SANJEEV KUMAR GOYAL,FATEHABAD vs. DCIT, CC-2, LUDHIANA

In the result, the appeal of the assesse is allowed

Bench: This Hon’Ble Tribunal Under Section 253 Of The Income Tax Act, 1961 As Amended From Time To Time. 2. The Assessee Is Aggrieved By The Order Of The Ld. Cit(A) Dt. 20/01/2023 In Appeal No. 10853/2018-19/It/Cit(A)-5/Ldh/2021-22 For The A.Y. 2019-20 Under Section 250(6) Of The Income Tax Act, 1961 Which Was Dismissed. Therefore The Present Second Appeal Under Section 253 Of The Income Tax Act, 1961 Before Us Against The Aforesaid Order Dt. 20/01/2023 Which Is Hereinafter Referred To As The Impugned Order.

69A and 69C being treated separately, because such deemed income is not income from salary, house property, profits and gains of business or profession, or capital gains, nor is it income from 'other sources' because the provisions of sections

SH. KRISHAN KUMAR,KHANNA vs. DCIT, CC-1, LUDHIANA

In the result, the appeal of the Assessee is allowed

Bench: Shri A.D. Jain & Shri Vikram Singh Yadav

69A, excess stock is covered u/s 69 or 69B, construction of Shed/Godown is covered u/s 69B or 69C and advances made to Sundry Parties is covered u/s 69, 69B or 69D is like an open ended hypothesis which is not supported by any specific finding that the matter shall fall under which of the specific sections and how the conditions

AJMER SINGH,MOHALI vs. ITO, W-6(5), MOHAL

In the result, the appeal of the Revenue is dismissed

Bench: Disposal Of Appeal.”

capital gain. The rest of amount of Rs 2,03,92,500/- was considered as unexplained cash for which the assessee had failed to offer satisfactory explanation and he accordingly added the same into the income of the assessee u/s 69A of the Act. Assessee filed an appeal against the said order before CIT(A). The Ld. CIT(A) after

ITO, W-6(5), MOHALI vs. SMT. GURDEV KAUR, KHARAR

In the result, the appeal of the Revenue is dismissed

Bench: Disposal Of Appeal.”

capital gain. The rest of amount of Rs 2,03,92,500/- was considered as unexplained cash for which the assessee had failed to offer satisfactory explanation and he accordingly added the same into the income of the assessee u/s 69A of the Act. Assessee filed an appeal against the said order before CIT(A). The Ld. CIT(A) after

AJMER SINGH,MOHALI vs. ITO, W-6(5), MOHAL

In the result, the appeal of the Revenue is dismissed

Bench: Disposal Of Appeal.”

capital gain. The rest of amount of Rs 2,03,92,500/- was considered as unexplained cash for which the assessee had failed to offer satisfactory explanation and he accordingly added the same into the income of the assessee u/s 69A of the Act. Assessee filed an appeal against the said order before CIT(A). The Ld. CIT(A) after

M/S SATWANT AGRO ENGINEERS,BHAWANIGARH vs. DCIT, CENTRAL CIRCLE, PATIALA

In the result, the appeal of the assessee is partly allowed for statistical purposes

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

69A and 69C being treated separately, because such deemed income is not income from salary, house property, profits and gains of business or profession, or capital gains, nor is it income from 'other sources' because the provisions of sections

RAJIV KUMAR GOYAL,DHURI vs. DCIT, CC-2, LUDHIANA

In the result, the appeal of the assessee is allowed

Bench: This Hon’Ble Tribunal Under Section 253 Of The Income Tax Act, 1961 As Amended From Time To Time. 2. The Assessee Is Aggrieved By Order Of The Ld. Cit(A) Dated 03/02/2023 In Appeal No. 10850/2018-19/It/Cit(A)-5/Ldh/2021-22 For A.Y. 2019-20 Under Section 250(6) Of The Income Tax Act, 1961 Which Was Dismissed. Therefore The Present Second Appeal Under Section 253 Of The Income Tax Act, 1961 Before Us Against The Aforesaid Order Dt. 03/02/2023 Which Is Hereiafter Referred To As The Impugned Order. Factual Matrix 3. The Assessee Had For The Relevant Year I.E; A.Y. 2019-20 Was Also Engaged In The Same Business I.E; Manufacturing Of Pvc Pipes & Had Filed

69A, 69B and 69C being treated separately, because such deemed income is not income from salary, house property, profits and gains of business or profession, or capital gains, nor as it income from "other sources" because the provisions of section

SMT. TEENA GARG,CHANDIGARH vs. PCIT, PANCHKULA

In the result, appeal of the assessee is allowed

section 10\nbeing not liable to capital gain as the shares sold after 31/01/2018\nare liable to tax by applying Face Value as on 31/01/2018 &\nDepartment contention of Long Term Capital Gain of Rs.60,65,724/-\nis totally incorrect.\n\nNote: (Through assessee in this reply aired grievance about reasons\nfor reopening, source of information, complete proposal under\nsection

RAV SHARAN SINGH,PATIALA vs. ACIT, C.C., PATIALA

In the result, appeal of the assessee is allowed

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

69A, excess stock is covered u/s 69 or 69B, construction of Shed/Godown is covered u/s 69B or 69C and advances made to Sundry Parties is covered u/s 69, 69B or 69D is like an open ended hypothesis which is not supported by any specific finding that the matter shall fall under which of the specific sections and how the conditions

M/S JASHAN FINLEASE LTD.,KHANNA vs. DCIT, CC-1, LUDHIANA

In the result, the appeal of the assessee is allowed

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

69A, excess stock is covered u/s 69 or 69B, construction of Shed/Godown is covered u/s 69B or 69C and advances made to Sundry Parties is covered u/s 69, 69B or 69D is like an open ended hypothesis which is not supported by any specific finding that the matter shall fall under which of the specific sections and how the conditions

PREM SINGH,CHAMBA vs. ACIT CIRCLE PALAMPUR, PALAMPUR

In the result, the appeal for AY 2017-18 stands partly allowed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No. 946/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2015-16) & 2. आयकर अपील सं. / Ita No. 947/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2017-18) Shri Prem Singh Dcit Circle, Palampur बनाम/ The Palace. Chamba Himachal Pradesh - 176061 Vs. Himachal Pradesh – 176310 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aampr-8876-P (अपीलाथ"/Appellant) : (""थ" / Respondent) Assessee By : Shri Ajay Jain (Ca) – Ld. Ar Revenue By : Shri Bharat Bhushan Garg (Cit) (Virtual) - Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 13-11-2025 घोषणाकीतारीख /Date Of Pronouncement : 13-01-2026 आदेश / O R D E R Manoj Kumar Aggarwal () 1. The Assessee Is In Further Appeals Before Us For Assessment Years (Ay) 2015-16 & 2017-18 Which Arises Out Of Separate Orders Of Learned First Appellate Authority. First, We Take Up Appeal For Assessment Year (Ay) 2015-16 Which Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), Nfac [Cit(A)] Dated 22-07-2025 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S 143(3) Of The Act On 29-12-2017. The Assessee Is Aggrieved By Computation Of Capital

section 54 since the assessee did not attend and comply with the show case notice issued by the AO on 26/12 for 28/12. 6. On the facts and in the circumstances of the case and in law the assessing officer was incorrect and unjustified in rejecting the claim of the assessee for exemption of long term capital gain without providing

MRS. KIRAN BALA,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the appeal is allowed

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

69A, excess stock is covered u/s 69 or 69B, construction of Shed/Godown is covered u/s 69B or 69C and advances made to Sundry Parties is covered u/s 69, 69B or 69D is like an open ended hypothesis which is not supported by any specific finding that the matter shall fall under which of the specific sections and how the conditions

M/S VEER ENTERPRISES,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the appeal is allowed

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

69A, excess stock is covered u/s 69 or 69B, construction of Shed/Godown is covered u/s 69B or 69C and advances made to Sundry Parties is covered u/s 69, 69B or 69D is like an open ended hypothesis which is not supported by any specific finding that the matter shall fall under which of the specific sections and how the conditions

JOINT COMMISSIONER OF INCOME TAX (OSD), LUDHIANA vs. M/S SHEETAL INDUSTRIES , KHANNA

The appeal of the Revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahay

69A, excess stock is covered u/s 69 or 69B, construction of Shed/Godown is covered u/s 69B or 69C and advances made to Sundry Parties is covered u/s 69, 69B or 69D is like an open ended hypothesis which is not supported by any specific finding that the matter shall fall under which of the specific sections and how the conditions

BALDEEP SINGH,CHANDIGARH vs. ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-5(1), CHANDIGARH, CHANDIGARH

In the result, Assessee’s appeal is allowed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 199/Chd/2025 "नधा"रण वष" / Assessment Year : 2012-13 Baldeep Singh, The Acit, C/O Tej Mohan Singh, बनाम Circle 5(1), Advocate Chandigarh Vs. #527, Sector 10-D. Chandigarh "थायी लेखा सं./Pan No: Adyps3636F अपीलाथ"/Appellant ""यथ"/Respondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : Sh. Tej Mohan Singh, Advocate राज"व क" ओर से/ Revenue By : Sh. Vivek Varadhan, Addl. Cit, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 03.07.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 03.09.2025 आदेश/Order Per Krinwant Sahay, Am: Appeal In This Case Has Been Filed By The Assessee Against The Order Dated 10.01.2025 Of Addl./Jcit(A)-1. Nagpur For The A.Y. 2012-13. 2. Grounds Of Appeal Are As Under: -

Section 69A treating the entire sale price of 10,000 units of VMS Industries Limited to be income of the assessee in utter disregard of the explanations rendered and as such the 199-Chd-2025 Baldeep Singh, Chandigarh 3 addition upheld is illegal, arbitrary and unjustified. 5. That the Ld. Commissioner of Income Tax (Appeals) has failed to appreciate that

M/S AMARJIT & SONS,LUDHIANA vs. DCIT, CC-2, LUDHIANA

In the result, appeal of the assessee is allowed

Bench: The Ld. Cit(A) Have Not Been Appreciated.

capital gains’ and (v) ‘income from other sources’ – cannot at all be adjusted against unexplained investment or expenditure. What is necessary as per Hon. Gujarat High Court is that source of acquisition of asset or expenditure should be clearly identifiable. In the case before Hon. Gujarat High Court the source of gold confiscated was not identifiable and hence adjustment

SH. GURINDER MAKKAR,LUDHIANA vs. DCIT, CC-3, LUDHIANA

In the result, the appeal of the assessee is disposed off in light of aforesaid directions

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

capital gains’ and (v) ‘income from other sources’ – cannot at all be adjusted against unexplained investment or expenditure. What is necessary as per Hon. Gujarat High Court is that source of acquisition of asset or expenditure should be clearly identifiable. In the case before Hon. Gujarat High Court the source of gold confiscated was not identifiable and hence adjustment

M/S A.P. KNIT FAB,LUDHIANA vs. DCIT CC-3, LUDHIANA

In the result, the appeal of the assessee is allowed

Bench: The Ld. Cit(A) Have Not Been Appreciated. 4. That The Ld. Cit(A) Has Failed To Appreciate That During The Course Of Survey, No Other Income Was Noticed By The Department And, As Such, Taxing The Amount Offered As Deemed Income, Is Against The Facts & Circumstances Of The Case. 5. That The Ld. Cit(A) Has Also Failed To Appreciate That At The Time Of Survey, It Was Agreed That The Applicant Shall Pay The Taxes On The Amount Offered

capital gains’ and (v) ‘income from other sources’ – cannot at all be adjusted against unexplained investment or expenditure. What is necessary as per Hon. Gujarat High Court is that source of acquisition of asset or expenditure should be clearly identifiable. In the case before Hon. Gujarat High Court the source of gold confiscated was not identifiable and hence adjustment