SH. SANJAY SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-

3 SCC178, the Hon'ble S.C. has clearly held that statements recorded by the ED cannot be termed to be statements that are recorded during the course of a judicial proceedings to enable their utilisation in Income Tax Act proceedings. This is because the statements recorded by the ED do not have the procedural safeguards that exist under the CrPC

SH. SANJAY SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-

3 SCC178, the Hon'ble S.C. has clearly held that statements recorded by the ED cannot be termed to be statements that are recorded during the course of a judicial proceedings to enable their utilisation in Income Tax Act proceedings. This is because the statements recorded by the ED do not have the procedural safeguards that exist under the CrPC

SMT. AARTI SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-

3 SCC178, the Hon'ble S.C. has clearly held that statements recorded by the ED cannot be termed to be statements that are recorded during the course of a judicial proceedings to enable their utilisation in Income Tax Act proceedings. This is because the statements recorded by the ED do not have the procedural safeguards that exist under the CrPC

SH. SANJAY SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-

3 SCC178, the Hon'ble S.C. has clearly held that statements recorded by the ED cannot be termed to be statements that are recorded during the course of a judicial proceedings to enable their utilisation in Income Tax Act proceedings. This is because the statements recorded by the ED do not have the procedural safeguards that exist under the CrPC

SMT. AARTI SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-

3 SCC178, the Hon'ble S.C. has clearly held that statements recorded by the ED cannot be termed to be statements that are recorded during the course of a judicial proceedings to enable their utilisation in Income Tax Act proceedings. This is because the statements recorded by the ED do not have the procedural safeguards that exist under the CrPC

SMT. AARTI SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-

3 SCC178, the Hon'ble S.C. has clearly held that statements recorded by the ED cannot be termed to be statements that are recorded during the course of a judicial proceedings to enable their utilisation in Income Tax Act proceedings. This is because the statements recorded by the ED do not have the procedural safeguards that exist under the CrPC

SH. SANJAY SINGAL HUF,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-

3 SCC178, the Hon'ble S.C. has clearly held that statements recorded by the ED cannot be termed to be statements that are recorded during the course of a judicial proceedings to enable their utilisation in Income Tax Act proceedings. This is because the statements recorded by the ED do not have the procedural safeguards that exist under the CrPC

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

70,120/-. A notice under Section 143(2) was issued and served upon the assessee. Thereafter ld. AO has passed an assessment order under Section 153A read with Section 143(3) of the Income Tax Act on 31.03.2015. Since no incriminating material was found during the course of search, therefore, no addition was made by the AO except Rs.25

ANIKET SINGAL,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH, CHANDIGARH

In the result, assessee’s appeals are allowed

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

Section 69C of the Act, on account of alleged unaccounted commission paid by the assessee at the rate of 6.5% for the purpose of earning Long Term Capital Gains. 9.1 We find from the record that the entire addition has been made by the Assessing Officer on the basis of the same arguments, information, evidence including findings of search

SANJAY SINGAL,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH, CHANDIGARH

In the result, assessee’s appeals are allowed

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

Section 69C of the Act, on account of alleged unaccounted commission paid by the assessee at the rate of 6.5% for the purpose of earning Long Term Capital Gains. 9.1 We find from the record that the entire addition has been made by the Assessing Officer on the basis of the same arguments, information, evidence including findings of search

SANJAY SINGAL (HUF),NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH , CHANDIGARH

In the result, assessee’s appeals are allowed

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

Section 69C of the Act, on account of alleged unaccounted commission paid by the assessee at the rate of 6.5% for the purpose of earning Long Term Capital Gains. 9.1 We find from the record that the entire addition has been made by the Assessing Officer on the basis of the same arguments, information, evidence including findings of search

AARTI SINGAL,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH, CHANDIGARH

In the result, assessee’s appeals are allowed

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

Section 69C of the Act, on account of alleged unaccounted commission paid by the assessee at the rate of 6.5% for the purpose of earning Long Term Capital Gains. 9.1 We find from the record that the entire addition has been made by the Assessing Officer on the basis of the same arguments, information, evidence including findings of search

AARTI SINGAL,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH, CHANDIGARH

In the result, assessee’s appeals are allowed

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

Section 69C of the Act, on account of alleged unaccounted commission paid by the assessee at the rate of 6.5% for the purpose of earning Long Term Capital Gains. 9.1 We find from the record that the entire addition has been made by the Assessing Officer on the basis of the same arguments, information, evidence including findings of search

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

In the result, the appeal of the Revenue is dismissed

Bench: Disposal Of Appeal.”

3. The land in question is purely agriculture land and does not attract any capital gain as the agricultural land is not a capital assets (I am enclosing a copy of certificate issued by revenue authority in this regard at "A "). The difference amount of registration does not matter as the whole sale proceed is non-taxable. Since

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

In the result, the appeal of the Revenue is dismissed

Bench: Disposal Of Appeal.”

3. The land in question is purely agriculture land and does not attract any capital gain as the agricultural land is not a capital assets (I am enclosing a copy of certificate issued by revenue authority in this regard at "A "). The difference amount of registration does not matter as the whole sale proceed is non-taxable. Since

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

In the result, the appeal of the Revenue is dismissed

Bench: Disposal Of Appeal.”

3. The land in question is purely agriculture land and does not attract any capital gain as the agricultural land is not a capital assets (I am enclosing a copy of certificate issued by revenue authority in this regard at "A "). The difference amount of registration does not matter as the whole sale proceed is non-taxable. Since

SHRI ABHISHEK SOIN,LUDHIANA vs. DCIT, CC-II, LUDHIANA

The appeals are partly allowed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 321 & 322/Chd/2019 "नधा"रण वष" / Assessment Year: 2010-11, 2011-12 Shri Abhishek Soin, The Dcit, C/O Sigma Cartons Pvt. Ltd., Vs Central Circle-Ii, Unit-Ii, Industrial Area-C, Ludhiana. Sua Road, Ludhiana. "थायी लेखा सं./Pan No: Anbps9446A अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Aditya Kumar, Ca Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 03.06.2025 Date Of Pronouncement : 29.07.2025 Hybrid Hearing O R D E R

70,120/-. A notice under Section 143(2) was issued and served upon the assessee. Thereafter ld. AO has passed an assessment order under Section 153A read with Section 143(3) of the Income Tax Act on 31.03.2015. Since no incriminating material was found during the course of search, therefore, no addition was made by the AO except Rs.25

SHRI ABHISHEK SOIN,LUDHIANA vs. DCIT, CC-II, LUDHIANA

The appeals are partly allowed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 321 & 322/Chd/2019 "नधा"रण वष" / Assessment Year: 2010-11, 2011-12 Shri Abhishek Soin, The Dcit, C/O Sigma Cartons Pvt. Ltd., Vs Central Circle-Ii, Unit-Ii, Industrial Area-C, Ludhiana. Sua Road, Ludhiana. "थायी लेखा सं./Pan No: Anbps9446A अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Aditya Kumar, Ca Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 03.06.2025 Date Of Pronouncement : 29.07.2025 Hybrid Hearing O R D E R

70,120/-. A notice under Section 143(2) was issued and served upon the assessee. Thereafter ld. AO has passed an assessment order under Section 153A read with Section 143(3) of the Income Tax Act on 31.03.2015. Since no incriminating material was found during the course of search, therefore, no addition was made by the AO except Rs.25