M/S GOLD STAR AMCO STEELS PVT. LTD.,LUDHIANA vs. DCIT, C-1, LUDHIANA

In the results, the book results as duly audited need to be accepted and the addition so made is hereby directed to be deleted

Bench: 30Th Of September 2013 And, As Such, Framing Of Assessment By The Assessing Officer Without Observing Mandatory

section 68 and in view of the same, both the additions so made by the AO are hereby directed to be deleted. 8.14 In the result, the ground no. 3 of the assessee’s appeal is allowed and ground no. 1 of the Revenue’s appeal is dismissed. 9. In Ground No. 4, the assessee had challenged the sustenance

DCIT, C-1, LUDHIANA vs. M/S GOLD STAR AMCO STEELS PVT. LTD., LUDHIANA

In the results, the book results as duly audited need to be accepted and the addition so made is hereby directed to be deleted

Bench: 30Th Of September 2013 And, As Such, Framing Of Assessment By The Assessing Officer Without Observing Mandatory

section 68 and in view of the same, both the additions so made by the AO are hereby directed to be deleted. 8.14 In the result, the ground no. 3 of the assessee’s appeal is allowed and ground no. 1 of the Revenue’s appeal is dismissed. 9. In Ground No. 4, the assessee had challenged the sustenance

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

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)

section 68 were, satisfied and hence the CIT(A) granted relief of Rs. 2,77,01,650/- to the assessee company. 41. Further, the CIT(A) in his order has mentioned that : ITA 5 &145/CHD/2023 A.Y. 2017-18 41 "It was further explained that the AO has used statement of Sh. Jagdish Rai Gupta selectively in parts by drawing wrong

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)

section 68 were, satisfied and hence the CIT(A) granted relief of Rs. 2,77,01,650/- to the assessee company. 41. Further, the CIT(A) in his order has mentioned that : ITA 5 &145/CHD/2023 A.Y. 2017-18 41 "It was further explained that the AO has used statement of Sh. Jagdish Rai Gupta selectively in parts by drawing wrong

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)

Section 68 of the Income Tax Act, has been brought to challenge. Here, undisputedly, the assessee company submitted the Cash Flow Statements, explanation of each debit and credit entry in the bank account of the assessee company and also filed the balance sheet, affidavit, confirmations, bank statement, ITA 3 &144/CHD/2023 A.Y. 2014-15 60 ITRs, balance sheets and copies

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)

Section 68 of the Income Tax Act, has been brought to challenge. Here, undisputedly, the assessee company submitted the Cash Flow Statements, explanation of each debit and credit entry in the bank account of the assessee company and also filed the balance sheet, affidavit, confirmations, bank statement, ITA 3 &144/CHD/2023 A.Y. 2014-15 60 ITRs, balance sheets and copies

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)

TDS matter, excise assessment, VAT assessment and also with regard to notices issued by the relevant Government Authority for relevant assessment years under various provisions of the Applicable Law including Income Tax Act or indirect tax laws, the relevant Government A.Y. 2011-12 14 Authorities make any further assessment with respect to resolution of losses or unabsorbed depreciation or raise

INCOME TAX OFFICER WARD 6 (1), MOHALI vs. SKYCITY BUILDERS AND PROMOTERS PRIVATE LIMITED, KHRAR PUNJAB

In the result, the corresponding grounds as raised by the revenue stand dismissed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No.1066/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2012-13) M/S Skycity Builders & Promoters Pvt. Ltd. Dcit Ward 6(1) बनाम/ Room No.3, 1St Floor Sco-90, City Heart Kharar-Chandigarh Road, Livestock Complex Vs. Kharar, Rupnagar (Punjab) - 140301 Sector – 68, Mohali -160062 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aapcs-2435-R (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकर अपील सं./ Ita No.1217/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2012-13) Dcit Ward 6(1) M/S Skycity Builders & Promoters Pvt. Ltd. बनाम/ Room No.3, 1St Floor Sco-90, City Heart Livestock Complex Kharar-Chandigarh Road, Vs. Sector – 68, Mohali -160062 Kharar, Rupnagar (Punjab) - 140301 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aapcs-2435-R (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Sudhir Sehgal (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Ms. Yamini (Cit) - Ld. Dr (Virtual) सुनवाईकीतारीख/Date Of Hearing : 05.02.2026 घोषणाकीतारीख /Date Of Pronouncement : 16.03.2026

section 68, without the assessee demonstrating actual financial capacity of lenders and genuineness of transactions? 3. Whether the CIT(A) erred in deleting the addition by not appreciating that the bank statements of creditors revealed heavy cash deposits immediately prior to advancing loans and that many creditors operated through cash credit accounts which turned into NPAs, thereby establishing that

SKYCITY BUILDERS AND PROMOTERS PRIVATE LIMITED, ,KHARAR, RUPNAGAR vs. DCIT WARD 6(1), CHANDIGARH JAO ITO 6(1) MOHALI, CHANDIGARH

In the result, the corresponding grounds as raised by the revenue stand dismissed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No.1066/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2012-13) M/S Skycity Builders & Promoters Pvt. Ltd. Dcit Ward 6(1) बनाम/ Room No.3, 1St Floor Sco-90, City Heart Kharar-Chandigarh Road, Livestock Complex Vs. Kharar, Rupnagar (Punjab) - 140301 Sector – 68, Mohali -160062 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aapcs-2435-R (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकर अपील सं./ Ita No.1217/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2012-13) Dcit Ward 6(1) M/S Skycity Builders & Promoters Pvt. Ltd. बनाम/ Room No.3, 1St Floor Sco-90, City Heart Livestock Complex Kharar-Chandigarh Road, Vs. Sector – 68, Mohali -160062 Kharar, Rupnagar (Punjab) - 140301 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aapcs-2435-R (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Sudhir Sehgal (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Ms. Yamini (Cit) - Ld. Dr (Virtual) सुनवाईकीतारीख/Date Of Hearing : 05.02.2026 घोषणाकीतारीख /Date Of Pronouncement : 16.03.2026

section 68, without the assessee demonstrating actual financial capacity of lenders and genuineness of transactions? 3. Whether the CIT(A) erred in deleting the addition by not appreciating that the bank statements of creditors revealed heavy cash deposits immediately prior to advancing loans and that many creditors operated through cash credit accounts which turned into NPAs, thereby establishing that

SH. BALJIT SINGH,LUDHIANA vs. PR. CIT, LUDHIANA -1, LUDHIANA

In the result, appeal of the Assessee is dismissed

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

68 with regard to unsecured loans and payment of interest thereon as a consequence thereof expenditure of Rs. 1,32,97,887/- has remained unexplained. The other issue dealt by him in para 4 & 5(supra) of the impugned order stands dealt with in fresh assessment order dt. 27/03/2023-i.e; the consequential order passed in pursuance to order under section

PAWAN KUMAR,AMBALA, HARYANA vs. INCOME TAX OFFICER WARD-3 AMBALA, AMBALA CANTT

In the result, the appeal is allowed

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

TDS, Labour is reconciled with sales tax and market fees. Assessee has only commission income which is cross verified with GST Records, DFSC Records, 26AS and there is no other source of income. Addition made is wrong and against the facts of the case may kindly be deleted. Addition made under section 68

ACIT, LUDHIANA vs. M/S K LAL OVERSEAS PVT. LTD., LUDHIANA

The appeal of the assessee is hereby allowed whereas the appeal of the Revenue is dismissed

Bench: Shri Sanjay Garg & Shri Vikram Singh Yadav

section 68 and it is the primary onus of assessee only to prove the identity, genuineness and creditworthiness.” ITA No. 165 &174-Chd-2020 A.Y. 2012-13 Page 18 of 29 10. Being aggrieved by the above additions confirmed by the CIT(A), the assessee has come in appeal before us. 11. We have considered the rival submissions and have

M/S K.LALL OVERSEAS,LUDHIANA vs. ACIT,CIRCLE-6, LUDHIANA

The appeal of the assessee is hereby allowed whereas the appeal of the Revenue is dismissed

Bench: Shri Sanjay Garg & Shri Vikram Singh Yadav

section 68 and it is the primary onus of assessee only to prove the identity, genuineness and creditworthiness.” ITA No. 165 &174-Chd-2020 A.Y. 2012-13 Page 18 of 29 10. Being aggrieved by the above additions confirmed by the CIT(A), the assessee has come in appeal before us. 11. We have considered the rival submissions and have

INCOME TAX OFFICER, WARD-1(3), LUDHIANA, LUDHIANA vs. SHREE BALAJI PROCESSORS, LUDHIANA

In the result, appeal of the Revenue is dismissed whereas, the 29

Bench: Shri A.D. Jain & Dr Krinwant Sahayआयकर अपील सं./ Ita No. 499/Chd/2023 "नधा"रण वष" / Assessment Year : 2017-18 The Ito, Vs. Shree Balaji Processors, बनाम Ward-1(3), Tajpur Road, Ludhiana Opp. Central Jail, Ludhiana 141010 "थायी लेखा सं./Pan No: Actfs8428B अपीलाथ"/ Appellant ""यथ"/ Repsondent & C.O. No. 09/Chd/2024 ( In आयकर अपील सं./ Ita No. 499/Chd/2023) "नधा"रण वष" / Assessment Year : 2017-18 Shree Balaji Processors, Vs. The Ito, बनाम Tajpur Road, Ward-1(3), Opp. Central Jail, Ludhiana Ludhiana 141010 "थायी लेखा सं./Pan No: Actfs8428B अपीलाथ"/ Appellant ""यथ"/ Repsondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : Shri Sudhir Sehgal, Advocate राज"व क" ओर से/ Revenue By : Smt. Kusum Bansal, Cit Dr सुनवाई क" तार"ख/Date Of Hearing : 26.06.2024 उदघोषणा क" तार"ख/Date Of Pronouncement : 20.08.2024

section 68/69 of the act is prohibited, as the same shall amount to double taxation. Reliance is being placed on the following judgment of Hon'ble Gujarat High Court in the case of President Industries reported in 258 ITR 654, wherein, it was held as under:- "The amount of sales by itself cannot represent the income of the assessee

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

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

68 ITD 65 CHD, and viii) Rupesh Chiman Lal V ITO, order dated 30.01.2017 in ITA Nos. 6179-6182/Mum/2016 13.5 Then, it is well settled that the assessee cannot be expected to be after the person with whom he has entered in the business transactions and the assessee's onus is to establish the identity of the party

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

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

68 ITD 65 CHD, and viii) Rupesh Chiman Lal V ITO, order dated 30.01.2017 in ITA Nos. 6179-6182/Mum/2016 13.5 Then, it is well settled that the assessee cannot be expected to be after the person with whom he has entered in the business transactions and the assessee's onus is to establish the identity of the party

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

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

68 ITD 65 CHD, and viii) Rupesh Chiman Lal V ITO, order dated 30.01.2017 in ITA Nos. 6179-6182/Mum/2016 13.5 Then, it is well settled that the assessee cannot be expected to be after the person with whom he has entered in the business transactions and the assessee's onus is to establish the identity of the party

HEALTH BIOTECH LIMITED,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX,CIRCLE 1(1), CHANDIGARH

In the result, the appeal of the assessee is allowed

Bench: the disposal of the same.

68,581/- on account of disallowance u/s 40(a)(ia) of Rs. 2,23,34,758/-. 4. That on facts, circumstances and legal position of the case, Worthy CIT(A) has erred in confirming the action of Ld. AO of imposition of penalty u/s 271(1)(c) even when the initiation and imposition of that penalty was totally vague