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)

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 out of vehicle of the company. The copy of account of hire charges, which had been furnished before both the taxing authorities, stands filed before us also. It formed part of the books of account

ASTT. COMMISSIONER OF INCOME TAX, CIRCLE-4, LUDHIANA, AAYAKAR BHAWAN vs. WARYAM STEEL CASTING PRIVATE LIMITED, KANGANWAL ROAD

In the result, appeal of the assessee is allowed and the Cross appeal of the Revenue is dismissed

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

133(6)) or non-existence at a particular address all factors over which the Appellant Company does not have any control, whereby the said failures/irregularities/inconsistencies cannot be festooned to enlarge the onus cast on it and resultantly latch it with some kind of far- reaching adverse conclusions with potentially serious ramifications. (12) Further, the attempt to link increase in sales

WARYAM STEEL CASTINGS PRIVATE LIMITED,LUDHIANA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-4, LUDHIANA

In the result, appeal of the assessee is allowed and the Cross appeal of the Revenue is dismissed

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

133(6)) or non-existence at a particular address all factors over which the Appellant Company does not have any control, whereby the said failures/irregularities/inconsistencies cannot be festooned to enlarge the onus cast on it and resultantly latch it with some kind of far- reaching adverse conclusions with potentially serious ramifications. (12) Further, the attempt to link increase in sales

ITO (TDS), PATIALA vs. M/S S.A. SINGH & CO., BHAWANIGARH

In the result, the appeal of the Revenue is dismissed

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

TDS @ 2% under Section 194C of the Act. 3.1 Thereafter, the proceedings under section 201(1) of the Act were initiated. During the course of proceedings, information was sought under section 133(6

M/S VENKATESH TECHNOKRAFT PVT. LTD.,LUDHIANA vs. ITO, W-1(5), LUDHIANA

Bench: Him Which Is Arbitrary & Unjustified. 3. That The Assessment Order Having Been Passed By The Assessing Officer After Due Application Of Mind & Taking Into Consideration The Various Replies, Material On Record & Books Of Account, The Action Resorted To By The Commissioner Of Income Tax Is Unwarranted & Uncalled For.

133(6) of the Act to six companies. In those replies, it was stated that their Directors came into contact with Shri Lokesh Kumar, Director of the assessee company somewhere in the beginning of financial year 2013-14 and Mr. Lokesh Kumar expressed his willingness to sell equity shares of the assessee company, since he was in need of long

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), CHANDIGARH, CHANDIGARH vs. UNIPRO TECHNO INFRASTRUCTURE PVT LTD, CHANDIGARH

In the result, the order of the ld CIT(A) is confirmed and the grounds of appeal taken by the Revenue are dismissed

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

133(6) is on record. Perusal of the same shows that the assessee was awarded the complete project contract on BOT basis and no other agency was involved in the same. The Id. Counsel has also cited CBDT Circular No. 10/2005 dt. 16.12.2005 which though specific to ports interprets Section 80IA as being applicable to projects/ structures built under

M/S DIN DAYAL PURSOTAM LAL,SIRSA vs. PR.CIT, ROHTAK

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

133(6) of the Act. It was observed that the AO had failed to make any enquiry to establish his suspicion that the purchases were bogus, whereas the assessee had produced on record documentary evidence to establish the genuineness of the purchase transactions; that the AO had brushed aside these evidences, which could not be accepted; that

M/S DIN DAYAL PURSOTAM LAL,SIRSA vs. PR.CIT, ROHTAK

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

133(6) of the Act. It was observed that the AO had failed to make any enquiry to establish his suspicion that the purchases were bogus, whereas the assessee had produced on record documentary evidence to establish the genuineness of the purchase transactions; that the AO had brushed aside these evidences, which could not be accepted; that

M/S DIN DAYAL PURSOTAM LAL,SIRSA vs. PR.CIT, ROHTAK

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

133(6) of the Act. It was observed that the AO had failed to make any enquiry to establish his suspicion that the purchases were bogus, whereas the assessee had produced on record documentary evidence to establish the genuineness of the purchase transactions; that the AO had brushed aside these evidences, which could not be accepted; that

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

Sections 133(6) or 131 of the Act for further investigation. However, it is noteworthy that neither the AO nor the CIT(A) extended any such notice to the lender / creditor for additional inquiries. Instead, an addition of Rs. 79,50,000/- was made based on the directive of a third party. 16.14 Moreover, if only the assessee

STATE BANK OF INDIA LOCAL HEAD OFFICE CHANDIGARH,CHANDIGARH vs. ADDL COMMISSIONER OF INCOME TAX(TDS) CHANDIGARH, CHANDIGARH

In the result, appeal filed by the Assessee is dismissed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

TDS verification proceedings and issued notice under section 133(6) seeking details of Leave Travel Concession/Leave Fare Concession (LTC/LFC) payments

INCOME TAX OFFICER, WARD-1(3), LUDHIANA, LUDHIANA vs. SHREE BALAJI PROCESSORS, LUDHIANA

In the result, appeal of the Revenue is dismissed whereas, the 29

Bench: Shri A.D. Jain & Dr Krinwant Sahayआयकर अपील सं./ Ita No. 499/Chd/2023 "नधा"रण वष" / Assessment Year : 2017-18 The Ito, Vs. Shree Balaji Processors, बनाम Ward-1(3), Tajpur Road, Ludhiana Opp. Central Jail, Ludhiana 141010 "थायी लेखा सं./Pan No: Actfs8428B अपीलाथ"/ Appellant ""यथ"/ Repsondent & C.O. No. 09/Chd/2024 ( In आयकर अपील सं./ Ita No. 499/Chd/2023) "नधा"रण वष" / Assessment Year : 2017-18 Shree Balaji Processors, Vs. The Ito, बनाम Tajpur Road, Ward-1(3), Opp. Central Jail, Ludhiana Ludhiana 141010 "थायी लेखा सं./Pan No: Actfs8428B अपीलाथ"/ Appellant ""यथ"/ Repsondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : Shri Sudhir Sehgal, Advocate राज"व क" ओर से/ Revenue By : Smt. Kusum Bansal, Cit Dr सुनवाई क" तार"ख/Date Of Hearing : 26.06.2024 उदघोषणा क" तार"ख/Date Of Pronouncement : 20.08.2024

133 TTJ 167 of Delhi Bench of the ITAT and Continental Carbon (India) Ltd. in ITA No. 526905270/Del/2010, ITAT, Delhi Bench. 6. It was also argued that the case of the assessee regarding the deposit of cash is duly covered by the Judgement of Jurisdictional Bench of the ITAT Chandigarh Bench in the case of 'Charu Aggarwal and Others' reported

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)

133(6) had been called for from the bank and placed on record. On perusal of the bank account, it was revealed that the assessee had deposited cash of Rs. 21 lakh in the bank account during the year. The assessee was show caused to explain the source of the cash deposit alongwith documentary evidence on specified dates. In response

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)

Sections 133(6) or 131 of the Act for further investigation. However, it is noteworthy that neither the AO nor the CIT(A) extended any such notice to the lender for additional inquiries. Instead, an addition of Rs. 3,70,000/- was made based on the directive of a third party. Neither enquiry was made by CIT(A) / AO before

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)

Sections 133(6) or 131 of the Act for further investigation. However, it is noteworthy that neither the AO nor the CIT(A) extended any such notice to the lender for additional inquiries. Instead, an addition of Rs. 3,70,000/- was made based on the directive of a third party. Neither enquiry was made by CIT(A) / AO before

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

Sections 133(6) or 131 of the Act for further investigation. However, it is noteworthy that neither the AO nor the CIT(A) extended any such notice to the lender for additional inquiries. Instead, an addition of Rs. 4,50,000/- was made based on the directive of a third party. 22.3 The documents are submitted by the company

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

In the result, appeal of the assessee is allowed

133(6) of the Income Tax Act, 1961, to the Punjab Agro Grain Corporation, Sangrur and the Punjab Agro has verified that the only one amount of Rs.78466/- was credited in the account of appellant firm and Rs. 1569/- TDS was deducted for this payment. The same may kindly be accepted. The reliance was placed on the following case laws

CEIGALL INDIA LIMITED, LUDHIANA,LUDHIANA vs. PRINCIPAL COMMISSIONER OF INCOME TAX, LUDHIANA, LUDHIANA

In the result, the appeal of the assessee stands allowed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

TDS was deducted; no discrepancy was shown. f. On capital gains, AO adopted a legally tenable view consistent with section 50. 8 g. On fixed asset additions, the issue was never part of scrutiny; PCIT travelled beyond his jurisdiction. 5.1. The Ld. PCIT in the order in para 5.2 had mentioned with respect to other expensesmentioned as under: Further, during