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

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

TDS deducted by M/s Omaxe Ltd. @ 15% as per Article-12 of India and U.K DTAA r/w Section 90 of the Act. 3.1 As per the AO, the income received by the assessee from M/s Omaxe Ltd. cannot be stated to be income from house property as there is no construction/ complete property and the question of letting

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

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

TDS deducted by M/s Omaxe Ltd. @ 15% as per Article-12 of India and U.K DTAA r/w Section 90 of the Act. 3.1 As per the AO, the income received by the assessee from M/s Omaxe Ltd. cannot be stated to be income from house property as there is no construction/ complete property and the question of letting

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

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

TDS deducted by M/s Omaxe Ltd. @ 15% as per Article-12 of India and U.K DTAA r/w Section 90 of the Act. 3.1 As per the AO, the income received by the assessee from M/s Omaxe Ltd. cannot be stated to be income from house property as there is no construction/ complete property and the question of letting

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

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

TDS deducted by M/s Omaxe Ltd. @ 15% as per Article-12 of India and U.K DTAA r/w Section 90 of the Act. 3.1 As per the AO, the income received by the assessee from M/s Omaxe Ltd. cannot be stated to be income from house property as there is no construction/ complete property and the question of letting

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

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

TDS deducted by M/s Omaxe Ltd. @ 15% as per Article-12 of India and U.K DTAA r/w Section 90 of the Act. 3.1 As per the AO, the income received by the assessee from M/s Omaxe Ltd. cannot be stated to be income from house property as there is no construction/ complete property and the question of letting

M/S PUNJAB NATIONAL BANK,HAMIRPUR vs. JT.CIT(OSD), TDS CIRCLE, PANCHKULA

In the result, both the above appeals of the Assessee are set-aside to the file of the ld CIT(A) and the same are allowed for statistical purposes

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

TDS on interest on FDRs on deposits beyond the threshold limit of Rs. 10,000/- as so prescribed under Section 194A of the Act and accordingly the assessee was held to be assessee in default under section 201 resulting in passing of the order under section 201 r.w.s. 201(1A) dt. 31/03/2018 raising the demand of tax and interest amounting

M/S PUNJAB NATIONAL BANK,HAMIRPUR vs. JT.CIT(OSD), TDS CIRCLE, PANCHKULA

In the result, both the above appeals of the Assessee are set-aside to the file of the ld CIT(A) and the same are allowed for statistical purposes

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

TDS on interest on FDRs on deposits beyond the threshold limit of Rs. 10,000/- as so prescribed under Section 194A of the Act and accordingly the assessee was held to be assessee in default under section 201 resulting in passing of the order under section 201 r.w.s. 201(1A) dt. 31/03/2018 raising the demand of tax and interest amounting

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 and proof of depositing the same was enclosed at assessee's Paper Book pages 1638- 1776. The ld. Counsel for the assessee stated that there are so many sub contractors and as per the alleged documents found from the premises of the Chartered Accountant Shri Gurinder Kumar Garg, the total parties are more than 150 which include the alleged

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)

TDS deducted, date of bills, details of cheques issued, etc., in such a case, he could not be held responsible for parties not appearing in person and, thus, impugned addition made under section 69C deserved to be deleted. Principal Commissioner of Income-tax, Mumbai v. Chawla Interbild Construction Co. (P.) Ltd [2019] 104 taxmann.com 402 (Bombay) (vii) Where sales supported

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)

TDS deducted, date of bills, details of cheques issued, etc., in such a case, he could not be held responsible for parties not appearing in person and, thus, impugned addition made under section 69C deserved to be deleted. Principal Commissioner of Income-tax, Mumbai v. Chawla Interbild Construction Co. (P.) Ltd [2019] 104 taxmann.com 402 (Bombay) (vii) Where sales supported

M/S SEL MANUFACTURING CO. LTD.,LUDHIANA vs. DCIT, CC-3, LUDHIANA

In the result, appeal is allowed

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

274, G.T. Road, Dhandari Khurd, Central Circle-3, Ludhiana. Ludhiana. "थायी लेखा सं./PAN /TAN No: AAHCS9189E अपीलाथ"/Appellant ""यथ"/Respondent "नधा"रती क" ओर से/Assessee by : Shri Ashwani Kumar, CA राज"व क" ओर से/ Revenue by : Smt. Kusum Bansal, CIT DR तार"ख/Date of Hearing : 16.04.2024 उदघोषणा क" तार"ख/Date of Pronouncement : 27.05.2024 HYBRID HEARAING

SANJEEV AGGARWAL,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1 , CHANDIGARH

section 158BD calling upon assessee to file return of undisclosed income\nfor block period 1-4-1989 to 28-1-2000 - Thereafter, valuation of cost of construction of\nbuildings constructed by assessee-firm was referred to DVO, for valuation under section\n133(6) - Assessing Officer added difference in valuation of cost of construction adopted\nby assessee-firm

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

section 158BD calling upon assessee to file return of undisclosed income\nfor block period 1-4-1989 to 28-1-2000 - Thereafter, valuation of cost of construction of\nbuildings constructed by assessee-firm was referred to DVO, for valuation under section\n133(6) - Assessing Officer added difference in valuation of cost of construction adopted\nby assessee-firm

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

section 158BD calling upon assessee to file return of undisclosed income\nfor block period 1-4-1989 to 28-1-2000 - Thereafter, valuation of cost of construction of\nbuildings constructed by assessee-firm was referred to DVO, for valuation under section\n133(6) - Assessing Officer added difference in valuation of cost of construction adopted\nby assessee-firm

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

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

section 80IC of the Act. Subject to above observations, this\nissue is decided in favour of the revenue.\nIssue 9 : Credits received from JAAPL and Disallowance u/s 80IC - GP earned on sale made\nto JAPPL on account of alleged bogus nature of sales to JAPPL.\n98. Following is the list of cases involving this issue :-\nSr.\nNo\n.\nName

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

section 158BD calling upon assessee to file return of undisclosed income\nfor block period 1-4-1989 to 28-1-2000 - Thereafter, valuation of cost of construction of\nbuildings constructed by assessee-firm was referred to DVO, for valuation under section\n133(6) - Assessing Officer added difference in valuation of cost of construction adopted\nby assessee-firm