ITO WARD-1, KHANNA vs. SMT. HARINDER KAUR, PROP. M/S GURU NANAK FILLING STATION, LUDHIANA

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri Krinwant Sahay & Shri Paresh M. Joshi

Loss Account, TDS details and the capital account of the proprietor for the A.Y. 2017-18. b) The copy of account of M/s Indian Oil Corporation in the books of the appellant for the relevant A.Y. 2017-18. c) The account information of the assessee downloaded from the login of the assessee maintained with the official portal of the Indian

RICO AUTO INDUSTRIES LIMITED,LUDHIANA vs. PR. COMMISSIONER OF INCOME TAX-1, LUDHIANA

The appeals stand allowed in terms of our above order

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.702/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2020-21) & 2. आयकर अपील सं. / Ita No.703/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2021-22) M/S Rico Auto Industries Ltd. Pr. Cit-1 बनाम/ B-26, Focal Point Aaykar Bhawan, Rishi Nagar Vs. Ludhiana (Punjab)-141010 Ludhiana (Punjab) - 141001 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aaacr-8724-R (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Sudhir Sehgal (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) (Virtual) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 07-10-2025 घोषणाकीतारीख /Date Of Pronouncement : 10/11/2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. In These Twin Appeals, The Assessee Assails Proposed Revision Of The Assessment Order By Revisionary Authority U/S 263 For Assessment Years (Ay) 2020-21 & 2021-22. Facts Are Stated To Be Identical In Both The Years. First, We Take Up Appeal For Ay 2020-21 Wherein The Assessee Challenges Invocation Of Revisionary Jurisdiction U/S 263 By Ld. Pr.

set of against other heads of income (vi) High liabilities as compared to low income / receipts (vii) Huge loss from currency fluctuations (viii) Large difference in the opening stock of current year (in trading and manufacturing account) and closing stock of previous year (in trading and manufacturing a/c as per return of income) (ix) Introduction / addition of high value intangible

RICO AUTO INDUSTRIES LIMITED,LUDHIANA vs. PR. COMMISSIONER OF INCOME TAX-1, LUDHIANA

The appeals stand allowed in terms of our above order

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.702/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2020-21) & 2. आयकर अपील सं. / Ita No.703/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2021-22) M/S Rico Auto Industries Ltd. Pr. Cit-1 बनाम/ B-26, Focal Point Aaykar Bhawan, Rishi Nagar Vs. Ludhiana (Punjab)-141010 Ludhiana (Punjab) - 141001 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aaacr-8724-R (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Sudhir Sehgal (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) (Virtual) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 07-10-2025 घोषणाकीतारीख /Date Of Pronouncement : 10/11/2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. In These Twin Appeals, The Assessee Assails Proposed Revision Of The Assessment Order By Revisionary Authority U/S 263 For Assessment Years (Ay) 2020-21 & 2021-22. Facts Are Stated To Be Identical In Both The Years. First, We Take Up Appeal For Ay 2020-21 Wherein The Assessee Challenges Invocation Of Revisionary Jurisdiction U/S 263 By Ld. Pr.

set of against other heads of income (vi) High liabilities as compared to low income / receipts (vii) Huge loss from currency fluctuations (viii) Large difference in the opening stock of current year (in trading and manufacturing account) and closing stock of previous year (in trading and manufacturing a/c as per return of income) (ix) Introduction / addition of high value intangible

M/S VENKATESH TECHNOKRAFT PVT. LTD.,LUDHIANA vs. ITO, W-1(5), LUDHIANA

Bench: Him Which Is Arbitrary & Unjustified. 3. That The Assessment Order Having Been Passed By The Assessing Officer After Due Application Of Mind & Taking Into Consideration The Various Replies, Material On Record & Books Of Account, The Action Resorted To By The Commissioner Of Income Tax Is Unwarranted & Uncalled For.

set aside. 7. In his rival submissions the Ld. CIT DR strongly supported the impugned order passed by the Ld. Pr. CIT and further submitted that the A.O. had not made the proper enquiry before framing the assessment, therefore the assessment order passed by the A.O. was erroneous. It was further submitted that all the companies who made the investment

BANUR BROTHER ,PATIALA vs. ITO-WARD-1, AMBALA

In the result appeal of the assessee is allowed as and by way of remand to Ld

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

loss shall be allowed to the assessee under any provision of this Act in computing his income referred to in clause (a) [and clause (b)] of sub section (1)." Penalty proceedings u/s 270A and 272A(1)(d) of the Income Tax Act are also proposed to be initiated. In the interest of natural justice, you are hereby given final opportunity

CEIGALL INDIA LIMITED, LUDHIANA,LUDHIANA vs. PRINCIPAL COMMISSIONER OF INCOME TAX, LUDHIANA, LUDHIANA

In the result, the appeal of the assessee stands allowed

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

Loss Account.  Since, we had deducted the TDS on much larger sum and all such figures are part and parcel of the regular books of accounts and audited set

ITO, WARD 2(1), CHANDIGARH vs. M/S LONGIA ENGINEERS, CHANDIGARH

In the result, the appeal of the assessee is allowed

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

Loss account, it is noted that the assessee has declared sales/receipts from job work at Rs. 1,36,73,469/- and as per Form 26 AS, the assessee has been shown as having receipts from three Garrison Engineers totaling to Rs 1,30,94,241/- (on which TDS of Rs 2,68,577/- has been deducted) and the difference

M/S SUSHIL KUMAR GUPTA & COMPANY,AMBALA CITY vs. PR.CIT, PANCHKULA

In the result, the appeal of the assessee is allowed

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

TDS u/s 194C for the job charges, which issue was duly considered by the Ld. Assessing Officer during the course of assessment proceedings as is evident from page-9 of the order of Ld. PCIT u/s 263. 4. That the PCIT has failed to appreciate the judgment of jurisdictional Bench of the ITAT, Chandigarh Bench in the case

ACIT, CHANDIGARH vs. M/S GLAXO SMITHKLINE ASIA PVT. LTD., GURGAON

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

set of the TPO comparable companies. In fact, has cherry picked only the companies with higher margins in order to predetermined result and rejected the said companies having lower margins. It may be noted that the companies passes all the filters applied by the TPO and functional dissimilarity is not disputed by the TPO. Therefore, the company be considered

ACIT, CHANDIGARH vs. M/S GLAXO SMITHKLINE ASIA PVT. LTD., GURGAON

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

set of the TPO comparable companies. In fact, has cherry picked only the companies with higher margins in order to predetermined result and rejected the said companies having lower margins. It may be noted that the companies passes all the filters applied by the TPO and functional dissimilarity is not disputed by the TPO. Therefore, the company be considered

M/S GLAXO SMITHKLINE ASIA PVT. LTD.,NABHA vs. DCIT, C-4(1), CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

set of the TPO comparable companies. In fact, has cherry picked only the companies with higher margins in order to predetermined result and rejected the said companies having lower margins. It may be noted that the companies passes all the filters applied by the TPO and functional dissimilarity is not disputed by the TPO. Therefore, the company be considered

ACIT, CHANDIGARH vs. M/S GLAXO SMITHKLINE ASIA PVT. LTD., GURGAON

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

set of the TPO comparable companies. In fact, has cherry picked only the companies with higher margins in order to predetermined result and rejected the said companies having lower margins. It may be noted that the companies passes all the filters applied by the TPO and functional dissimilarity is not disputed by the TPO. Therefore, the company be considered

GLAXOSMITHKLINE ASIA PVT. LTD.,GURGAON vs. ACIT, CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

set of the TPO comparable companies. In fact, has cherry picked only the companies with higher margins in order to predetermined result and rejected the said companies having lower margins. It may be noted that the companies passes all the filters applied by the TPO and functional dissimilarity is not disputed by the TPO. Therefore, the company be considered

M/S GLAXO SMITHKLINE ASIA PVT. LTD.,GURGAON vs. ACIT, C-4(1), CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

set of the TPO comparable companies. In fact, has cherry picked only the companies with higher margins in order to predetermined result and rejected the said companies having lower margins. It may be noted that the companies passes all the filters applied by the TPO and functional dissimilarity is not disputed by the TPO. Therefore, the company be considered

GLAXOSMITHKLINE ASIA PVT. LTD.,GURGAON vs. ACIT, CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

set of the TPO comparable companies. In fact, has cherry picked only the companies with higher margins in order to predetermined result and rejected the said companies having lower margins. It may be noted that the companies passes all the filters applied by the TPO and functional dissimilarity is not disputed by the TPO. Therefore, the company be considered

GLAXOSMITHKLINE ASIA PVT. LTD.,GURGAON vs. DCIT, CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

set of the TPO comparable companies. In fact, has cherry picked only the companies with higher margins in order to predetermined result and rejected the said companies having lower margins. It may be noted that the companies passes all the filters applied by the TPO and functional dissimilarity is not disputed by the TPO. Therefore, the company be considered

ACIT, CHANDIGARH vs. M/S GLAXO SMITHKLINE ASIA PVT. LTD., GURGAON

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

set of the TPO comparable companies. In fact, has cherry picked only the companies with higher margins in order to predetermined result and rejected the said companies having lower margins. It may be noted that the companies passes all the filters applied by the TPO and functional dissimilarity is not disputed by the TPO. Therefore, the company be considered

GLAXOSMITHKLINE ASIA PVT. LTD.,GURGAON vs. DCIT, CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

set of the TPO comparable companies. In fact, has cherry picked only the companies with higher margins in order to predetermined result and rejected the said companies having lower margins. It may be noted that the companies passes all the filters applied by the TPO and functional dissimilarity is not disputed by the TPO. Therefore, the company be considered