC, Rule 6DDD and form 3BC (ITA 6534 / 2012). Therefore, just because NCDEX was notified

ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR vs. M/S JASDEEP KAUR CHADHA, JALANDHAR

In the result, the appeal of the assessee is allowed and the revenue appeal is dismissed

Bench: Sh. Udayan Das Gupta & Sh. Khettra Mohan Roy

section 68 of the Act. The Hon’ble Supreme Court in NRA Iron & Steel Pvt. Ltd. has categorically held that the assessee must prove identity, capacity, and genuineness of the transaction by cogent evidence. The acceptance of such transactions by the CIT(A) without proper I.T.A. Nos. 250 & 359/Asr/2025 19 Assessment Year: 2018-19 verification and giving an opportunity

JASDEEP KAUR CHADHA-JALANDHAR,PUNJAB vs. JAO THE DCIT CIRCLE-4 JALANDHAR, PUNJAB

In the result, the appeal of the assessee is allowed and the revenue appeal is dismissed

Bench: Sh. Udayan Das Gupta & Sh. Khettra Mohan Roy

section 68 of the Act. The Hon’ble Supreme Court in NRA Iron & Steel Pvt. Ltd. has categorically held that the assessee must prove identity, capacity, and genuineness of the transaction by cogent evidence. The acceptance of such transactions by the CIT(A) without proper I.T.A. Nos. 250 & 359/Asr/2025 19 Assessment Year: 2018-19 verification and giving an opportunity

M/S G G OILS & FATS PVT.LTD ,BATHINDA vs. DEPUTY COMMISSIONER OF INCOME TAX, BATHINDA

In the result, the assessee’s appeal is dismissed

Bench: Sh. Sanjay Arora & Sh. N. K. Choudhryi. T. A. No. 508/Asr/2017 Assessment Year: 2014-15

19(1)(f) and (g) of the Constitution. The scope of the relevant entry (in the Legislative lists), it explained, are not powers but fields of legislation and the widest import and significance should be attached to them. While section 2(6A), analogous to section 2(22) of the Act, defines dividend, including deemed dividend (under certain specified

SH. PUNEET SEHDEV PROP,JAMMU vs. THE INCOME-TAX OFFICER, JAMMU

Bench: Shri L. P. Sahu & Shri Ravish Sood

68. Ground of appeal No. 6 is allowed. 7. DISALLOWANCE U/S 40A(3) : Shri Puneet Sehdev Vs. ITO, Ward 2(2), Jammu – A.Y 2008-09 & A.Y 2009-10- ITA No. 305/Asr/2015 & ITA No. 05/Asr/2013 Shri Puneet Sehdev Vs. ITO, Ward 2(2), Jammu –A.Y 2009-10- ITA No.579/Asr/2016 11 ITO, Ward 2(2), Jammu Vs. Puneet Sehdev

PUNEET SAHDEV,JAMMU vs. THE INCOME TAX OFFICER, JAMMU

Bench: Shri L. P. Sahu & Shri Ravish Sood

68. Ground of appeal No. 6 is allowed. 7. DISALLOWANCE U/S 40A(3) : Shri Puneet Sehdev Vs. ITO, Ward 2(2), Jammu – A.Y 2008-09 & A.Y 2009-10- ITA No. 305/Asr/2015 & ITA No. 05/Asr/2013 Shri Puneet Sehdev Vs. ITO, Ward 2(2), Jammu –A.Y 2009-10- ITA No.579/Asr/2016 11 ITO, Ward 2(2), Jammu Vs. Puneet Sehdev

SH. PUNEET SEHDEV PROP;,JAMMU vs. THE INCOME-TAX OFFICER,, JAMMU

Bench: Shri L. P. Sahu & Shri Ravish Sood

68. Ground of appeal No. 6 is allowed. 7. DISALLOWANCE U/S 40A(3) : Shri Puneet Sehdev Vs. ITO, Ward 2(2), Jammu – A.Y 2008-09 & A.Y 2009-10- ITA No. 305/Asr/2015 & ITA No. 05/Asr/2013 Shri Puneet Sehdev Vs. ITO, Ward 2(2), Jammu –A.Y 2009-10- ITA No.579/Asr/2016 11 ITO, Ward 2(2), Jammu Vs. Puneet Sehdev

INCOME TAX OFFICER, JAMMU vs. SH. PUNEET SEHDEV, PROP., JAMMU

Bench: Shri L. P. Sahu & Shri Ravish Sood

68. Ground of appeal No. 6 is allowed. 7. DISALLOWANCE U/S 40A(3) : Shri Puneet Sehdev Vs. ITO, Ward 2(2), Jammu – A.Y 2008-09 & A.Y 2009-10- ITA No. 305/Asr/2015 & ITA No. 05/Asr/2013 Shri Puneet Sehdev Vs. ITO, Ward 2(2), Jammu –A.Y 2009-10- ITA No.579/Asr/2016 11 ITO, Ward 2(2), Jammu Vs. Puneet Sehdev

SHRI FAROOQ AHMAD AHANGAR,SRINAGAR vs. INCOME TAX OFICER, WARD-3(1, SRINAGAR

In the result, both the appeals are allowed

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

19. In the above view, we hold that the order of the Ld. CIT(A) is perverse on the facts of the case and thus, section 68 of the Act was wrongly invoked in the present case in respect of the wage liability. Accordingly, the addition of Rs 572590.00 is deleted. Farooq Ahmad Ahangar