M/S STYLAM INDUSTRIES LTD.,CHANDIGARH vs. DCIT, C-1(1), CHANDIGARH

In the result, the Department’s appeal in for assessment year

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

TDS ignoring the detailed finding of the assessing officer that as per section 5 and section 9 of the Act the income is deemed to accrue or arise in India even if the services by the commission agents have been rendered abroad. Further since the right to receive the commission arises in India, the income of such commission agents

DCIT, C-1(1), CHANDIGARH vs. M/S STYLAM INDUSTRIES LTD., CHANDIGARH

In the result, the Department’s appeal in for assessment year

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

TDS ignoring the detailed finding of the assessing officer that as per section 5 and section 9 of the Act the income is deemed to accrue or arise in India even if the services by the commission agents have been rendered abroad. Further since the right to receive the commission arises in India, the income of such commission agents

DCIT, C-1(1), CHANDIGARH vs. M/S STYLAM INDUSTRIES LTD., CHANDIGARH

In the result, the Department’s appeal in for assessment year

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

TDS ignoring the detailed finding of the assessing officer that as per section 5 and section 9 of the Act the income is deemed to accrue or arise in India even if the services by the commission agents have been rendered abroad. Further since the right to receive the commission arises in India, the income of such commission agents

ACIT, CIRCLE 1(1), CHANDIGARH vs. M/S SML ISUZU LTD., CHANDIGARH

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

250 of the Act, which is hereinafter referred to as the “impugned order”. 2. At the outset the Registry has pointed out that the appeal filed by the Revenue is time barred by 05 days for which Revenue has filed a condonation of delay application. 3. Delay of 05 days is condoned for which Revenue has shown sufficient cause

M/S PUNJAB TOURISM DEVELOPMENET CORPORATION LIMITED,CHANDIGARH vs. DCIT,CIRCLE-1(1), CHANDIGARH

Appeal of the assessee is allowed

Bench: Ao)

section 250 (6) is not a speaking order. 2. That the Hon'ble Commissioner of Income Tax Appeals 1, Chandigarh has erred in upholding the addition of Rs. 35,61,462/ of administrative expenses without correctly appreciating the nature, quantum and reasonableness of the legitimate business expenditure incurred by the State Government undertaking in discharging its statutory and legitimate liabilities

M/S PUNJAB TOURISM DEVELOPMENET CORPORATION LIMITED,CHANDIGARH vs. DCIT,CIRCLE-1(1), CHANDIGARH

Appeal of the assessee is allowed

Bench: Ao)

section 250 (6) is not a speaking order. 2. That the Hon'ble Commissioner of Income Tax Appeals 1, Chandigarh has erred in upholding the addition of Rs. 35,61,462/ of administrative expenses without correctly appreciating the nature, quantum and reasonableness of the legitimate business expenditure incurred by the State Government undertaking in discharging its statutory and legitimate liabilities

M/S PUNJAB TOURISM DEVELOPMENET CORPORATION LIMITED,CHANDIGARH vs. DCIT,CIRCLE-1(1), CHANDIGARH

Appeal of the assessee is allowed

Bench: Ao)

section 250 (6) is not a speaking order. 2. That the Hon'ble Commissioner of Income Tax Appeals 1, Chandigarh has erred in upholding the addition of Rs. 35,61,462/ of administrative expenses without correctly appreciating the nature, quantum and reasonableness of the legitimate business expenditure incurred by the State Government undertaking in discharging its statutory and legitimate liabilities

M/S PUNJAB TOURISM DEVELOPMENET CORPORATION LIMITED,CHANDIGARH vs. DCIT,CIRCLE-1(1), CHANDIGARH

Appeal of the assessee is allowed

Bench: Ao)

section 250 (6) is not a speaking order. 2. That the Hon'ble Commissioner of Income Tax Appeals 1, Chandigarh has erred in upholding the addition of Rs. 35,61,462/ of administrative expenses without correctly appreciating the nature, quantum and reasonableness of the legitimate business expenditure incurred by the State Government undertaking in discharging its statutory and legitimate liabilities

PUNJAB SMALL INDUSTRIES AND EXPORT CORPORATION LTD.,CHANDIGARH vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 2(1), CHANDIGARH, CHANDIGARH

In the result, appeal of the Assessee is partly allowed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. MANOJ KUMAR AGGARWAL (Accountant Member)

250 by the Ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi in Appeal No. ITBA/NFAC/S/250/2023-24/1063489078 (1) is contrary to law and facts of the case. 2. (a) That in the facts and circumstances of the case, ld. Commissioner of Income Tax (Appeals) gravelly erred in upholding the addition

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)

TDS of Rs. 1,50,000/- @1%. Thus, on facts, it is observed that M/s TJR was having income generating apparatus in past and future years and was undertaking business activities. There is no definition of shell company given under the provisions of Income Tax Act, 1961 or Companies Act, 1956/2013. Every case needs to be examined on merits

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)

TDS of Rs. 1,50,000/- @1%. Thus, on facts, it is observed that M/s TJR was having income generating apparatus in past and future years and was undertaking business activities. There is no definition of shell company given under the provisions of Income Tax Act, 1961 or Companies Act, 1956/2013. Every case needs to be examined on merits

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

250 Dev Chaudhary, # 3085 Sector 21 D, Chandigarh 8. Gian Singh Salary Rent Interest Salary Rent Interest Salary Rent Interest Sardana S/o Sh. 14,40,00 0 2,05,459 18,80,00 0 2,191 24,16,00 0 5,000 J.R. Sardana, Manav Mangal High School, Sector 21 C, Chandigarh Particulars

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

250 Dev Chaudhary, # 3085 Sector 21 D, Chandigarh 8. Gian Singh Salary Rent Interest Salary Rent Interest Salary Rent Interest Sardana S/o Sh. 14,40,00 0 2,05,459 18,80,00 0 2,191 24,16,00 0 5,000 J.R. Sardana, Manav Mangal High School, Sector 21 C, Chandigarh Particulars

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

250 Dev Chaudhary, # 3085 Sector 21 D, Chandigarh 8. Gian Singh Salary Rent Interest Salary Rent Interest Salary Rent Interest Sardana S/o Sh. 14,40,00 0 2,05,459 18,80,00 0 2,191 24,16,00 0 5,000 J.R. Sardana, Manav Mangal High School, Sector 21 C, Chandigarh Particulars

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

250 Dev Chaudhary, # 3085 Sector 21 D, Chandigarh 8. Gian Singh Salary Rent Interest Salary Rent Interest Salary Rent Interest Sardana S/o Sh. 14,40,00 0 2,05,459 18,80,00 0 2,191 24,16,00 0 5,000 J.R. Sardana, Manav Mangal High School, Sector 21 C, Chandigarh Particulars

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

250 Dev Chaudhary, # 3085 Sector 21 D, Chandigarh 8. Gian Singh Salary Rent Interest Salary Rent Interest Salary Rent Interest Sardana S/o Sh. 14,40,00 0 2,05,459 18,80,00 0 2,191 24,16,00 0 5,000 J.R. Sardana, Manav Mangal High School, Sector 21 C, Chandigarh Particulars

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

250 Dev Chaudhary, # 3085 Sector 21 D, Chandigarh 8. Gian Singh Salary Rent Interest Salary Rent Interest Salary Rent Interest Sardana S/o Sh. 14,40,00 0 2,05,459 18,80,00 0 2,191 24,16,00 0 5,000 J.R. Sardana, Manav Mangal High School, Sector 21 C, Chandigarh Particulars

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

250 Dev Chaudhary, # 3085 Sector 21 D, Chandigarh 8. Gian Singh Salary Rent Interest Salary Rent Interest Salary Rent Interest Sardana S/o Sh. 14,40,00 0 2,05,459 18,80,00 0 2,191 24,16,00 0 5,000 J.R. Sardana, Manav Mangal High School, Sector 21 C, Chandigarh Particulars

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

250 Dev Chaudhary, # 3085 Sector 21 D, Chandigarh 8. Gian Singh Salary Rent Interest Salary Rent Interest Salary Rent Interest Sardana S/o Sh. 14,40,00 0 2,05,459 18,80,00 0 2,191 24,16,00 0 5,000 J.R. Sardana, Manav Mangal High School, Sector 21 C, Chandigarh Particulars