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

Section 2(22)(e), it was argued therein, should be read down inasmuch as it carried an irrebuttable presumption of a loan or advance to a substantial shareholder being a distribution of profit and, thus, dividend thereto, by definition, by a company (in which public is not substantially interested). It worked unfairly on those repaying the loan as against

M/S ACTIVE TOOLS (P). LIMITED,JALANDHAR vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE -II, JALANDHAR

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

68, 69A, 69B, 69C or 69D. Reliance is being placed on following case laws:- ITA 260/Amr/2019 8 a) DEV RAJ HI-TECH MECHINES LTD. vs.DEPUTY COMMISSIONER OF INCOME TAX (2015) 174 TTJ 0009 (Asr) ((UO)) Unexplained Income—Income from undisclosed sources—Assessee was a Manufacturer of Rice Sheller Machineries and its parts—A survey was carried out on the premises

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

22 SA No. 03/Asr./2019 P.D. Sekhsaria Trading Company Pvt. Ltd. a recognised association for the purposes of clause (e) of the proviso to clause (5) of section 43 may be made to the Member (Legislation), Central Board of Direct Taxes, North Block, New Delhi. (2) The application referred to in sub-rule (1) shall be accompanied with

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 of the Act. Without prejudice to the above, the AO further observed that if at any stage in the appellate proceedings, the higher judicial authorities, hold that the cash deposits as explained, and cash is actually belongs to the company, then the payment to be examined in the light of provisions of section 2(22)(e

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

E R Manoj Kumar Aggarwal (Accountant Member) 1. Aforesaid appeal by assessee for Assessment Year (AY) 2017- 18 arises out of an order of learned Commissioner of Income Tax (Appeals)-3, Gurgaon [CIT(A)] dated 25-11-2024 in the matter of an assessment framed by Ld. AO u/s 143(3) on 19-12-2019. In the assessment 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

e) All the purchases are from identifiable parties and majorly all the payments for the purchases have been made through normal banking channels and nothing has been I.T.A. No.195/Asr/2022 11 Assessment Year: 2017-18 doubted about such purchases. Thus, all the purchases are fully vouched. The sales are also fully vouched but majorly, the sales are made in cash

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

e. That the assessee has duly discharged his onus cast on it, therefore, no addition can be made in the hands of assessee firm, particularly considering the situation where the assessee firm has duly produced the relevant documents as required u/s 68 of the Act. 4.5 The ld. Counsel further argued that the assessee had submitted the details in relation

DR.HARPRIT SINGH,JALANDHAR vs. DY. COMMISSIONER OF INCOME TAX , JALANDHAR

In the result, appeal of the assessee is allowed

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

68 of the Income Tax Act, 1961 is illegal and bad in law. b) That on the facts and circumstances of the case, Ld. Assessing Officer has grossly erred in law in making addition of Rs. 18,959/- as undisclosed interest income. Addition made is illegal and bad in law. c) While estimating income, no credit for withdrawals made

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

e brought to tax as per the provisions section 68 of the Income Tax Act, 1961. During the appellate proceedings, the appellant has taken the ground that no addition can be made under section 68 of the Income Tax Act where the assessee is not maintaining any books of account as Section 68 of the Income

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

e) The consideration for transfer is a lump sum consideration. This consideration should be arrived at without assigning values to individual assets and liabilities. 35 A.Y.2015-16 The consideration may be discharged in cash or by issuing shares of Transferor Company. (f) Possibility of identification of price attributable to individual items (plant, machinery and dead stock) which are sold as part

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

2. That the Ld. CIT(A) has failed to appreciate that the amount of loan was received from the above said parties during the year under consideration through banking channels and the same was paid back through banking channels during the same year and, as such, the confirmation of addition as made by the Ld. CIT(A) is against

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

2. That the Ld. CIT(A) has failed to appreciate that the amount of loan was received from the above said parties during the year under consideration through banking channels and the same was paid back through banking channels during the same year and, as such, the confirmation of addition as made by the Ld. CIT(A) is against

SMT.ADEEKSHA NARULA,AMRITASR vs. DY.COMMISSIONER OF INCOME TAX , AMRITSAR

In the result, the particular issue u/s 153C of the Act related in ITA

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

2(22)(e) of the Act. The assessment was completed u/s 153A/143(3) of the Act. The ld. CIT(A) adjudicated the issue and confirmed the order of the AO. During the appellate proceeding assessee did not take the ground related to assessment U/s 153A was made on non-incriminating material. In the additional ground the ld. Counsel agitated

M/S. PINKU BATRA ,JALANDHAR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-II, JALANDHAR

In the result, the particular issue u/s 153C of the Act related in ITA

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

2(22)(e) of the Act. The assessment was completed u/s 153A/143(3) of the Act. The ld. CIT(A) adjudicated the issue and confirmed the order of the AO. During the appellate proceeding assessee did not take the ground related to assessment U/s 153A was made on non-incriminating material. In the additional ground the ld. Counsel agitated

M/S. PINKU BATRA ,JALANDHAR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-II, JALANDHAR

In the result, the particular issue u/s 153C of the Act related in ITA

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

2(22)(e) of the Act. The assessment was completed u/s 153A/143(3) of the Act. The ld. CIT(A) adjudicated the issue and confirmed the order of the AO. During the appellate proceeding assessee did not take the ground related to assessment U/s 153A was made on non-incriminating material. In the additional ground the ld. Counsel agitated

M/S. PINKU BATRA ,JALANDHAR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-II, JALANDHAR

In the result, the particular issue u/s 153C of the Act related in ITA

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

2(22)(e) of the Act. The assessment was completed u/s 153A/143(3) of the Act. The ld. CIT(A) adjudicated the issue and confirmed the order of the AO. During the appellate proceeding assessee did not take the ground related to assessment U/s 153A was made on non-incriminating material. In the additional ground the ld. Counsel agitated

M/S. PINKU BATRA ,JALANDHAR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-II, JALANDHAR

In the result, the particular issue u/s 153C of the Act related in ITA

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

2(22)(e) of the Act. The assessment was completed u/s 153A/143(3) of the Act. The ld. CIT(A) adjudicated the issue and confirmed the order of the AO. During the appellate proceeding assessee did not take the ground related to assessment U/s 153A was made on non-incriminating material. In the additional ground the ld. Counsel agitated

M/S. PINKU BATRA ,JALANDHAR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-II, JALANDHAR

In the result, the particular issue u/s 153C of the Act related in ITA

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

2(22)(e) of the Act. The assessment was completed u/s 153A/143(3) of the Act. The ld. CIT(A) adjudicated the issue and confirmed the order of the AO. During the appellate proceeding assessee did not take the ground related to assessment U/s 153A was made on non-incriminating material. In the additional ground the ld. Counsel agitated