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. ITA 146,147 & 148/CHD/2021 A.Y. 2011-12, 2015-16 & 2016-17 5 3. The sales have been confirmed meaning thereby you have purchased cotton from the open market in cash. The purchases being made in cash from open market, the applicability of provision of Section 40A

AMAN THUKRAL,LUDHIANA vs. INCOME TAX OFFICER WARD 2(1), LUDHIANA , LUDHIANA

Accordingly, Additional Ground No. 1 is allowed for statistical

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

bogus purchase without any base and reason thereof without appreciating that the said amount is very excessive and arbitrary. 3. That the Ld. CIT(A), NFAC, Delhi has failed to appreciate that the Ld. AO has wrongly made an addition of Rs. 19,33,905 u/s. 69C on account of alleged unexplained purchases from one Sumanpreet Singh completely disregarding

SH. SHER SINGH RANA,SOLAN vs. PR.CIT-1, CHANDIGARH

In the result, the appeal of the assessee is partly allowed in light of aforesaid directions

Bench: Smt.Diva Singh & Shri Vikram Singh Yadavआदेश/Order

Section 40A(3) of l.T. Act 1961.” 9 A.Y.2016-17 6. It was submitted by the Ld. AR that firstly on the issue of bogus liability for financial year 2014-15, there is no basis for arriving at such a finding by the Ld. Pr.CIT as she has failed to consider the entries in the ledger account so submitted

INCOME TAX OFFICER, LUDHIANA vs. SH SURENDER KUMAR PROP, LUDHIANA

The appeal of the Assessee is partly allowed for statistical purposes

Bench: Itat Shall Not Be Filed In Cases Where The Tax Effect Does Not Exceed The Monetary Limit Of Rs. 20 Lacs. The Tax Will Not Include Any Interest Thereon. It Is Further Clarified That If In The Case Of An Assessee, Disputed Issues Arise In More Than One Assessment Year, Appeal Can Be Filed In Respect Of Such Assessment Year Or Years In Which The Tax Effect In Respect Of Disputed Issues Exceeds The Monetary Limit So Specified.

bogus shareholders, whose names are given to the AO, then the Deptt. is free to proceed to reopen their individual assessments in accordance with law, but it cannot be regarded as undisclosed income of the assessee company. (Copy of Judgement enclosed herewith). DCIT vs Rohini Builders (2003) 182 CTR 0373,(2002) 256 ITR 0360 (High Court of Gujrat

SURINDER KUMAR,LUDHIANA vs. DCIT, LUDHIANA

The appeal of the Assessee is partly allowed for statistical purposes

Bench: Itat Shall Not Be Filed In Cases Where The Tax Effect Does Not Exceed The Monetary Limit Of Rs. 20 Lacs. The Tax Will Not Include Any Interest Thereon. It Is Further Clarified That If In The Case Of An Assessee, Disputed Issues Arise In More Than One Assessment Year, Appeal Can Be Filed In Respect Of Such Assessment Year Or Years In Which The Tax Effect In Respect Of Disputed Issues Exceeds The Monetary Limit So Specified.

bogus shareholders, whose names are given to the AO, then the Deptt. is free to proceed to reopen their individual assessments in accordance with law, but it cannot be regarded as undisclosed income of the assessee company. (Copy of Judgement enclosed herewith). DCIT vs Rohini Builders (2003) 182 CTR 0373,(2002) 256 ITR 0360 (High Court of Gujrat

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

bogus commission income. No such document has been brought to my notice by the AO or Survey Report that establishes trail of transfer of cash clandestinely to the members of the society. Hence, if there is bogus commission raised by the members of the society, Ld.AO is free to initiate action against the members in their personal capacities as they

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

bogus commission income. No such document has been brought to my notice by the AO or Survey Report that establishes trail of transfer of cash clandestinely to the members of the society. Hence, if there is bogus commission raised by the members of the society, Ld.AO is free to initiate action against the members in their personal capacities as they

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

bogus commission income. No such document has been brought to my notice by the AO or Survey Report that establishes trail of transfer of cash clandestinely to the members of the society. Hence, if there is bogus commission raised by the members of the society, Ld.AO is free to initiate action against the members in their personal capacities as they

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

bogus commission income. No such document has been brought to my notice by the AO or Survey Report that establishes trail of transfer of cash clandestinely to the members of the society. Hence, if there is bogus commission raised by the members of the society, Ld.AO is free to initiate action against the members in their personal capacities as they

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

bogus commission income. No such document has been brought to my notice by the AO or Survey Report that establishes trail of transfer of cash clandestinely to the members of the society. Hence, if there is bogus commission raised by the members of the society, Ld.AO is free to initiate action against the members in their personal capacities as they

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

bogus commission income. No such document has been brought to my notice by the AO or Survey Report that establishes trail of transfer of cash clandestinely to the members of the society. Hence, if there is bogus commission raised by the members of the society, Ld.AO is free to initiate action against the members in their personal capacities as they

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

bogus commission income. No such document has been brought to my notice by the AO or Survey Report that establishes trail of transfer of cash clandestinely to the members of the society. Hence, if there is bogus commission raised by the members of the society, Ld.AO is free to initiate action against the members in their personal capacities as they

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

bogus commission income. No such document has been brought to my notice by the AO or Survey Report that establishes trail of transfer of cash clandestinely to the members of the society. Hence, if there is bogus commission raised by the members of the society, Ld.AO is free to initiate action against the members in their personal capacities as they

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), CHANDIGARH vs. ALLIED NOVATECH PRIVATE LIMITED, CHANDIGARH

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Rajpal Yadav, Vice Presiden & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 609/Chd/2024 "नधा"रण वष" / Assessment Year : 2017-18 Deputy Allied Novatech Private Commissioner Of बनाम Limited Sco 90, Income Tax, Circle- Sector 44-C, Vs. 1(1), Chandigarh Chandigarh. "थायी लेखा सं./Pan No: Aakca2286M अपीलाथ"/Appellant ""यथ"/Respondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By: Shri Parikshit Aggarwal Ca & Ms. Shruti Khandewal, Advocate राज"व क" ओर से/ Revenue By : Shri Vivek Vardhan, Addl. Cit Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 05-06-2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 12-08-2025 आदेश/Order Per Krinwant Sahay, Am: Appeal In This Case Has Been Filed By The Revenue Against The Order Dated 22-03-2024 Of Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi.

bogus sales for generating cash in its books and subsequent deposits in bank accounts.” 2. That Ld. CIT(A)/NFAC has erred in deleting the addition of Rs. 1,83,95,000/- made by the A.O. u/s 69A in view of the facts and circumstances of the case completely ignoring the principles of Preponderance of Human Probability and circumstantial evidence

SANJEEV KUMAR RANA,ROPAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, CHANDIGARH

The appeal stands allowed in terms of our above order

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकर अपील सं. / Ita No.706/Chandi/2024 (िनधा"रण वष" / Assessment Year: 2015-16) Shri Sanjeev Kumar Rana Pr. Cit बनाम/ Vs. 93-Kiln Area, Nangal Ropar Sector -17E (Punjab) 140124. Chandigarh "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aespk-7126-B (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Parikshit Aggarwal (Ca)(Virtual) –Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit)(Virtual) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 07-10-2025 घोषणाकीतारीख /Date Of Pronouncement : 14/10/2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. By Way Of This Appeal, The Assessee Assails Invocation Of Revisionary Jurisdiction U/S 263 By Ld. Pr. Commissioner Of Income Tax, Chandigarh-1 (Pr. Cit) For The Assessment Year (Ay) 2015-16 Vide Impugned Order Dated 10-05-2023 Proposing Revision Of An Assessment As Framed By Ld. Assessing Officer [Ao] U/S.143(3) Of The Act On 12-10-2017. 2. Briefly Stated, The Assessee Was Assessed U/S 143(3) On 12-10-2017 Wherein The Income Of The Assessee Was Determined At Rs.8.79 Lacs After

40A(3). On the issue of introduction of capital, it was noted that the assessee introduced cash of Rs.174 Lacs in Sanjeev Kumar, Rajpur Bhaiyan as well as another capital of Rs.63 Lacs in Sanjeev Kumar, Chandigarh. The amount was stated to be withdrawn from M/s Raman Kumar & Co., Nangal. However, this issue was not examined during assessment proceedings. Accordingly

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