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 on the payment made. 11. The decision of the A.A.R. in the case of ‘S.K.F. Boilers & Driers P Ltd.’ (supra) is, as duly taken note of the ld. CIT(A), clearly distinguishable on facts. That decision, places reliance on the decision in the case of ‘Rajiv Malhotra’, rendered by the A.A.R., and reported at 284 ITR 564. In that

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 on the payment made. 11. The decision of the A.A.R. in the case of ‘S.K.F. Boilers & Driers P Ltd.’ (supra) is, as duly taken note of the ld. CIT(A), clearly distinguishable on facts. That decision, places reliance on the decision in the case of ‘Rajiv Malhotra’, rendered by the A.A.R., and reported at 284 ITR 564. In that

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 on the payment made. 11. The decision of the A.A.R. in the case of ‘S.K.F. Boilers & Driers P Ltd.’ (supra) is, as duly taken note of the ld. CIT(A), clearly distinguishable on facts. That decision, places reliance on the decision in the case of ‘Rajiv Malhotra’, rendered by the A.A.R., and reported at 284 ITR 564. In that

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 on the payment made. 11. The decision of the A.A.R. in the case of ‘S.K.F. Boilers & Driers P Ltd.’ (supra) is, as duly taken note of the ld. CIT(A), clearly distinguishable on facts. That decision, places reliance on the decision in the case of ‘Rajiv Malhotra’, rendered by the A.A.R., and reported at 284 ITR 564. In that

ACIT, CIRCLE, PANCHKULA vs. M/S HARYANA VIDYUT PRASARAN NIGAM LTD., PANCHKULA

In the result, we upheld the

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

TDS under section 194A of the Act. Hence, the provision so made was also held disallowable under section 40(a)(ia)of the Act and this was one of the reason recorded before issuance of notice under section 148 of the Act. Thereafter, during the reassessment proceedings, the AO accepted the submissions of the assessee that no tax was required

INCOME TAX OFFICER, FATEHABAD vs. MAHESH NAGPAL, FATEHABAD

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

TDS) by the payer at the time of making payment for compulsory acquisition of immovable property other than agricultural land. It was further contended that in the case of Hari Singh v. Union of India [2018] 91 taxmann.com 20 (SC)the issue of chargeability of interest to tax was not the lis before the Hon’ble Supreme Court. The only

SH. AMARDEEP SINGH ATHWAL,YAMUNANAGAR vs. ITO, WARD-1, YAMUNANAGAR

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

TDS) by the payer at the time of making payment for compulsory acquisition of immovable property other than agricultural land. It was further contended that in the case of Hari Singh v. Union of India [2018] 91 taxmann.com 20 (SC)the issue of chargeability of interest to tax was not the lis before the Hon’ble Supreme Court. The only

ARJESH KUMAR,PATIALA vs. ITO NATIONAL E-ASSESSMENT CENTRE , DELHI

TDS) by the payer at the time of making payment for compulsory acquisition of immovable property other than agricultural land. It was further contended that in the case of Hari Singh v. Union of India [2018] 91 taxmann.com 20 (SC)the issue of chargeability of interest to tax was not the lis before the Hon’ble Supreme Court. The only

BALBIR KUMAR HUF,CHANDIGARH vs. ITO , CHANDIGARH

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

TDS) by the payer at the time of making payment for compulsory acquisition of immovable property other than agricultural land. It was further contended that in the case of Hari Singh v. Union of India [2018] 91 taxmann.com 20 (SC)the issue of chargeability of interest to tax was not the lis before the Hon’ble Supreme Court. The only

PAWAN KUMAR,FATEHABAD vs. INCOME TAX OFFICER WARD-1, FATEHABAD

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

TDS) by the payer at the time of making payment for compulsory acquisition of immovable property other than agricultural land. It was further contended that in the case of Hari Singh v. Union of India [2018] 91 taxmann.com 20 (SC)the issue of chargeability of interest to tax was not the lis before the Hon’ble Supreme Court. The only

SH. AMARDEEP SINGH ATHWAL,YAMUNANAGAR vs. ITO, WARD-1, YAMUNANAGAR

Bench: BEFORE: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

TDS) by the payer at the time of making payment for compulsory acquisition of immovable property other than agricultural land. It was further contended that in the case of Hari Singh v. Union of India [2018] 91 taxmann.com 20 (SC)the issue of chargeability of interest to tax was not the lis before the Hon’ble Supreme Court. The only

RANJIT SINGH,PANCHKULA vs. DEPUTY DIRECTOR, CPC DEPARTMENT

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

TDS) by the payer at the time of making payment for compulsory acquisition of immovable property other than agricultural land. It was further contended that in the case of Hari Singh v. Union of India [2018] 91 taxmann.com 20 (SC)the issue of chargeability of interest to tax was not the lis before the Hon’ble Supreme Court. The only

SAROJ CHAUDHARY BALA,PANCHKULA vs. ITO, WARD-4, PANCHKULA

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

TDS) by the payer at the time of making payment for compulsory acquisition of immovable property other than agricultural land. It was further contended that in the case of Hari Singh v. Union of India [2018] 91 taxmann.com 20 (SC)the issue of chargeability of interest to tax was not the lis before the Hon’ble Supreme Court. The only

SMT. SHANKRI DEVI,PANCHKULA vs. ACIT, PANCKULA CIRCLE, PANCHKULA

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

TDS) by the payer at the time of making payment for compulsory acquisition of immovable property other than agricultural land. It was further contended that in the case of Hari Singh v. Union of India [2018] 91 taxmann.com 20 (SC)the issue of chargeability of interest to tax was not the lis before the Hon’ble Supreme Court. The only

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.

69,68,581/- 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

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, 69

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)

69 of the Income-tax Act, 1961 - Unexplained investments (Bogus purchase) Assessment year 2009-10 - Where Assessing Officer had not brought any material on record to conclusively establish fact that purchases were bogus, merely relying upon information from Sales Tax Department or fact that parties were not produced Assessing Officer could not have treated purchases as bogus and made addition

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)

69 of the Income-tax Act, 1961 - Unexplained investments (Bogus purchase) Assessment year 2009-10 - Where Assessing Officer had not brought any material on record to conclusively establish fact that purchases were bogus, merely relying upon information from Sales Tax Department or fact that parties were not produced Assessing Officer could not have treated purchases as bogus and made addition

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