M/S SADHU SINGH HAMDARD TRUST,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeals of the assessee bearing ITA Nos

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

reassessment or recomputation, as the case may be, is less than sixty days, such remaining period shall be extended to sixty days and the aforesaid period of limitation shall be deemed to be extended accordingly:” 5.1 We thoughtfully considered that the submission of the ld. counsel to section 153(4) is related to the transfer pricing

M/S SADHU SINGH HAMDARD TRUST,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeals of the assessee bearing ITA Nos

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

reassessment or recomputation, as the case may be, is less than sixty days, such remaining period shall be extended to sixty days and the aforesaid period of limitation shall be deemed to be extended accordingly:” 5.1 We thoughtfully considered that the submission of the ld. counsel to section 153(4) is related to the transfer pricing

M/S SADHU SINGH HAMDARD TRUST,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeals of the assessee bearing ITA Nos

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

reassessment or recomputation, as the case may be, is less than sixty days, such remaining period shall be extended to sixty days and the aforesaid period of limitation shall be deemed to be extended accordingly:” 5.1 We thoughtfully considered that the submission of the ld. counsel to section 153(4) is related to the transfer pricing

M/S SADHU SINGH HAMDARD TRUST,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeals of the assessee bearing ITA Nos

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

reassessment or recomputation, as the case may be, is less than sixty days, such remaining period shall be extended to sixty days and the aforesaid period of limitation shall be deemed to be extended accordingly:” 5.1 We thoughtfully considered that the submission of the ld. counsel to section 153(4) is related to the transfer pricing

M/S SADHU SINGH HAMDARD TRUST,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeals of the assessee bearing ITA Nos

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

reassessment or recomputation, as the case may be, is less than sixty days, such remaining period shall be extended to sixty days and the aforesaid period of limitation shall be deemed to be extended accordingly:” 5.1 We thoughtfully considered that the submission of the ld. counsel to section 153(4) is related to the transfer pricing

M/S SADHU SINGH HAMDARD TRUST,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeals of the assessee bearing ITA Nos

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

reassessment or recomputation, as the case may be, is less than sixty days, such remaining period shall be extended to sixty days and the aforesaid period of limitation shall be deemed to be extended accordingly:” 5.1 We thoughtfully considered that the submission of the ld. counsel to section 153(4) is related to the transfer pricing

M/S SADHU SINGH HAMDARD TRUST,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeals of the assessee bearing ITA Nos

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

reassessment or recomputation, as the case may be, is less than sixty days, such remaining period shall be extended to sixty days and the aforesaid period of limitation shall be deemed to be extended accordingly:” 5.1 We thoughtfully considered that the submission of the ld. counsel to section 153(4) is related to the transfer pricing

POONAM MARWAHA,AMRITSAR vs. ACIT DCIT CEN CIR, AMRITSAR

In the result, the appeal filed by assessee is allowed

transfer of long term securities (Penny stock shares) - Assessment year 2014-\n15 - Whether before exercise of power under section 263 it is Principal Commissioner\nwho has to apply its mind to issue and thereafter record reasons as to how twin conditions\nof order of Assessing Officer being erroneous and prejudicial to interest of revenue are\nsatisfied and then issue

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

price per QUNTL for exported sales comes to Rs. 3,997.30. The realization from exports is much better than domestic market. Hence no adverse cognizance is drawn. 4. The statement of Sh. Raman Arora, who is accommodate entry provider, is taken on oath during the course of proceedings dated 08.10.2018. In his statement Sh. Raman Arora had specifically denied

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

price per QUNTL for exported sales comes to Rs. 3,997.30. The realization from exports is much better than domestic market. Hence no adverse cognizance is drawn. 4. The statement of Sh. Raman Arora, who is accommodate entry provider, is taken on oath during the course of proceedings dated 08.10.2018. In his statement Sh. Raman Arora had specifically denied

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

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

reassessment are held to be devoid of any merits and substance and therefore, same are as such rejected. 12. In ground no. 3 & 4, the assessee has challenged approval granted by the CIT u/s 151 for issuing notice u/s 147 as bad in law. This issue of approval granted u/s 151 of the Income

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

transferred by the assessee to the M/s Devinder Kumar Deepesh Kumar ,as an accommodation entry for recording of bogus purchase, because 4 I.T.A. No. 236/Asr/2023 Assessment Year: 2011-12 as per the AO the physical movement of goods could not be proved, in absence of any Bilty, weighment slip of goods, octroi receipts, and in absence of any proof

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 CITI PLAZA,JALANDHAR vs. INCOME TAX OFFICER , WARD 3(1), JALANDHAR

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

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

price of Rs.2,30,00,000/-, has wrongly been assessed and upheld in this case. I.T.A. No. 356/Asr/2017 3 Assessment Year: 2006-07 6. That the Id.CIT(A) was not justified in ignoring assessee's submissions that if at all the reopening was valid, the Id ITO could not have given a clean chit to other group of partners headed

SMT. GURJEET KAUR,JALANDHAR vs. INCOME TAX OFFICER, WARD- IV (2),, JALANDHAR

The appeal of the assessee is allowed in terms of our

Bench: Sh. Ravish Sood & Dr. M. L. Meena

transferred from his bank account. Backed by his aforesaid observations, the A.O acting upon the contents of the “agreement to sell”, therein, held the amount of Rs. 1.50 crore received by the assessee as 8 Smt. Gurjeet Kaur Vs. ITO-Ward 3(4), Jalandhar ITA No. 627 & 628/Asr/2017 – A.Y 2008-09 & 2009-10 earnest money from Sh. Surjit Singh (supra

SMT. GURJEET KAUR,JALANDHAR vs. INCOME TAX OFFICER, WARD- IV (2),, JALANDHAR

The appeal of the assessee is allowed in terms of our

Bench: Sh. Ravish Sood & Dr. M. L. Meena

transferred from his bank account. Backed by his aforesaid observations, the A.O acting upon the contents of the “agreement to sell”, therein, held the amount of Rs. 1.50 crore received by the assessee as 8 Smt. Gurjeet Kaur Vs. ITO-Ward 3(4), Jalandhar ITA No. 627 & 628/Asr/2017 – A.Y 2008-09 & 2009-10 earnest money from Sh. Surjit Singh (supra

SHRI SURINDER SINGH DECEASED,AMRITSAR. vs. THE INCOME TAX OFFICER,, AMRITSAR.

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

Bench: Sh. Sanjay Arora

reassessment proceedings, initiated through issue of notice u/s. 148(1) on 26.3.2009, his wife Smt. Jatinder Kaur, filed a reply dated 08.12.2009 (through her counsel, Sh. Nagpal), reproduced at page 3 of the assessment order, stating to be not aware of any such bank account of her late husband and, in any case, of any such money belonging