DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2,, LUDHIANA vs. AB ALCOBEV PRIVATE LIMITED, DELHI

In the result, appeals of Revenue are dismissed, Cross\nObjections of the assessee for

section 153C in the case of the assessee after duly\nrecording satisfaction that the seized documents belonged to the assessee and represented its\nundisclosed 11 income. In the absence of such compliance, the assessment so framed is without\njurisdiction and liable to be quashed.\n6. The Assessing Officer has relied upon various documents and digital data seized during\nthe search

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2, LUDHIANA , LUDHIANA vs. AB ALCOBEV PRIVATE LIMITED, DELHI

In the result, appeals of Revenue are dismissed, Cross\nObjections of the assessee for

section 153C in the case of the assessee after duly\nrecording satisfaction that the seized documents belonged to the assessee and represented its\nundisclosed 11 income. In the absence of such compliance, the assessment so framed is without\njurisdiction and liable to be quashed.\n6. The Assessing Officer has relied upon various documents and digital data seized during\nthe search

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2, LUDHIANA vs. AB ALCOBEV PRIVATE LIMITED, DELHI

In the result, appeals of Revenue are dismissed, Cross\nObjections of the assessee for

section 153C in the case of the assessee after duly\nrecording satisfaction that the seized documents belonged to the assessee and represented its\nundisclosed 11 income. In the absence of such compliance, the assessment so framed is without\njurisdiction and liable to be quashed.\n6. The Assessing Officer has relied upon various documents and digital data seized during\nthe search

S.P. SINGLA CONSTRUCTION PRIVATE LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CHANDIGARH

In the result, the appeal is allowed

Bench: SHRI MAHAVIR SINGH (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

TDS deducted and credited to the Central Govt. account.” 9.1 The ld. Counsel for the assessee explained that further the AO while completing assessment under Section 153A

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)

153A(1)(b) ITA 3 &144/CHD/2023 A.Y. 2014-15 56 read with Section 143(3) of the Income Tax Act, in the case of Smt. Kiran Singla, for assessment year 2014-15, which were duly explained by the assessee as supporting the stand taken by the assessee on the amount of Rs.3 lacs, have nowhere been rebutted by the taxing

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)

153A(1)(b) ITA 3 &144/CHD/2023 A.Y. 2014-15 56 read with Section 143(3) of the Income Tax Act, in the case of Smt. Kiran Singla, for assessment year 2014-15, which were duly explained by the assessee as supporting the stand taken by the assessee on the amount of Rs.3 lacs, have nowhere been rebutted by the taxing

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)

153A r.w.s. 143(3) of the Act for these years. Hence ground Nos. 2, 3, 4 and 5 are hereby rejected. 25. Concerning Ground No.6, here again the addition was made by the AO without considering each credit separately on merit, while making addition of Rs.3,70,000/-, holding ITA 5 &145/CHD/2023 A.Y. 2017-18 20 that the purpose

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)

153A r.w.s. 143(3) of the Act for these years. Hence ground Nos. 2, 3, 4 and 5 are hereby rejected. 25. Concerning Ground No.6, here again the addition was made by the AO without considering each credit separately on merit, while making addition of Rs.3,70,000/-, holding ITA 5 &145/CHD/2023 A.Y. 2017-18 20 that the purpose

SUBHASH CHANDER GUPTA, H.NO. 16528 VISHNU COLONY, RALIWAY ROAD, KURUKSHETRA,HARYANA vs. JOINT COMMISSIONER OF INCOME TAX, KURUKSHETRA

In the result, both appeals of the assessee are

Bench: Shri Rajpal Yadav & Shri Krinwant Sahay

153A of Searched person, namely Sanjay Bansal, relied upon by the Ld. AO in the present matter. d.) That the CIT(A) has failed to appreciate that while framing the assessment of Sh. Sanjay Bansal (copy of the order filed before the CIT(A), Sh. Sanjay Bansal had never stated that he had paid any amount to the appellate

SUBHASH CHANDER GUPTA, H.NO. 1652 8 VISHNU COLONY, RAILWAY ROAD, KURUKSHETRA,HARYANA vs. ITO WARD-3, KURUKSHETRA, HARYANA

In the result, both appeals of the assessee are

Bench: Shri Rajpal Yadav & Shri Krinwant Sahay

153A of Searched person, namely Sanjay Bansal, relied upon by the Ld. AO in the present matter. d.) That the CIT(A) has failed to appreciate that while framing the assessment of Sh. Sanjay Bansal (copy of the order filed before the CIT(A), Sh. Sanjay Bansal had never stated that he had paid any amount to the appellate

SCOTT EDIL ADVANCE RESEARCH LABORATORIES AND EDUCATION LIMITED,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

153A - Addition towards the cost of construction of the building -\nReference made to ld. DVO u/s 142A - HELD THAT:- Admittedly, no incriminating\nmaterial has been found during the course of search qua this addition towards cost of\nconstruction. This fact is evident from the perusal of the orders of the lower authorities.\n[Refer para 13]\nSole basis

SHRI BALRAM KRISHAN,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH, CHANDIGARH

153A - Addition towards the cost of construction of the building -\nReference made to ld. DVO u/s 142A - HELD THAT:- Admittedly, no incriminating\nmaterial has been found during the course of search qua this addition towards cost of\nconstruction. This fact is evident from the perusal of the orders of the lower authorities. [Refer para 13]\nSole basis of the addition

SHRI BALRAM KRISHAN,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH, CHANDIGARH

153A - Addition towards the cost of construction of the building -\nReference made to ld. DVO u/s 142A - HELD THAT:- Admittedly, no incriminating\nmaterial has been found during the course of search qua this addition towards cost of\nconstruction. This fact is evident from the perusal of the orders of the lower authorities.\n[Refer para 13]\nSole basis

SHRI BALRAM KRISHAN,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH, CHANDIGARH

153A - Addition towards the cost of construction of the building -\nReference made to ld. DVO u/s 142A - HELD THAT:- Admittedly, no incriminating\nmaterial has been found during the course of search qua this addition towards cost of\nconstruction. This fact is evident from the perusal of the orders of the lower authorities.\n[Refer para 13]\nSole basis

SCOTT EDIL PHARMACIA LTD.,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

153A of the Income Tax Act in\nthe absence of any incriminating material found during the search action. He has further\nrelied upon various case laws to contend that the report of the DVO cannot be construed\nas an incriminating material found during the course of search action and further that\naddition cannot be made on account of unexplained investment

SCOTT EDIL ADVANCE RESEARCH LABORATORIES AND EDUCATION LIMITED,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

153A - Addition towards the cost of construction of the building -\nReference made to ld. DVO u/s 142A - HELD THAT:- Admittedly, no incriminating\nmaterial has been found during the course of search qua this addition towards cost of\nconstruction. This fact is evident from the perusal of the orders of the lower authorities.\n[Refer para 13]\nSole basis

SHRI BALRAM KRISHAN,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH, CHANDIGARH

Section 69B of the Act. In absence of any other material on\nrecord, addition was correctly deleted. Tax Appeal is, therefore, dismissed.”\n11. A perusal of the above judgments would indicate that mere valuation report is not\nsufficient to conclude that the assessee has made unexplained investment. From perusal\nof the assessment, nowhere it reveals that inspite of search, Revenue

MAXPORT INDIA PRIVATE LIMITED,CHANDIGARH vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,CHANDIGARH, CHANDIGARH

153A - Addition towards the cost of construction of the building -\nReference made to ld. DVO u/s 142A - HELD THAT:- Admittedly, no incriminating\nmaterial has been found during the course of search qua this addition towards cost of\nconstruction. This fact is evident from the perusal of the orders of the lower authorities. [Refer para 13]\nSole basis of the addition

SCOTT EDIL ADVANCE RESEARCH LABORATORIES AND EDUCATION LIMITED,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

153A - Addition towards the cost of construction of the building -\nReference made to ld. DVO u/s 142A - HELD THAT:- Admittedly, no incriminating\nmaterial has been found during the course of search qua this addition towards cost of\nconstruction. This fact is evident from the perusal of the orders of the lower authorities. [Refer para 13]\nSole basis of the addition