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

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

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

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

TDS liability on behalf of trust and amount of Rs. 4,42,520/- is outstanding against his name as it was paid to him in advance. Further, there is also a reference to various entries such as: Entry standings in the Balance Sheet as white amount: 1) Abhinav Gupta 17250/- 2) Arun Gupta 226056/- 3) Rama Gupta 675322/- 4) Subash

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

TDS liability on behalf of trust and amount of Rs. 4,42,520/- is outstanding against his name as it was paid to him in advance. Further, there is also a reference to various entries such as: Entry standings in the Balance Sheet as white amount: 1) Abhinav Gupta 17250/- 2) Arun Gupta 226056/- 3) Rama Gupta 675322/- 4) Subash

KARNAIL SINGH,UK vs. JCIT (OSD) INTL. TAXATION, CIRCLE, CHANDIGARH

In the result, all the appeals of the assessee stands allowed

153A of the Act and Explanation 3 to Section 271(1)(c) have been invoked. In this regard, it was submitted that there was reasonable cause on the part of the assessee in not filing the return of income. It was submitted that the assessee was an NRI and permanent resident of U.K. and was running textile business in Derby

KARNAIL SINGH,UK vs. JCIT (OSD) INTL. TAXATION, CIRCLE, CHANDIGARH

In the result, all the appeals of the assessee stands allowed

153A of the Act and Explanation 3 to Section 271(1)(c) have been invoked. In this regard, it was submitted that there was reasonable cause on the part of the assessee in not filing the return of income. It was submitted that the assessee was an NRI and permanent resident of U.K. and was running textile business in Derby

KARNAIL SINGH,UK vs. JCIT (OSD) INTL. TAXATION, CIRCLE, CHANDIGARH

In the result, all the appeals of the assessee stands allowed

153A of the Act and Explanation 3 to Section 271(1)(c) have been invoked. In this regard, it was submitted that there was reasonable cause on the part of the assessee in not filing the return of income. It was submitted that the assessee was an NRI and permanent resident of U.K. and was running textile business in Derby

KARNAIL SINGH,UK vs. JCIT (OSD) INTL. TAXATION, CIRCLE, CHANDIGARH

In the result, all the appeals of the assessee stands allowed

153A of the Act and Explanation 3 to Section 271(1)(c) have been invoked. In this regard, it was submitted that there was reasonable cause on the part of the assessee in not filing the return of income. It was submitted that the assessee was an NRI and permanent resident of U.K. and was running textile business in Derby

KARNAIL SINGH,UK vs. JCIT (OSD) INTL. TAXATION, CIRCLE, CHANDIGARH

In the result, all the appeals of the assessee stands allowed

153A of the Act and Explanation 3 to Section 271(1)(c) have been invoked. In this regard, it was submitted that there was reasonable cause on the part of the assessee in not filing the return of income. It was submitted that the assessee was an NRI and permanent resident of U.K. and was running textile business in Derby

KARNAIL SINGH,UK vs. JCIT (OSD) INTL. TAXATION, CIRCLE, CHANDIGARH

In the result, all the appeals of the assessee stands allowed

153A of the Act and Explanation 3 to Section 271(1)(c) have been invoked. In this regard, it was submitted that there was reasonable cause on the part of the assessee in not filing the return of income. It was submitted that the assessee was an NRI and permanent resident of U.K. and was running textile business in Derby

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

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

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)

153A read with Section 143(3) of the Act, originally, vide questionnaire dated 18.02.2015 vide No. DCIT/CC-26/2014- 15/1391 dated 18.02.2015 wherein questions particularly about sub contracts were raised and the relevant reads as under : In continuation of this office questionnaire dated 13.02.2015 you are also requested to furnish the details of expenses claimed by you (above Rs.2 Crores) under head

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

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