DCIT, CHANDIGARH vs. M/S WINSOME YARNS LTD., CHANDIGARH

In the result, all the appeals of the Revenue are dismissed

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

1), sections 4, 5, 9, 90, 91 as well as the provisions of the DTAA are also relevant, while applying tax deduction at source provisions. Reference to the Income-tax Officer (TDS

DCIT, CHANDIGARH vs. M/S WINSOME YARNS LTD., CHANDIGARH

In the result, all the appeals of the Revenue are dismissed

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

1), sections 4, 5, 9, 90, 91 as well as the provisions of the DTAA are also relevant, while applying tax deduction at source provisions. Reference to the Income-tax Officer (TDS

DCIT, C-1 (EXEMPTIONS), CHANDIGARH vs. THE INSTITUTION OF CIVIL ENGINEERS SOCIETY, LUDHIANA

In the result, appeal of the Revenue is dismissed

90,000/-\nusing the funds of the assessee stating that these allegations have not\nled to any additions or disallowance and there is no need to discuss this\nissue, whereas it is a ground for proving non-charitable object of the\nassessee?\nvii)\nWhether on the facts and in the circumstances of the case, the Ld.\nCIT(A) has erred

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

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

1. That the notice issued under section 274 read with section 271(l)(c) of the Act initiating penalty proceedings against the appellant is vague, illegal and bad in law. 2. That, in view of the facts and circumstances of the case and in law, no valid satisfaction has been recorded by the Assessing Officer while completing the assessment proceedings

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

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

1. That the notice issued under section 274 read with section 271(l)(c) of the Act initiating penalty proceedings against the appellant is vague, illegal and bad in law. 2. That, in view of the facts and circumstances of the case and in law, no valid satisfaction has been recorded by the Assessing Officer while completing the assessment proceedings

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

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

1. That the notice issued under section 274 read with section 271(l)(c) of the Act initiating penalty proceedings against the appellant is vague, illegal and bad in law. 2. That, in view of the facts and circumstances of the case and in law, no valid satisfaction has been recorded by the Assessing Officer while completing the assessment proceedings

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

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

1. That the notice issued under section 274 read with section 271(l)(c) of the Act initiating penalty proceedings against the appellant is vague, illegal and bad in law. 2. That, in view of the facts and circumstances of the case and in law, no valid satisfaction has been recorded by the Assessing Officer while completing the assessment proceedings

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

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

1. That the notice issued under section 274 read with section 271(l)(c) of the Act initiating penalty proceedings against the appellant is vague, illegal and bad in law. 2. That, in view of the facts and circumstances of the case and in law, no valid satisfaction has been recorded by the Assessing Officer while completing the assessment proceedings

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

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

1. That the notice issued under section 274 read with section 271(l)(c) of the Act initiating penalty proceedings against the appellant is vague, illegal and bad in law. 2. That, in view of the facts and circumstances of the case and in law, no valid satisfaction has been recorded by the Assessing Officer while completing the assessment proceedings

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2, LUDHIANA , LUDHIANA vs. AB ALCOBEV PRIVATE LIMITED, DELHI

In the result, appeals of Revenue are dismissed, Cross\nObjections of the assessee for

section 153C in the case of the assessee after duly\nrecording satisfaction that the seized documents belonged to the assessee and represented its\nundisclosed 11 income. In the absence of such compliance, the assessment so framed is without\njurisdiction and liable to be quashed.\n6. The Assessing Officer has relied upon various documents and digital data seized during\nthe search

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2, LUDHIANA vs. AB ALCOBEV PRIVATE LIMITED, DELHI

In the result, appeals of Revenue are dismissed, Cross\nObjections of the assessee for

section 153C in the case of the assessee after duly\nrecording satisfaction that the seized documents belonged to the assessee and represented its\nundisclosed 11 income. In the absence of such compliance, the assessment so framed is without\njurisdiction and liable to be quashed.\n6. The Assessing Officer has relied upon various documents and digital data seized during\nthe search

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2,, LUDHIANA vs. AB ALCOBEV PRIVATE LIMITED, DELHI

In the result, appeals of Revenue are dismissed, Cross\nObjections of the assessee for

90 assessment orders of this group were also\nsent to the Addl. Commissioner who has granted the approval\non same day i.e. 29.09.2021. The ld. counsel for the assessee,\nthereafter, made reference to the letter of the Assessing\nOfficer dated 29.09.2021 vide which approval was sought in\nthe case of Shri Rajinder Singh Gujral, Shri Kewal Krishan\nChhabra for assessment

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2 LUDHIANA, LUDHIANA vs. AB ALCOBEV PRIVATE LIMITED , DELHI

In the result, appeals of Revenue are dismissed, Cross\nObjections of the assessee for

90 assessment orders of this group were also\nsent to the Addl. Commissioner who has granted the approval\non same day i.e. 29.09.2021. The ld. counsel for the assessee,\nthereafter, made reference to the letter of the Assessing\nOfficer dated 29.09.2021 vide which approval was sought in\nthe case of Shri Rajinder Singh Gujral, Shri Kewal Krishan\nChhabra for assessment

M/S GLAXOSMITHKLINE ASIA PVT. LTD.,GURGAON vs. DCIT, CHANDIGARH

In the result, the appeal of the assessee is partly allowed

90,20.655 under section 40{a)(i) of the Act, with respect to purchase of vaccine amounting to Rs. 1 6,08,70,538 made by the assessing officer and sustained by the C1T(A) is unlawful and not sustainable for the reasons submitted in our written submissions separately filed. Further, it has been repeatedly held by the Courts

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,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

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