SARAF THE JEWELLER, CHANDIGARH,CHANDIGARH vs. THE DCIT/ACIT CENTRAL CIRCLE -2, CHANDIGARH, CHANDIGARH

Appeal stand dismissed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं. / Ita No.1231/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2020-21) Saraf The Jeweller Dcit / Acit (Central)-2 बनाम/ Sco 45, Pocket No.1 C.R. Building Nac Showroom, Manimajra Himalaya Marg, Vs. Chandigarh – 160101 Sector-17E, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकरअपीलसं. / Ita No.1593/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2020-21) Dcit / Acit (Central)-2 Saraf The Jeweller बनाम/ C.R. Building Sco 45, Pocket No.1 Himalaya Marg, Nac Showroom, Manimajra Vs. Sector-17E, Chandigarh Chandigarh – 160101 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/Appellant Sh. Sudhir Sehgal (Advocate) & Sh. Sahil Ratra (Advocate) – Ld. Ars By : ""थ"कीओरसे/Respondent By : Sh. Abhishek Pal Garg (Cit) & Dr. Ranjit Kaur (Addl. Cit) – Ld. Drs सुनवाईकीतारीख/Date Of Hearing : 12.02.2026 घोषणाकीतारीख /Date Of Pronouncement 11.03.2026 : आदेश / O R D E R Per Bench

credit u/s 68, the assessee contended that it furnished complete details of all the lenders including name, address, confirmation, PAN and bank statements. The loans were received through normal banking channels. There was no material to suggest that the same represent assessee’s unaccounted money. No enquiry was made from any of the lender parties and there was no adverse

TEJ PAUL BHARDWAJ,SUNAM vs. PR. CIT, PATIALA

In the result, the appeal filed by the assessee is allowed

Bench: The Ao & Furnished The Details Called

unexplained cash credit of the assessee has been under assessed by the AO. ii) There was another bank account of the assessee in HDFC bank in Goa where total deposits of Rs. 19,31,750/- was made by the assessee but the AO found credited amount of Rs. 5,76,056/- only. Thus, total deposits made in the bank were

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

unexplained cash credit. The substantial loan / advance stood repaid in next year through banking channels. The loans are supported by ledger extracts. Once loans are repaid within short period of time and the repayment has been accepted, the genuineness of the same could not be questioned. Regarding M/s Binus Trading Co., it has been stated that it is a directly

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

unexplained cash credit. The substantial loan / advance stood repaid in next year through banking channels. The loans are supported by ledger extracts. Once loans are repaid within short period of time and the repayment has been accepted, the genuineness of the same could not be questioned. Regarding M/s Binus Trading Co., it has been stated that it is a directly

SARAF THE JEWELLER, CHANDIGARH,CHANDIGARH vs. THE DCIT/ACIT CENTRAL CIRCLE- 2, CHANDIGARH, CHANDIGARH

Appeal stand dismissed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं. / Ita No.1232/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2021-22) Saraf The Jeweller Dcit / Acit (Central)-2 बनाम/ Sco 45, Pocket No.1 C.R. Building Nac Showroom, Manimajra Himalaya Marg, Vs. Chandigarh – 160101 Sector-17E, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकरअपीलसं. / Ita No.1594/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2021-22) Dcit / Acit (Central)-2 Saraf The Jeweller बनाम/ C.R. Building Sco 45, Pocket No.1 Himalaya Marg, Nac Showroom, Manimajra Vs. Sector-17E, Chandigarh Chandigarh – 160101 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) Assessee By : Sh. Sudhir Sehgal (Advocate) & Sh. Sahil Ratra (Advocate) – Ld. Ars Revenue By : Sh. Abhishek Pal Garg (Cit) & Dr. Ranjit Kaur (Addl. Cit) – Ld. Drs सुनवाईकीतारीख/Date Of Hearing : 12.02.2026 घोषणाकीतारीख /Date Of Pronouncement 12.03.2026 : आदेश / O R D E R Per Bench

credit entry is found in the books of the assessee and the assessee is unable to explain its nature and source. The receipts under consideration were recorded sales proceeds. Their nature was known and their source was the trading activity of the assessee. Therefore, this addition was deleted against which the revenue is in further appeal before

ASSISTANT COMMISSIONER OF INCOME TAX, CHANDIGARH vs. SARAF THE JEWELLERS, PUNJAB

Appeal stand dismissed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं. / Ita No.1232/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2021-22) Saraf The Jeweller Dcit / Acit (Central)-2 बनाम/ Sco 45, Pocket No.1 C.R. Building Nac Showroom, Manimajra Himalaya Marg, Vs. Chandigarh – 160101 Sector-17E, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकरअपीलसं. / Ita No.1594/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2021-22) Dcit / Acit (Central)-2 Saraf The Jeweller बनाम/ C.R. Building Sco 45, Pocket No.1 Himalaya Marg, Nac Showroom, Manimajra Vs. Sector-17E, Chandigarh Chandigarh – 160101 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) Assessee By : Sh. Sudhir Sehgal (Advocate) & Sh. Sahil Ratra (Advocate) – Ld. Ars Revenue By : Sh. Abhishek Pal Garg (Cit) & Dr. Ranjit Kaur (Addl. Cit) – Ld. Drs सुनवाईकीतारीख/Date Of Hearing : 12.02.2026 घोषणाकीतारीख /Date Of Pronouncement 12.03.2026 : आदेश / O R D E R Per Bench

credit entry is found in the books of the assessee and the assessee is unable to explain its nature and source. The receipts under consideration were recorded sales proceeds. Their nature was known and their source was the trading activity of the assessee. Therefore, this addition was deleted against which the revenue is in further appeal before

SH. GULSHAN KUMAR PROP. G.K. RESORTS,LUDHIANA vs. DCIT CIRCLE-2, LUDHIANA

In the result, the appeal of the assessee is allowed

Bench: Smt.Diva Singh & Shri Vikram Singh Yadavsh. Gulshan Kumar बनाम Deputy Commissioner Of Prop. G. K. Resorts House No. 3, Income Tax, Central Circle-2, Agar Nagar Extension, Ferospur Ludhiana Road, Ludhiana 1410212, Punjab "थायी लेखा सं./Pan No: Aaqpk1200Q

unexplained credits and the source of the credit entries in the bank accounts are not available. Regarding rental income, it was submitted that the assessee has let out various properties from where assessee earns monthly rental income of Rs. 55000/- which has been duly reflected in the return filed for F.Y 2015-16 and the Assessing Officer has merely rejected

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)

unexplained cash credit u/s 68 of the Act, since the assessee did not establish its genuineness during the assessment proceedings. The Department has ITA 5 &145/CHD/2023 A.Y. 2017-18 40 contended that the ld. CIT(A) erred in holding that the identity and credit worthiness of the persons from whom the credits comprising the amount of Rs.1

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)

unexplained cash credit u/s 68 of the Act, since the assessee did not establish its genuineness during the assessment proceedings. The Department has ITA 5 &145/CHD/2023 A.Y. 2017-18 40 contended that the ld. CIT(A) erred in holding that the identity and credit worthiness of the persons from whom the credits comprising the amount of Rs.1

VINAYAK STEEL,PEHOWA vs. DEPUTY COMMISSIONER OF INCOME TAX, KURUKSHETRA

In the result, appeal of the assessee is partly allowed

Bench: Shri Mahavir Singh & Shri Krinwant Sahay

unexplained cash credit. Similarly, the assessee also filed the bank account details of Sidh Prakash & Sons and drew our attention to the balance sheet and entry list. The Ld. Counsel stated that this amount of Rs. 85 lakhs was received by account payee cheques of Central Bank of India’s CC account and these amounts were received

JAI GOPAL GOYAL,MOHALI vs. INCOME TAX OFFICER, WARD 6(1), MOHALI

In the result, Assessee’s appeal is allowed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 1123/Chd/2024 "नधा"रण वष" / Assessment Year : 2017-18 Jai Gopal Goyal, The Ito, बनाम C-146, Industrial Area, Ward 6(1), Phase Vii, Chandigarh Vs. Mohali, Punjab "थायी लेखा सं./Pan No: Acdpg0160G अपीलाथ"/Appellant ""यथ"/Respondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : Sh. Parikshit Aggarwal, Ca & Ms. Shruti Khandelwal, Advocate राज"व क" ओर से/ Revenue By : Shri Vivek Vardhan, Addl. Cit, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 04.06.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 11.08.2025 आदेश/Order Per Krinwant Sahay, Am: Appeal In This Case Has Been Filed By The Assessee Against The Order Dated 04.10.2024 Of Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi.

cash amount was deposited in the bank account of Smt. Santosh Kumari before the transferring the money to the assessee. Accordingly, the amount of Rs. 18,00,000/- is hereby treated as unexplained credit u/s 68 of the Act and added to the declared returned income for the year under consideration." From the above extract, it is clearly evident that

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)

unexplained cash credit u/s 68 of the Act, since the assessee did not establish its genuineness during the assessment proceedings. The Department has contended that the ld. CIT(A) erred in holding that the identity and credit worthiness of the persons from whom the credits comprising the amount of Rs.2,77,01,650/- were received, stood proved, whereas the genuineness

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)

unexplained cash credit u/s 68 of the Act, since the assessee did not establish its genuineness during the assessment proceedings. The Department has contended that the ld. CIT(A) erred in holding that the identity and credit worthiness of the persons from whom the credits comprising the amount of Rs.2,77,01,650/- were received, stood proved, whereas the genuineness

SWATI INDUSTRIES D-74, PHASE-V FOCAL POINT, LUDHIANA,PUNJAB vs. THE DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-3, LUDHIANA , PUNJAB

In the result, the grounds of appeal of the department are dismissed and that of assessee are allowed

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 216/Chd/2024 निर्धारण वर्ष / Assessment Year : 2019-20 Swati Industries D-74, Phase-V, Focal Point, Ludhiana, Punjab-141010 बनाम The DCIT Central Circle-3 Ludhiana, Punjab स्थायी लेखा सं./PAN NO: AADFS5870M अपीलार्थी/Appellant प्रत्यर्थी/Respondent आयकर अपील सं. / ITA No. 547/Chd/2024 निर्धारण वर्ष / Assessment Year : 2019-20 बनाम The DCIT Central Circle-3 Ludhiana, Punjab स्थायी लेखा सं./PAN NO: AADFS5870

TDS. 5. Whether upon the facts and circumstances of the case, the Ld.CITIA) was rightly justified in deleting addition of Rs. 15,00,000/- on account of unverified unsecured loan as unexplained cash credit

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 3, LUDHIANA, LUDHIANA vs. SWATI INDUSTRIES, PUNJAB

In the result, the grounds of appeal of the department are dismissed and that of assessee are allowed

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 216/Chd/2024 निर्धारण वर्ष / Assessment Year : 2019-20 Swati Industries D-74, Phase-V, Focal Point, Ludhiana, Punjab-141010 बनाम The DCIT Central Circle-3 Ludhiana, Punjab स्थायी लेखा सं./PAN NO: AADFS5870M प्रत्यर्थी/Respondent अपीलार्थी/Appellant आयकर अपील सं. / ITA No. 547/Chd/2024 निर्धारण वर्ष / Assessment Year : 2019-20 बनाम The DCIT Central Circle-3 Ludhiana, Punjab स्थायी लेखा सं./PAN NO: AADFS5870

TDS. 5. Whether upon the facts and circumstances of the case, the Ld.CITIA) was rightly justified in deleting addition of Rs. 15,00,000/- on account of unverified unsecured loan as unexplained cash credit

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

unexplained cash credit u/s 68 of the Income Tax Act. This addition was confirmed by the Ld. CIT(A). The matter was carried by the assessee before the Hon'ble ITAT and the Hon'ble ITAT deleted the addition vii). Further, it is submitted that whatever cash deposits were made by the assessee during the year under consideration and during

BANSAL RICE TRADERS,SANGRUR vs. ITO-WARD, SANGRUR

In the result, appeal of the assessee is allowed

unexplained cash and Rs. 2,223,119/- contractual receipt received at Rs. 17,23,120/-. During the course of assessment proceedings, sufficient opportunities of being heard were provided to the assessee and the assessee the assessee has not shown any interest to provide the same. Aggrieved assessee had not accepted the order passed u/s 144 of Income

M/S TJR PROPERTIES PVT. LTD.,CHANDIGARH vs. ACIT, CC-2, CHANDIGARH

In the result, the Appeal is partly allowed

Bench: Shri A.D. Jain & Shri Vikram Singh Yadav

credit separately on merit and on the plea that purpose and utilization of funds not explained by assessee. CIT(A)’s Observation - Page 100, point 7 of CIT Order 17.3 The CIT(A) confirmed addition of Rs. 4,13,000/- on account of cash deposit made by the assessee company by mentioning that - "The cash deposits were explained as made

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)

unexplained sources under Section 69A of the Income Tax Act and was added to the income of the assessee for the assessment year 2017-18. The total income assessed was taxed under Section 115BBE of the Act. 4. Before the ld. CIT(A), the assessee made the following A.Y. 2017-18 4 written submissions : "Assessee Sh. Pawan Kumar is engaged