SCOTT EDIL ADVANCE RESEARCH LABORATORIES AND EDUCATION LIMITED,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

investment towards cost of construction outside the regular books of\naccount. We also note that the Ld. CIT(A) had deleted the addition in this year by\nfollowing the order of the Ld. CIT(A) for the immediately preceding assessment year.\nSince no material was found in the search and seizure operations which could justify the\nAssessing Officer's action

SCOTT EDIL ADVANCE RESEARCH LABORATORIES AND EDUCATION LIMITED,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

investment towards cost of construction outside the regular books of\naccount. We also note that the Ld. CIT(A) had deleted the addition in this year by\nfollowing the order of the Ld. CIT(A) for the immediately preceding assessment year.\nSince no material was found in the search and seizure operations which could justify the\nAssessing Officer's action

SCOTT EDIL ADVANCE RESEARCH LABORATORIES AND EDUCATION LIMITED,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

investment towards cost of construction outside the regular books of\naccount. We also note that the Ld. CIT(A) had deleted the addition in this year by\nfollowing the order of the Ld. CIT(A) for the immediately preceding assessment year.\nSince no material was found in the search and seizure operations which could justify the\nAssessing Officer's action

SANJEEV AGGARWAL,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1 , CHANDIGARH

investment towards cost of construction outside the regular books of\naccount. We also note that the Ld. CIT(A) had deleted the addition in this year by\nfollowing the order of the Ld. CIT(A) for the immediately preceding assessment year.\nSince no material was found in the search and seizure operations which could justify the\nAssessing Officer's action

MAXPORT INDIA PRIVATE LIMITED,CHANDIGARH vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,CHANDIGARH, CHANDIGARH

investment towards cost of construction outside the regular books of\naccount. We also note that the Ld. CIT(A) had deleted the addition in this year by\n54\nfollowing the order of the Ld. CIT(A) for the immediately preceding assessment year.\nSince no material was found in the search and seizure operations which could justify the\nAssessing Officer

SHRI BALRAM KRISHAN,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH, CHANDIGARH

investment towards cost of construction outside the regular books of\naccount. We also note that the Ld. CIT(A) had deleted the addition in this year by\nfollowing the order of the Ld. CIT(A) for the immediately preceding assessment year.\nSince no material was found in the search and seizure operations which could justify the\nAssessing Officer's action

SHRI BALRAM KRISHAN,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH, CHANDIGARH

investment towards cost of construction outside the regular books of\naccount. We also note that the Ld. CIT(A) had deleted the addition in this year by\nfollowing the order of the Ld. CIT(A) for the immediately preceding assessment year.\nSince no material was found in the search and seizure operations which could justify the\nAssessing Officer's action

MAXPORT INDIA PRIVATE LIMITED,CHANDIGARH vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,CHANDIGARH, CHANDIGARH

investment towards cost of construction outside the regular books of\naccount. We also note that the Ld. CIT(A) had deleted the addition in this year by\nfollowing the order of the Ld. CIT(A) for the immediately preceding assessment year.\nSince no material was found in the search and seizure operations which could justify the\nAssessing Officer's action

SCOTT EDIL ADVANCE RESEARCH LABORATORIES AND EDUCATION LIMITED,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

investment towards cost of construction outside the regular books of\naccount. We also note that the Ld. CIT(A) had deleted the addition in this year by\nfollowing the order of the Ld. CIT(A) for the immediately preceding assessment year.\nSince no material was found in the search and seizure operations which could justify the\nAssessing Officer's action

JANTA LAND PROMOTERS PVT LTD,MOHALI vs. THE PRINICIPAL COMMISSIONER OF INCOME TAX ,CHANDIGARH-1, CHANDIGARH

In the result, appeal of the Assessee is allowed

investment in a partnership firm. Therefore, the provisions of Section 1941A or TDS under any other section are not applicable in this case. The contention is proved by means of the following a) As per provision of section 1941A, the TDS on purchase of property has to be deducted at the time of payment, The assessee has already deducted TDS

INCOME TAX OFFICER, CHANDIGARH vs. CHARANDEEP SINGH, CHANDIGARH

Accordingly, the C.O. is dismissed as not pressed

unexplained of investment u/s 69 of the Act\nand is added to the taxable income of the assessee.\"\n\n5. Against the assessment order passed by the A.O. the\nassessee filed an appeal before the 1d. CIT(A) NFAC. The 1d.\nCIT(A) in the appellate order has given his findings on the\nissues as under:\n\n“The assessment

SCOTT EDIL PHARMACIA LTD.,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

investment and would not constitute as conclusive evidence of\ninvestment. The ld. Counsel has further relied upon the decision of the Hon’ble Supreme\nCourt in the case of PCIT vs. Abhisar Buildwell P. Ltd. Civil Appeal No.6580 of 2021\ndated 24.04.2023 reported in [2023] 149 taxmann.com 399 (SC) wherein the Hon’ble\nSupreme Court has held that in respect

DEVINDER SINGH HANSPAL,MOHALI vs. DCIT ACIT CIR 1(1), CHANDIGARH

The appeal of the assessee is allowed for statistical

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

unexplained investment made in cash in property at M/s Homeland Buildwell Pvt. Ltd. 4. That on facts, circumstances and legal position of the case, Worthy CIT(A) has erred in confirming the action of Ld.AO of not allowing the credit of TDS

SHRI BALRAM KRISHAN,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH, CHANDIGARH

unexplained investment in a property solely on\nthe basis of DVO report without any other corroborating evidence or incriminating\nevidence found in support of such addition. The Hon’ble Supreme Court in Sargam\n...\n...\n...\n...\n53\nCinema v. CIT (328 ITR 513) has held that a DVO’s report cannot be relied upon unless\nthe books of accounts

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

unexplained investment by the assessee has been found during search proceedings since the only addition made is addition of alleged unaccounted sales. Therefore, the addition made by Ld. AO merely on the basis of welcome letters and loose sheets is misconceived and unjustified. The allegation that the units were sold at much higher price do not have any foundation

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

unexplained investment by the assessee has been found during search proceedings since the only addition made is addition of alleged unaccounted sales. Therefore, the addition made by Ld. AO merely on the basis of welcome letters and loose sheets is misconceived and unjustified. The allegation that the units were sold at much higher price do not have any foundation

SCOTT EDIL PHARMACIA LTD.,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

unexplained investment in a property solely on\nthe basis of DVO report without any other corroborating evidence or incriminating\nevidence found in support of such addition. The Hon’ble Supreme Court in Sargam\n53\nCinema v. CIT (328 ITR 513) has held that a DVO’s report cannot be relied upon unless\nthe books of accounts are found

SCOTT EDIL PHARMACIA LTD.,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

investment in construction\nof property, the same would have come from the same profit from manufacturing\noperations. Therefore, the deduction u/s 80IC should have been allowed on that\ncomponent of income invested in alleged construction.\n52. The Ld. CIT (DR) , on the other hand, has contended that the ld. AO was justified\nin making the impugned addition on the basis