M/S AJAY KUMAR SOOD ENGINEERS & CONTRACTORS,SHIMLA vs. DCIT, CHANDIGARH

The appeal of the Revenue is hereby dismissed

Bench: Smt. Diva Singh & Dr. B.R.R. Kumar

TDS was deducted was submitted before the Ld. CIT(A). 16.7 The Ld. DR in addition to placing reliance on the order of the Ld. CIT(A), argued that in spite of giving sufficient opportunity to the assessee to explain the huge drop in the GP rate from earlier years, the assessee failed to give any plausible explanation. Further

M/S AJAY KUMAR SOOD ENGINEERS & CONTRACTORS,SHIMLA vs. DCIT, CHANDIGARH

The appeal of the Revenue is hereby dismissed

Bench: Smt. Diva Singh & Dr. B.R.R. Kumar

TDS was deducted was submitted before the Ld. CIT(A). 16.7 The Ld. DR in addition to placing reliance on the order of the Ld. CIT(A), argued that in spite of giving sufficient opportunity to the assessee to explain the huge drop in the GP rate from earlier years, the assessee failed to give any plausible explanation. Further

DCIT, CHANDIGARH vs. M/S AJAY KUMAR SOOD ENGINEERS AND CONTRACTORS, SHIMLA

The appeal of the Revenue is hereby dismissed

Bench: Smt. Diva Singh & Dr. B.R.R. Kumar

TDS was deducted was submitted before the Ld. CIT(A). 16.7 The Ld. DR in addition to placing reliance on the order of the Ld. CIT(A), argued that in spite of giving sufficient opportunity to the assessee to explain the huge drop in the GP rate from earlier years, the assessee failed to give any plausible explanation. Further

M/S AJAY KUMAR SOOD ENGINEERS & CONTRACTORS,SHIMLA vs. DCIT, CHANDIGARH

The appeal of the Revenue is hereby dismissed

Bench: Smt. Diva Singh & Dr. B.R.R. Kumar

TDS was deducted was submitted before the Ld. CIT(A). 16.7 The Ld. DR in addition to placing reliance on the order of the Ld. CIT(A), argued that in spite of giving sufficient opportunity to the assessee to explain the huge drop in the GP rate from earlier years, the assessee failed to give any plausible explanation. Further

M/S AJAY KUMAR SOOD ENGINEERS & CONTRACTORS,SHIMLA vs. DCIT, CHANDIGARH

The appeal of the Revenue is hereby dismissed

Bench: Smt. Diva Singh & Dr. B.R.R. Kumar

TDS was deducted was submitted before the Ld. CIT(A). 16.7 The Ld. DR in addition to placing reliance on the order of the Ld. CIT(A), argued that in spite of giving sufficient opportunity to the assessee to explain the huge drop in the GP rate from earlier years, the assessee failed to give any plausible explanation. Further

M/S AJAY KUMAR SOOD ENGINEERS & CONTRACTORS,SHIMLA vs. DCIT, CHANDIGARH

The appeal of the Revenue is hereby dismissed

Bench: Smt. Diva Singh & Dr. B.R.R. Kumar

TDS was deducted was submitted before the Ld. CIT(A). 16.7 The Ld. DR in addition to placing reliance on the order of the Ld. CIT(A), argued that in spite of giving sufficient opportunity to the assessee to explain the huge drop in the GP rate from earlier years, the assessee failed to give any plausible explanation. Further

SH. SAURABH KAUSHIK,PANCHKULA vs. ITO, WARD 2(1), CHANDIGARH

In the result, the appeal of the assessee is dismissed

Bench: The Disposal Of The Same.

loss is caused to the Revenue, the assessee cannot be saddled with levy of late filing fee u/s 234E of the Act, taking.a judicious view of the matter. In, result, we hold that Ld. CIT(A) has erred in law and in facts in upholding levy of penalty u/s 234E of the Act. • Sh. Gurpreet Singh vs. The ACIT, TDS

HP AGRO INDUSTRIES CORP. LTD.,PARWANOO vs. ACIT, CPC (TDS), VAISHALI

In the result, the appeal of the assessee is allowed

Bench: Shri N.K. Saini & Shri R.L Negiआयकरअपीलसं./Ita No. 1072/Chd/2018 "नधा"रणवष" / Assessment Year : 2015-16 M/S H.P. Agro Industries The Asstt. Cit, बनाम Corporation Ltd., Centralized Processing Cell-Tds, Plot No. 8, Bangluru Pesticide Unit, Parwanoo (H.P) "थायीलेखासं./Pan No: Ptlh11428E अपीलाथ"/Appellant ""यथ"/Respondent Hearing Through Video Conferencing "नधा"रतीक"ओरसे/Assessee By : Shri Manoj Kumar, Advocate राज"वक"ओरसे/ Revenue By : Smt. Meenakshi Vohra, Addl. Cit(Dr)

loss was caused to the department; and that the assessee being a public sector undertaking of the govt. had no intention for late filing of TDS return. However, the Ld. CIT(A) rejecting the contention of the assessee upheld the action of the Assistant Commissioner and dismissed the appeal filed by the assessee. Against the said findings

M/S FASTWAY TRANSMISSION (P) LTD.,CHANDIGARH vs. DCIT, CC-II, CHANDIGARH

In the result the captioned appeals of the assessee are

Bench: Shri N.K. Saini & Shri Sanjay Gargआयकर अपील सं./ Ita No.547/Chd/2017 "नधा"रण वष" / Assessment Year : 2013-14

Set top boxes at the eligible rate of 60% " 7. Ground No.1 raised by the assessee is general in nature, hence needs no adjudication. 8. Grounds No.2 : The assessee vide ground No. 2 has agitated the action of the CIT(A) in confirming the addition of Rs.6,00,38,170/- made on account of interest paid to M/s CISCO Capital

M/S FASTWAY TRANSMISSION (P) LTD.,CHANDIGARH vs. ACIT, CHANDIGARH

In the result the captioned appeals of the assessee are

Bench: Shri N.K. Saini & Shri Sanjay Gargआयकर अपील सं./ Ita No.547/Chd/2017 "नधा"रण वष" / Assessment Year : 2013-14

Set top boxes at the eligible rate of 60% " 7. Ground No.1 raised by the assessee is general in nature, hence needs no adjudication. 8. Grounds No.2 : The assessee vide ground No. 2 has agitated the action of the CIT(A) in confirming the addition of Rs.6,00,38,170/- made on account of interest paid to M/s CISCO Capital

M/S FASTWAY TRANSMISSION (P) LTD.,CHANDIGARH vs. DCIT, CC-II, CHANDIGARH

In the result the captioned appeals of the assessee are

Bench: Shri N.K. Saini & Shri Sanjay Gargआयकर अपील सं./ Ita No.547/Chd/2017 "नधा"रण वष" / Assessment Year : 2013-14

Set top boxes at the eligible rate of 60% " 7. Ground No.1 raised by the assessee is general in nature, hence needs no adjudication. 8. Grounds No.2 : The assessee vide ground No. 2 has agitated the action of the CIT(A) in confirming the addition of Rs.6,00,38,170/- made on account of interest paid to M/s CISCO Capital

DCIT, CHANDIGARH vs. M/S THE TRIBUNE TRUST, CHANDIGARH

In the result, the appeal of the Revenue is allowed

Bench: Shri Sanjay Garg & Ms.Annapurna Guptathe D.C.I.T., Vs. M/S The Tribune Trust, Circle 4(1), Sector 29-C, Chandigarh. Chandigarh. Pan: Aaatt2141D (Appellant) (Respondent)

TDS 1,035,650.00 Refundable (1,035,650.00) 7. The Ld. DR pointed out therefrom that against the gross receipts as per the Profit & Loss a/c of the assessee amounting to Rs.149.14 crores the total expenditure incurred by the assessee both revenue and capital amounted to Rs.136.48 crores resulting in surplus of Rs.12.66 crores and that the losses returned

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