THE H.P.STATE CO-OPERATIVE BANK LTD.,SIRMOUR vs. ITO(TDS), SOLAN

In the result, all the above appeals filed by the Assessee are\nallowed

194 A(3)(v).\n* Non deduction of TDS on interest paid by the assessee co-operative\nbank to Government run temple.\n5.3 It is contended before us that additionsare made by invoking\nsection 194A(3)(i)(b) and 194A(3)(viia)(b) and denying the provisions of\nSection 194A(3)(v). The Ld. CIT(A) in para 5.1.2 (page

THE H.P.STATE CO-OPERATIVE BANK LTD.,SIRMOUR vs. ITO(TDS), SOLAN

In the result, all the above appeals filed by the Assessee are\r\nallowed

194 A(3)(v).\r\n* Non deduction of TDS on interest paid by the assessee co-operative\r\nbank to Government run temple.\r\n5.3 It is contended before us that additionsare made by invoking\r\nsection 194A(3)(i)(b) and 194A(3)(viia)(b) and denying the provisions of\r\nSection 194A(3

EXOTIC REALTORS AND DEVELOPERS,CHANDIGARH vs. PR.CIT-1, CHANDIGARH

In the result, appeal of the assessee is allowed

Bench: SHRI. KRINWANT SAHAY (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

3) and another under section 147/148 r.w.s 144 read with section 144B of the Income Tax Act. In addition to this the assessee firm has gone through further rigours of proceedings under section 263. The Ld. AR further contended that in prior A.Y 2017-18 the assessee’s firm was scrutinized too by same officer and nothing adversial was found

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

section 13(1)(c) is to judge the reasonableness of the payments made to the members of the society and secondly and more importantly, there is no finding of the AO that the society is not working towards the objects of education etc. as defined in its Memorandum and Rules and Regulations. No case of siphoning off of the funds

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

section 13(1)(c) is to judge the reasonableness of the payments made to the members of the society and secondly and more importantly, there is no finding of the AO that the society is not working towards the objects of education etc. as defined in its Memorandum and Rules and Regulations. No case of siphoning off of the funds

M/S MANAV MANGAL SOCIETY,CHANDIGARH vs. DCIT, C-1, (E), CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

section 13(1)(c) is to judge the reasonableness of the payments made to the members of the society and secondly and more importantly, there is no finding of the AO that the society is not working towards the objects of education etc. as defined in its Memorandum and Rules and Regulations. No case of siphoning off of the funds

DCIT,CIRCLE-1(EXEMPTION), CHANDIGARH vs. M/S MANAV MANGAL SCHOOL( MANAV MANGAL SOCIETY), CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

section 13(1)(c) is to judge the reasonableness of the payments made to the members of the society and secondly and more importantly, there is no finding of the AO that the society is not working towards the objects of education etc. as defined in its Memorandum and Rules and Regulations. No case of siphoning off of the funds

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

section 13(1)(c) is to judge the reasonableness of the payments made to the members of the society and secondly and more importantly, there is no finding of the AO that the society is not working towards the objects of education etc. as defined in its Memorandum and Rules and Regulations. No case of siphoning off of the funds

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

section 13(1)(c) is to judge the reasonableness of the payments made to the members of the society and secondly and more importantly, there is no finding of the AO that the society is not working towards the objects of education etc. as defined in its Memorandum and Rules and Regulations. No case of siphoning off of the funds

M/S MANAV MANGAL SOCIETY,CHANDIGARH vs. DCIT, C-1, (E), CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

section 13(1)(c) is to judge the reasonableness of the payments made to the members of the society and secondly and more importantly, there is no finding of the AO that the society is not working towards the objects of education etc. as defined in its Memorandum and Rules and Regulations. No case of siphoning off of the funds

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

section 13(1)(c) is to judge the reasonableness of the payments made to the members of the society and secondly and more importantly, there is no finding of the AO that the society is not working towards the objects of education etc. as defined in its Memorandum and Rules and Regulations. No case of siphoning off of the funds

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

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

194 (S.C.). Besides, the following decisions are also to the same effect : i) ITA No. 3205/Del/2017 M/s Amira Pure Foods (P) Ltd. v. PCIT ii) ITA No. 574/Del/2018 dated 19.06.2018 M/s Vidya Prakashan Mandir (P) Ltd. vs PrCIT iii) ITA no. 2539/Del/2018 dated 29.08.2018 Durgesh Autofin P Ltd. Vs Pr. CIT ITA 146,147 & 148/CHD/2021

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

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

194 (S.C.). Besides, the following decisions are also to the same effect : i) ITA No. 3205/Del/2017 M/s Amira Pure Foods (P) Ltd. v. PCIT ii) ITA No. 574/Del/2018 dated 19.06.2018 M/s Vidya Prakashan Mandir (P) Ltd. vs PrCIT iii) ITA no. 2539/Del/2018 dated 29.08.2018 Durgesh Autofin P Ltd. Vs Pr. CIT ITA 146,147 & 148/CHD/2021

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

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

194 (S.C.). Besides, the following decisions are also to the same effect : i) ITA No. 3205/Del/2017 M/s Amira Pure Foods (P) Ltd. v. PCIT ii) ITA No. 574/Del/2018 dated 19.06.2018 M/s Vidya Prakashan Mandir (P) Ltd. vs PrCIT iii) ITA no. 2539/Del/2018 dated 29.08.2018 Durgesh Autofin P Ltd. Vs Pr. CIT ITA 146,147 & 148/CHD/2021

SIMMI GUPTA,CHANDIGARH vs. DCIT/ACIT TDS, CHANDIGARH

In the result, appeal of the assessee is allowed

Bench: Shri Laliet Kumar & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 212/Chd/2025 "नधा"रण वष" / Assessment Year: 2017-18 Simmi Gupta, The Dcit/Acit (Tds), 1076, Sector 37-B, Vs Chandigarh. Chandigarh. "थायी लेखा सं./Pan No: Afwpg4983R अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Parikshit Aggarwal, Ca Revenue By : Dr. Ranjit Kaur, Addl. Cit, Sr.Dr Date Of Hearing : 10.12.2025 Date Of Pronouncement : 22.12.2025

3). The provisions of section 203A shall not apply to a person required to deduct tax in accordance with the provisions of this Section." Explanation — For the purposes of this section,— (a) "agricultural land" means agricultural land in India, not being a land situated in any area referred to in items (a) and (b) of sub-clause (iii) of clause

JANTA LAND PROMOTERS PVT LTD,MOHALI vs. THE PRINICIPAL COMMISSIONER OF INCOME TAX ,CHANDIGARH-1, CHANDIGARH

In the result, appeal of the Assessee is allowed

section 263 of the Income Tax Act 1961,extracted by the PCIT identified five heads: (i) Provision for development expenses of Rs.100 crore; ii) Oxford Street Project, Zirakpur – investment of Rs.26.50 crore and TDS u/s 194-IA; (iii) Advances from customers Rs.64,285.60 lakh and Advance against property Rs.7,607.14 lakh; (iv) Rs.921.39 lakh “previous year taxes” appearing in Reserves

DCIT, C-1 (EXEMPTIONS), CHANDIGARH vs. CT EDUCATIONAL SOCIETY, JALANDHAR

In the result, both the appeals of the Revenue are

3) The provisions of section 203A shall not apply to a person required to dedut in accordance with the provisions of this section. Explanation.— For the purposes of this section,— (a) "agricultural land" means agricultural land in India, not being a land situate i area referred to in items (a) and (b) of sub-clause (iii) of clause

DCIT, C-1 (EXEMPTIONS), CHANDIGARH vs. CT EDUCATIONAL SOCIETY, JALANDHAR

In the result, both the appeals of the Revenue are

3) The provisions of section 203A shall not apply to a person required to dedut in accordance with the provisions of this section. Explanation.— For the purposes of this section,— (a) "agricultural land" means agricultural land in India, not being a land situate i area referred to in items (a) and (b) of sub-clause (iii) of clause