PAWAN KUMAR,AMBALA, HARYANA vs. INCOME TAX OFFICER WARD-3 AMBALA, AMBALA CANTT

In the result, the appeal is allowed

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

deposited in the bank out of the cash withdrawal from the same bank or recovered from the zimidars. As assessee has not other source of income other then commission income and he has not purchased / sold any goods. Addition made by Ld. AO is wrong, unjustified and against the facts of the case. Reconciliation of sales, VAT, Commission

SH. GULSHAN KUMAR PROP. G.K. RESORTS,LUDHIANA vs. DCIT CIRCLE-2, LUDHIANA

In the result, the appeal of the assessee is allowed

Bench: Smt.Diva Singh & Shri Vikram Singh Yadavsh. Gulshan Kumar बनाम Deputy Commissioner Of Prop. G. K. Resorts House No. 3, Income Tax, Central Circle-2, Agar Nagar Extension, Ferospur Ludhiana Road, Ludhiana 1410212, Punjab "थायी लेखा सं./Pan No: Aaqpk1200Q

cash deposits by the assessee, it was submitted that the assessee has contended that the TDS provisions are not applicable

BANUR BROTHER ,PATIALA vs. ITO-WARD-1, AMBALA

In the result appeal of the assessee is allowed as and by way of remand to Ld

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

TDS on supply of foodgrains. Therefore, Ld. CIT(A) had erred in upholding the finding of Ld. AO that total sales to DFSC of Rs. 3,19,30,200/- doesn't match with the Form 26AS sales. 2.2.12 Moreover, the Appellant had also deposited Value Added Tax (VAT) of Rs. 16,14,682.03/- on the total sales made during

SKYCITY BUILDERS AND PROMOTERS PRIVATE LIMITED, ,KHARAR, RUPNAGAR vs. DCIT WARD 6(1), CHANDIGARH JAO ITO 6(1) MOHALI, CHANDIGARH

In the result, the corresponding grounds as raised by the revenue stand dismissed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No.1066/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2012-13) M/S Skycity Builders & Promoters Pvt. Ltd. Dcit Ward 6(1) बनाम/ Room No.3, 1St Floor Sco-90, City Heart Kharar-Chandigarh Road, Livestock Complex Vs. Kharar, Rupnagar (Punjab) - 140301 Sector – 68, Mohali -160062 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aapcs-2435-R (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकर अपील सं./ Ita No.1217/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2012-13) Dcit Ward 6(1) M/S Skycity Builders & Promoters Pvt. Ltd. बनाम/ Room No.3, 1St Floor Sco-90, City Heart Livestock Complex Kharar-Chandigarh Road, Vs. Sector – 68, Mohali -160062 Kharar, Rupnagar (Punjab) - 140301 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aapcs-2435-R (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Sudhir Sehgal (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Ms. Yamini (Cit) - Ld. Dr (Virtual) सुनवाईकीतारीख/Date Of Hearing : 05.02.2026 घोषणाकीतारीख /Date Of Pronouncement : 16.03.2026

cash deposits and this entity has defaulted in loans. The TDS has been deducted against this entity for AYs 2013-14 and 2014-15 only

INCOME TAX OFFICER WARD 6 (1), MOHALI vs. SKYCITY BUILDERS AND PROMOTERS PRIVATE LIMITED, KHRAR PUNJAB

In the result, the corresponding grounds as raised by the revenue stand dismissed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No.1066/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2012-13) M/S Skycity Builders & Promoters Pvt. Ltd. Dcit Ward 6(1) बनाम/ Room No.3, 1St Floor Sco-90, City Heart Kharar-Chandigarh Road, Livestock Complex Vs. Kharar, Rupnagar (Punjab) - 140301 Sector – 68, Mohali -160062 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aapcs-2435-R (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकर अपील सं./ Ita No.1217/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2012-13) Dcit Ward 6(1) M/S Skycity Builders & Promoters Pvt. Ltd. बनाम/ Room No.3, 1St Floor Sco-90, City Heart Livestock Complex Kharar-Chandigarh Road, Vs. Sector – 68, Mohali -160062 Kharar, Rupnagar (Punjab) - 140301 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aapcs-2435-R (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Sudhir Sehgal (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Ms. Yamini (Cit) - Ld. Dr (Virtual) सुनवाईकीतारीख/Date Of Hearing : 05.02.2026 घोषणाकीतारीख /Date Of Pronouncement : 16.03.2026

cash deposits and this entity has defaulted in loans. The TDS has been deducted against this entity for AYs 2013-14 and 2014-15 only

M/S TJR PROPERTIES PVT. LTD.,CHANDIGARH vs. ACIT, CC-2, CHANDIGARH

Bench: SHRI A.D.JAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)

deposited, neither the AO, nor the CIT(A) on receipt of the documentary ITA 3 &144/CHD/2023 A.Y. 2014-15 59 evidence put any question to the assessee, or initiated any enquiry, either u/s 133(6) of the Act, or u/s 131 thereof. It stands made out that the assessee had earned the income of Rs.7 lacs from leasing

ACIT, CC-2, CHANDIGARH vs. M/S TJR PROPERTIES PVT. LTD., CHANDIGARH

Bench: SHRI A.D.JAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)

deposited, neither the AO, nor the CIT(A) on receipt of the documentary ITA 3 &144/CHD/2023 A.Y. 2014-15 59 evidence put any question to the assessee, or initiated any enquiry, either u/s 133(6) of the Act, or u/s 131 thereof. It stands made out that the assessee had earned the income of Rs.7 lacs from leasing

ITO WARD-1, KHANNA vs. SMT. HARINDER KAUR, PROP. M/S GURU NANAK FILLING STATION, LUDHIANA

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri Krinwant Sahay & Shri Paresh M. Joshi

deposit of cash in the regular bank account of the assessee as under: a) The copy of the computation of income, Audit report, Balance Sheet, Trading and Profit & Loss Account, TDS

SHRI DILRAJ SINGH DHALIWAL,CHANDIGARH vs. PR.CIT-1, CHANDIGARH

deposits made by the assessee. It was submitted that during the course of assessment proceedings, notices and detailed questionnaire were issued by the AO from time to time vide notices dt. 19/09/2016, 19/01/2017, 05/09/2017 and also through various order sheet entries and in response, the assessee filed written submission vide letter dt. 25/07/2017, 28/08/2017, 05/09/2017 and 14/09/2017 and thereafter after

SMT. SHIPRA VIG,YAMUNA NAGAR vs. PR. CIT, PANCHKULA

In the result, appeal of the Assessee is allowed

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

cash in hand and which has been deposited in the bank accounts of the assessee for remitting to NBFC companies. 3.8 Lastly, it was argued vehemently that commission income as disclosed has not been doubted at all and such commission income is matching to TDS

M/S TJR PROPERTIES PVT. LTD.,CHANDIGARH vs. ACIT, CC-2, CHANDIGARH

In the result, the Appeal is partly allowed

Bench: Shri A.D. Jain & Shri Vikram Singh Yadav

TDS Receivable. The CIT has wrongly taken a plea that the assessee company has deposited cash amounting to Rs.4,50,000/- on 25.03.2015 as date

ACIT, LUDHIANA vs. M/S K LAL OVERSEAS PVT. LTD., LUDHIANA

The appeal of the assessee is hereby allowed whereas the appeal of the Revenue is dismissed

Bench: Shri Sanjay Garg & Shri Vikram Singh Yadav

deposited in bank in cash . 3. Lakhvinder singh chawla - Rs. 30,00,0001- . No confirmation filed by appellant, even after no verification in absence of service of notice by A.O, in enquiry proceedings. 4. Rahul Jain - RS. 25,00,000/- . It is observed that, the party has received accommodation entry of Rs. 24,62,623/- from a penny stock company

M/S K.LALL OVERSEAS,LUDHIANA vs. ACIT,CIRCLE-6, LUDHIANA

The appeal of the assessee is hereby allowed whereas the appeal of the Revenue is dismissed

Bench: Shri Sanjay Garg & Shri Vikram Singh Yadav

deposited in bank in cash . 3. Lakhvinder singh chawla - Rs. 30,00,0001- . No confirmation filed by appellant, even after no verification in absence of service of notice by A.O, in enquiry proceedings. 4. Rahul Jain - RS. 25,00,000/- . It is observed that, the party has received accommodation entry of Rs. 24,62,623/- from a penny stock company

M/S TJR PROPERTIES PVT. LTD.,CHANDIGARH vs. ACIT, CC-2, CHANDIGARH

In the result, the Appeal is partly allowed

Bench: Shri A.D. Jain & Shri Vikram Singh Yadav

deposits and of Rs. 4,13,000/- remain unexplained." ITA 4/CHD/2023 A.Y. 2015-16 31 17.4 The assessee contends that the company submitted copy of income account along with copy of cash account, bank account statement, profit and loss account and copy of expense account in the books of the company for AY 2015-16 before the CIT(A), which

SATISH KUMAR JAIN,AMBALA vs. INCOME TAX OFFICER WARD -4 AMBALA, AMBALA

The appeal stand partly allowed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.63/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2017-18) & 2. आयकर अपील सं. / Ita No.362/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2017-18) Shri Satish Kumar Jain Ito Ward-4 (Prop. Of M/S Jain Abhushan Bhandar) Ambala, Haryana - 133001 बनाम/ C/O Rajiv Goel & Associates (Ca) Vs. 179 Bank Road, Ambala Cantt. Haryana – 133001 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Acgpk-6011-K (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Dhruv Goel (Ca) – Ld. Ar ""थ"कीओरसे/Respondent By : Sh. Dr. Ranjit Kaur (Addl.Cit) – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 12.02.2026 घोषणाकीतारीख /Date Of Pronouncement 24.02.2026 : आदेश / O R D E R Manoj Kumar Aggarwal () 1. In These Captioned Appeals For Assessment Year (Ay) 2017-18, The Assessee Is Aggrieved By Confirmation Of Quantum Addition As Well As Levy Of Penalty U/S 271Aac For Rs.2,77,868/-. First, We Take Up Quantum Appeal Ita No.63/Chandi/2025 Which Arises Out Of An Order

deposited cash of Rs.55.97 Lacs during demonetization period which is stated to be sourced out of cash balance as available with the assessee in the cash book. The same has been accumulated out of cash sales, receipt from debtors etc. The same has not been accepted by Ld. CIT(A) on the allegation that the assessee manipulated books by inflating

SATISH KUMAR JAIN,SATISH KUMAR JAIN, JAIN ABHUSHAN BHANDAR, AMBALA vs. INCOME TAX OFFICER, WARD-4, AMBALA, INCOME TAX OFFICE, AMBALA

The appeal stand partly allowed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.63/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2017-18) & 2. आयकर अपील सं. / Ita No.362/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2017-18) Shri Satish Kumar Jain Ito Ward-4 (Prop. Of M/S Jain Abhushan Bhandar) Ambala, Haryana - 133001 बनाम/ C/O Rajiv Goel & Associates (Ca) Vs. 179 Bank Road, Ambala Cantt. Haryana – 133001 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Acgpk-6011-K (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Dhruv Goel (Ca) – Ld. Ar ""थ"कीओरसे/Respondent By : Sh. Dr. Ranjit Kaur (Addl.Cit) – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 12.02.2026 घोषणाकीतारीख /Date Of Pronouncement 24.02.2026 : आदेश / O R D E R Manoj Kumar Aggarwal () 1. In These Captioned Appeals For Assessment Year (Ay) 2017-18, The Assessee Is Aggrieved By Confirmation Of Quantum Addition As Well As Levy Of Penalty U/S 271Aac For Rs.2,77,868/-. First, We Take Up Quantum Appeal Ita No.63/Chandi/2025 Which Arises Out Of An Order

deposited cash of Rs.55.97 Lacs during demonetization period which is stated to be sourced out of cash balance as available with the assessee in the cash book. The same has been accumulated out of cash sales, receipt from debtors etc. The same has not been accepted by Ld. CIT(A) on the allegation that the assessee manipulated books by inflating

INDERJEET SINGH PROP. MS GURMUKH TRAVELS 490-A, MODEL TOWN EXTENSION, LUDHIANA,PUNJAB vs. THE INCOME TAX OFFICER WARD 6(1), AAYKAR BHAWAN RISHI NAGAR, LUDHIANA , PUNJAB

In the result, the appeal of the Assessee is allowed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 799/Chd/2023 "नधा"रण वष" / Assessment Year : 2018-19 Inderjeet Singh Prop. Vs. The Ito, Ms. Gurmukh Travels, बनाम Ward 6(1), 490A, Model Town Extension, Aaykar Bhawan, Ludhiana Rishi Nagar, Ludhiana "थायी लेखा सं./Pan No: Ayvps2540L अपीलाथ"/ ""यथ"/ Appellant Repsondent

deposits in the two current accounts in HDFC Bank, represent the sale proceeds of the ticket and complete copy of the cashbook, copies of the bank statements. Reference was also made before the CIT(A) that, whatever, commission was received by the assessee, TDS have been deducted therefrom and the same is reflected in the Form 26AS of the Department

BANSAL RICE TRADERS,SANGRUR vs. ITO-WARD, SANGRUR

In the result, appeal of the assessee is allowed

TDS was deducted for this payment. Further, on perusal of the cash flow statement submitted before the Ld. C/T(A) Patiala, opening balance of cash was shown at Rs. 10, 38, 753/-. To verify the genuineness of the opening balance as shown in the cash statement, Balance Sheet of the previous year was called for. On perusal of previous year

ACIT, CC-2, CHANDIGARH vs. M/S TJR PROPERTIES PVT. LTD., CHANDIGARH

Bench: SHRI A.D.JAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)

cash was given, nature of transaction with them have been furnished, without even going through the written ITA 5 &145/CHD/2023 A.Y. 2017-18 27 submission and documentary evidences submitted by the assessee company during appellate proceedings. The assessee company submitted the completed reply before the ld. CIT(A) in the year 2020, and it took the ld. CIT(A) more