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

unexplained money u/s.69A of the Income Tax Act. 4. Whether upon the facts and circumstances of the case, the Ld. CIT(A) was rightly justified in deleting addition of Rs. 4,65,765/ on account of disallowance of commission expenses u/s 40(a)(ia) for non-deduction of TDS

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

money by the assessee.These loose excel sheets have no corroboration with any other material on record. Similar is the case with whatsapp chats as relied upon by Ld. AO to fortify its allegation. The same are bereft of any third-party corroboration. It is trite law that no addition could be made merely on the basis of presumption, assumptions, conjectures

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

money by the assessee.These loose excel sheets have no corroboration with any other material on record. Similar is the case with whatsapp chats as relied upon by Ld. AO to fortify its allegation. The same are bereft of any third-party corroboration. It is trite law that no addition could be made merely on the basis of presumption, assumptions, conjectures

SMT. TEENA GARG,CHANDIGARH vs. PCIT, PANCHKULA

In the result, appeal of the assessee is allowed

unexplained money u/s 69A of the Act. Thus an\nopportunity was given to assessee to show cause why proposed\n\nvariation should not be made and the assessment should not be\ncompleted accordingly. (Page 14 & 15 of PB)\n\nThe assessee in response to this notice by a reply (page 16 & 17 of\nPB) reiterated that the assessee has only

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

money of M/s Balaji Processors find somewhere in Kolkata which the Assessee has deposited during the demonetization period. 5.8 While making the above observations, the AO failed It appreciate that all the purchases of the Appellant are properly vouched for which required details have been submitted. Further, the Appellant has given quantitative detail such as opening stock, purchased, sales

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. AJAY GOEL,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

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

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.

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 the AO has made the impugned addition on the 1123-Chd-2024 Jai Gopal Goyal, Mohali

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)

money of Rs.1,50,00,000/- during F.Y. 2016-17 for purchase of a plot to build flat/apartment and paid TDS of Rs. 1,50,000/- @1%. Thus, on facts, it is observed that M/s TJR was having income generating apparatus in past and future years and was undertaking business activities. There is no definition of shell company given under

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)

money of Rs.1,50,00,000/- during F.Y. 2016-17 for purchase of a plot to build flat/apartment and paid TDS of Rs. 1,50,000/- @1%. Thus, on facts, it is observed that M/s TJR was having income generating apparatus in past and future years and was undertaking business activities. There is no definition of shell company given under

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

money of Rs.1,50,00,000/- during FY. 2016-17 for purchase of a plot to build flat/apartment and paid TDS of Rs.1,50,000/- @1%. Thus, on facts, it is observed that M/s TJR was having income generating apparatus in past and future years and was undertaking business activities. There is no definition of shell company given under

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)

money of Rs. 1,50,00,000/- during F.Y. 2016-17 for purchase of a plot to build flat/apartment and paid TDS of Rs. 1,50,000/- @1%. Thus, on facts, it is observed that M/s TJR was having income generating apparatus in past and future years and was undertaking business activities. There is no definition of shell company given

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)

money of Rs. 1,50,00,000/- during F.Y. 2016-17 for purchase of a plot to build flat/apartment and paid TDS of Rs. 1,50,000/- @1%. Thus, on facts, it is observed that M/s TJR was having income generating apparatus in past and future years and was undertaking business activities. There is no definition of shell company given