M/S DIN DAYAL PURSOTAM LAL,SIRSA vs. PR.CIT, ROHTAK

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

bogus purchases, the theory that the transaction defies human probability cannot be applied to purchases in isolation, but has to be applied to the entire transaction in the light of documentary evidences produced by the assessee; and that where the sales are accepted as genuine, the purchases cannot be disallowed. 12.5 The decision of the Delhi Bench of the Tribunal

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

249 of Income Tax Act, which provides powers to the ld. Commissioner to condone the delay in filing the appeal before the Commissioner. Similarly, it has been used in section 5 of Indian Limitation Act, 1963. Whenever interpretation and construction of this expression has fallen for consideration before Hon’ble High Court as well as before the Hon’ble Supreme

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

249 of Income Tax Act, which provides\npowers to the 1d. Commissioner to condone the delay in filing\nthe appeal before the Commissioner. Similarly, it has been\nused in section 5 of Indian Limitation Act, 1963. Whenever\ninterpretation and construction of this expression has fallen\nfor consideration before Hon'ble High Court as well as before\nthe Hon'ble Supreme

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)

249) ITR 307 vii) Asprin Wall & Co. Ltd. Vs. CIT 2001 (251) ITR 323 viii) CIT Vs. Shri Mahesh Chnder Sharma 308 ITR 222 (2009) P&H ix) Computer Graphics case of Apex Court x) Gramphone Co. (India) ltd. Vs. Collector of Customs (2000) 1 SCC 549 xi) UOI Vs. DCM (1963) AIR 1963 SC 791 xii) Dy. Commissioner

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)

249) ITR 307 vii) Asprin Wall & Co. Ltd. Vs. CIT 2001 (251) ITR 323 viii) CIT Vs. Shri Mahesh Chnder Sharma 308 ITR 222 (2009) P&H ix) Computer Graphics case of Apex Court x) Gramphone Co. (India) ltd. Vs. Collector of Customs (2000) 1 SCC 549 xi) UOI Vs. DCM (1963) AIR 1963 SC 791 xii) Dy. Commissioner

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

In the result, appeal of the assessee is allowed

249 DEL-HC • Shri Rathi Steel Ltd. V/s Assistant Commissioner of Income Tax 104 taxmann.com 400 DEL- TRIB • Charan Singh V/s Income Tax Officer ITA NO.906/ASR/2018 ASR-TRIB • Commissioner of Income Tax V/s Naveen Chander 323 ITR 49 P&H-HC • Monika Rani V/s The Income Tax Officer ITA NO.582/CHD/2019 CHD-TRIB • Gaurav Joshi V/s The Income Tax Officer

M/S MANAV MANGAL SOCIETY,CHANDIGARH vs. DCIT, C-1, (E), CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

249 ITR 533, Bombay High Court ii. CIT Vs. Fr. Mullers Chartiable Institutions (2014) 363 ITR 230, Karnataka High Court iii. The above said view is further fortified by the Circular No.387, dated 6th of July, 1999, in which,it has been held as under:- Therefore, under such circumstances, taxing of entire surplus as per income and expenditure account

M/S MANAV MANGAL SOCIETY,CHANDIGARH vs. DCIT, C-1, (E), CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

249 ITR 533, Bombay High Court ii. CIT Vs. Fr. Mullers Chartiable Institutions (2014) 363 ITR 230, Karnataka High Court iii. The above said view is further fortified by the Circular No.387, dated 6th of July, 1999, in which,it has been held as under:- Therefore, under such circumstances, taxing of entire surplus as per income and expenditure account

DCIT,CIRCLE-1(EXEMPTION), CHANDIGARH vs. M/S MANAV MANGAL SCHOOL( MANAV MANGAL SOCIETY), CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

249 ITR 533, Bombay High Court ii. CIT Vs. Fr. Mullers Chartiable Institutions (2014) 363 ITR 230, Karnataka High Court iii. The above said view is further fortified by the Circular No.387, dated 6th of July, 1999, in which,it has been held as under:- Therefore, under such circumstances, taxing of entire surplus as per income and expenditure account

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

249 ITR 533, Bombay High Court ii. CIT Vs. Fr. Mullers Chartiable Institutions (2014) 363 ITR 230, Karnataka High Court iii. The above said view is further fortified by the Circular No.387, dated 6th of July, 1999, in which,it has been held as under:- Therefore, under such circumstances, taxing of entire surplus as per income and expenditure account

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

249 ITR 533, Bombay High Court ii. CIT Vs. Fr. Mullers Chartiable Institutions (2014) 363 ITR 230, Karnataka High Court iii. The above said view is further fortified by the Circular No.387, dated 6th of July, 1999, in which,it has been held as under:- Therefore, under such circumstances, taxing of entire surplus as per income and expenditure account

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

249 ITR 533, Bombay High Court ii. CIT Vs. Fr. Mullers Chartiable Institutions (2014) 363 ITR 230, Karnataka High Court iii. The above said view is further fortified by the Circular No.387, dated 6th of July, 1999, in which,it has been held as under:- Therefore, under such circumstances, taxing of entire surplus as per income and expenditure account

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

249 ITR 533, Bombay High Court ii. CIT Vs. Fr. Mullers Chartiable Institutions (2014) 363 ITR 230, Karnataka High Court iii. The above said view is further fortified by the Circular No.387, dated 6th of July, 1999, in which,it has been held as under:- Therefore, under such circumstances, taxing of entire surplus as per income and expenditure account

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

249 ITR 533, Bombay High Court ii. CIT Vs. Fr. Mullers Chartiable Institutions (2014) 363 ITR 230, Karnataka High Court iii. The above said view is further fortified by the Circular No.387, dated 6th of July, 1999, in which,it has been held as under:- Therefore, under such circumstances, taxing of entire surplus as per income and expenditure account

SHRI SATISH SOIN,LUDHIANA vs. ACIT, CC-II, LUDHIANA

In the result, appeal of the assessee is allowed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 303/Chd/2019 "नधा"रण वष" / Assessment Year : 2012-13 Shri Satish Soin, बनाम The Acit, House No.31, Garden Enclave, Central Circle-2, Vs South City-Ii, Ludhiana. Ludhiana. "थायी लेखा सं./Pan /Tan No: Advps6254N अपीलाथ"/Appellant ""यथ"/Respondent "नधा"रती क" ओर से/Assessee By : Shri Ashwani Kumar & Ms. Muskan Garg, Cas राज"व क" ओर से/ Revenue By : Smt. Kusum Bansal, Cit Dr तार"ख/Date Of Hearing : 26.05.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 23.07.2025 Hybrid Hearing आदेश/Order Per Rajpal Yadav, Vp

bogus Long Term Capital Gain earned on alleged purchase and sale of a penny stock. 8. We have duly considered the rival contentions and gone through the record carefully. We find that issues agitated in this appeal are verbatim same, therefore, for the facility of reference, we take note of our order passed in ITA 306/CHD/2019 and other appeals, which

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, LUDHIANA , LUDHIANA vs. AVINASH SINGLA, KHANNA

In the result, all the appeals of the Revenue are dismissed

Bench: Shri Rajpal Yaday & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 814 & 815/Chd/2023 "नधा"रण वष" / Assessment Years :2013-14 & 2014-15 Dcit, Vs. Avinash Singla, Central Circle-1, बनाम C-47, C.O Avinash Ludhiana Industries, Focal Point, Khanna "थायी लेखा सं./Pan No. Acypk9591N अपीलाथ"/Appellant ""यथ"/Respondent & आयकर अपील सं./ Ita No. 15/Chd/2024 "नधा"रण वष" / Assessment Year : 2014-15 Dcit, Vs. Meenu Singla, बनाम Central Circle-1, C-47, C.O Avinash Ludhiana Industries, Focal Point, Khanna "थायी लेखा सं./Pan No.Afips6556G अपीलाथ"/Appellant ""यथ"/Respondent

249 of Income Tax Act, which provides powers to the ld. Commissioner to condone the delay in filing the appeal before the Commissioner. Similarly, it has been used in section 5 of Indian Limitation Act, 1963. Whenever interpretation and construction of this expression has fallen for consideration before Hon’ble High Court as well as before the Hon’ble Supreme

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, LUDHIANA , LUDHIANA vs. AVINASH SINGLA, KHANNA

In the result, all the appeals of the Revenue are dismissed

249 of Income Tax Act,\nwhich provides powers to the ld. Commissioner to condone the delay\nin filing the appeal before the Commissioner. Similarly, it has been\nused in section 5 of Indian Limitation Act, 1963. Whenever\ninterpretation and construction of this expression has fallen for\nconsideration before Hon'ble High Court as well as before the Hon'ble\nSupreme

SMT. GINNY SOIN,LUDHIANA vs. ACIT, CC-II, LUDHIANA

The appeals are partly allowed

249 of Income Tax Act,\nwhich provides powers to the ld. Commissioner to condone\nthe delay in filing the appeal before the Commissioner.\nSimilarly, it has been used in section 5 of Indian Limitation\nAct, 1963. Whenever interpretation and construction of this\nexpression has fallen for consideration before Hon'ble High\nCourt as well as before the Hon'ble Supreme