DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, LUDHIANA vs. MALBROS INTERNATIONAL PVT LTD, FARIDKOT

In the result, both the appeals and the Cross Objections are dismissed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 992 & 993/Chd/2024 "नधा"रण वष" / Assessment Years: 2017-18, 2016-17 The Dcit, Vs Malbros International Pvt. Ltd., Central Circle-2, Village – Mansoorwal, Teh-Zira, Ludhiana. Head Offices Old Cantt. Road, Faridkot. "थायी लेखा सं./Pan No: Aadcm7203R अपीलाथ"/Appellant ""यथ"/Respondent & C.O. Nos. 46 & 45/Chd/2024 In आयकर अपील सं./ Ita Nos. 992 & 993/Chd/2024 "नधा"रण वष" / Assessment Year: 2017-18, 2016-17 Malbros International Pvt. Ltd., The Dcit, Village – Mansoorwal, Teh-Zira, Vs Central Circle-2, Head Offices Old Cantt. Road, Ludhiana. Faridkot. "थायी लेखा सं./Pan No: Aadcm7203R अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Sudhir Sehgal, Advocate Revenue By : Smt. Kusum Bansal, Cit Dr Date Of Hearing : 14.05.2025 Date Of Pronouncement : 25.06.2025

Section 5 of the Limitation Act should receive a liberal construction so as to advance substantial justice vide Shakuntala Devi lain Vs. Kuntal Kumari [AIR 1969 SC 575] and State of West Bengal Vs. The Administrator, Howrah Municipality [AIR 1972 SC 749]. It must be remembered that in every case of delay there can be some lapse on the part

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, LUDHIANA vs. MALBROS INTERNATIONAL PVT LTD, FARIDKOT

In the result, both the appeals and the Cross Objections\nare dismissed

Section 5 of the Limitation Act should receive a\nliberal construction so as to advance substantial\njustice vide Shakuntala Devi lain Vs. Kuntal Kumari\n[AIR 1969 SC 575] and State of West Bengal Vs. The\nAdministrator, Howrah Municipality [AIR 1972 SC\n749]. It must be remembered that in every case of\ndelay there can be some lapse

INCOME TAX OFFICER, BILASPUR vs. M/S AUSTEE HYDRO POWER & CONSTRUCTION COMPANY (P) LTD., BILASPUR

In the result, the appeal of the assessee is partly

Bench: Shri Sanjay Garg & Ms. Annapurna Guptam/S Austees Hydro Power & Vs. The Income Tax Officer, Construction Company (P) Ltd., Bilaspur Distt. Bilaspur Vpo Bahot Kasol, Tehsil Sadar, (Hp). Distt Bilaspur (Hp), Through Its Authorised Signatory Pan: Aafca8697M & The Income Tax Officer, Vs. M/S Austees Hydro Power & Bilaspur Distt. Bilaspur Construction Company (P) Ltd., (Hp). Vpo Bahot Kasol, Tehsil Sadar, Distt Bilaspur (Hp), Through Its Authorised Signatory Pan: Aafca8697M (Appellant) (Respondent)

bogus, but has also accepted that purchases to the extent of Rs.1.24 crores were made by them from Nikhil Filling station for supplying to the assessee, believing the version /statement of the manager of the filling station. The conclusion derived by the Ld.CIT(A) is clearly not sustainable. Therefore, in our view, the entire exercise of the Revenue

M/S AUSTEES HYDRO POWER & CONSTRUCTION COMPANY (P) LTD.,BILASPUR vs. INCOME TAX OFFICER, BILASPUR

In the result, the appeal of the assessee is partly

Bench: Shri Sanjay Garg & Ms. Annapurna Guptam/S Austees Hydro Power & Vs. The Income Tax Officer, Construction Company (P) Ltd., Bilaspur Distt. Bilaspur Vpo Bahot Kasol, Tehsil Sadar, (Hp). Distt Bilaspur (Hp), Through Its Authorised Signatory Pan: Aafca8697M & The Income Tax Officer, Vs. M/S Austees Hydro Power & Bilaspur Distt. Bilaspur Construction Company (P) Ltd., (Hp). Vpo Bahot Kasol, Tehsil Sadar, Distt Bilaspur (Hp), Through Its Authorised Signatory Pan: Aafca8697M (Appellant) (Respondent)

bogus, but has also accepted that purchases to the extent of Rs.1.24 crores were made by them from Nikhil Filling station for supplying to the assessee, believing the version /statement of the manager of the filling station. The conclusion derived by the Ld.CIT(A) is clearly not sustainable. Therefore, in our view, the entire exercise of the Revenue

M/S INTERNATIONAL CUSTOMER RELATED MANAGEMENT SERVICES PRIVATE LIMITED,CHANDIGARH vs. D.C.I.T., CIRCLE 6(1), MOHALI

In the result, for statistical purposes, the appeal is

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

purchased by the appellant from farmers/local residents were executed at rates which were much higher than the actual consideration paid for such land. 6.3. That the assessing officer erred on facts and in law in relying upon various ex-parte documents/ material collected behind the back of the appellant, without confronting the same to the appellant. ITA 436/CHD/2022 A.Y.2008-09 Page

M/S SHUBHAM COTTON MILLS PVT. LTD.,ELLENABAD vs. DCIT, CIRCLE, SIRSA

In the result appeal of the assessee is allowed

234B of the Act and u/s 234C of the Act is not leviable on the facts of the case. 14 In view of the aforesaid submission, it is therefore prayed that it be held that addition made by the learned Assessing Officer alongwith interest levied may kindly be deleted and appeal of the appellant company may be allowed. Should your

PAWAN GARG,PANCHKULA vs. ITO WARD 5((5) CHANDIGARH, CHANDIGARH

In the result, appeal of the assessee is allowed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 1218/Chd/2024 "नधा"रण वष" / Assessment Year: 2014-15 Shri Pawan Garg, The Ito, House No. 766, Sector 16, Vs Ward 5(5), Panchkula. Chandigarh. "थायी लेखा सं./Pan No: Abmpg4243N अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ajay Jain, Ca Revenue By : Dr. Ranjit Kaur, Addl. Cit Sr.Dr Date Of Hearing : 27.01.2026 Date Of Pronouncement : 02.02.2026

234B, 234C and 234D as per the provisions of IT. Act, 1961. Penalty proceedings u/s 271F for non-filing of ITR in respect to the notice u/s 148 of the IT. Act 1961, penalty proceedings u/s 271 (1)(b) for noncompliance of notices u/s 142(1) and penalty proceedings u/s 271(1)(c) for concealing the income or for furnishing

INCOME TAX OFFICER, WARD-2(1), CHANDIGARH, CHANDIGARH vs. ATMA RAM JEWELLERS, CHANDIGARH

In the result, appeal of the Revenue is dismissed

section 234A, B and C amounting to Rs.24,51,682/- is arbitrary\nunjustified and in the alternative is highly excessive.\n6.1 Charging interest u/s 234A, 234B and 234C is mandatory and\nconsequential in view of Hon'ble Supreme Court decision in the case of Anjum\nM.H. Ghaswala - 252 (2001) ITR 1 (SC). Since ground no 2 to 9 of appeal

M/S ASHA TECHNOLOGIES,SIRMOUR vs. ADDL. CIT, SOLAN

In the result, both the above appeals of the Assessee are partly allowed as aforesaid in respect of impugned orders dt

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

purchase of chillies. The chillies purchased by the assessee are sorted, graded as per Agmark specifications. Better quality chillies are picked up and sorted out for export and before export they are clipped and stemmed and subjected to fumigation under expert technical hands in order to prevent deterioration and with a view to give better polish and appearance and during

M/S ASHA TECHNOLOGIES,KALA AMB vs. ITO, SIRMOUR

In the result, both the above appeals of the Assessee are partly allowed as aforesaid in respect of impugned orders dt

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

purchase of chillies. The chillies purchased by the assessee are sorted, graded as per Agmark specifications. Better quality chillies are picked up and sorted out for export and before export they are clipped and stemmed and subjected to fumigation under expert technical hands in order to prevent deterioration and with a view to give better polish and appearance and during