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)

survey u/s 133A of the I.T. Act, 1961 on the BPSL Group on 27.12.2012. A search & Seizure operation u/s 132 of the I.T. Act, 1961 was also conducted by the Dl(lnvestigation), Ahemedabad in the case ofSh. Shrish Chandrakant Shah(SCS) on 09.04.2013. Another search and seizure operation u/s 132(1) of the I.T. Act, 1961 was also conducted

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)

survey u/s 133A of the I.T. Act, 1961 on the BPSL Group on 27.12.2012. A search & Seizure operation u/s 132 of the I.T. Act, 1961 was also conducted by the Dl(lnvestigation), Ahemedabad in the case ofSh. Shrish Chandrakant Shah(SCS) on 09.04.2013. Another search and seizure operation u/s 132(1) of the I.T. Act, 1961 was also conducted

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)

survey u/s 133A of the I.T. Act, 1961 on the BPSL Group on 27.12.2012. A search & Seizure operation u/s 132 of the I.T. Act, 1961 was also conducted by the Dl(lnvestigation), Ahemedabad in the case ofSh. Shrish Chandrakant Shah(SCS) on 09.04.2013. Another search and seizure operation u/s 132(1) of the I.T. Act, 1961 was also conducted

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)

survey u/s 133A of the I.T. Act, 1961 on the BPSL Group on 27.12.2012. A search & Seizure operation u/s 132 of the I.T. Act, 1961 was also conducted by the Dl(lnvestigation), Ahemedabad in the case ofSh. Shrish Chandrakant Shah(SCS) on 09.04.2013. Another search and seizure operation u/s 132(1) of the I.T. Act, 1961 was also conducted

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)

survey u/s 133A of the I.T. Act, 1961 on the BPSL Group on 27.12.2012. A search & Seizure operation u/s 132 of the I.T. Act, 1961 was also conducted by the Dl(lnvestigation), Ahemedabad in the case ofSh. Shrish Chandrakant Shah(SCS) on 09.04.2013. Another search and seizure operation u/s 132(1) of the I.T. Act, 1961 was also conducted

SH. MOHINDER KUMAR,RAJPURA vs. ACIT, CIRCLE, PATIALA

In the result, all the three captioned appeals are allowed

Bench: Shri Sanjay Gargआयकर अपील सं./ Ita No. 433 /Chd/2023 "नधा"रण वष" / Assessment Year : 2018-19 बनाम Shri Mohinder Kumar, The Acit, #371, Dalima Vihar, Circle, Rajpaura 140401 Patiala Punjab "थायी लेखा सं./Pan No: Aenpk2131D अपीलाथ"/Appellant ""यथ"/Respondent

Capital Gains which is arbitrary and unjustified. 433 to 435 -Chd-2024 Mohinder Singh, Rajpura & Ors, Rajpura 3 3. That the Ld. Commissioner of Income Tax (Appeals) has further erred in upholding the denial of deduction of Rs. 3,54,788/- claimed u/s 54B which is arbitrary and unjustified. 4. That the Ld. Commissioner of Income Tax (Appeals) has further

SH. PAWAN KUMAR,RAJPURA vs. ACIT, CIRCLE, PATIALA

In the result, all the three captioned appeals are allowed

Bench: Shri Sanjay Gargआयकर अपील सं./ Ita No. 433 /Chd/2023 "नधा"रण वष" / Assessment Year : 2018-19 बनाम Shri Mohinder Kumar, The Acit, #371, Dalima Vihar, Circle, Rajpaura 140401 Patiala Punjab "थायी लेखा सं./Pan No: Aenpk2131D अपीलाथ"/Appellant ""यथ"/Respondent

Capital Gains which is arbitrary and unjustified. 433 to 435 -Chd-2024 Mohinder Singh, Rajpura & Ors, Rajpura 3 3. That the Ld. Commissioner of Income Tax (Appeals) has further erred in upholding the denial of deduction of Rs. 3,54,788/- claimed u/s 54B which is arbitrary and unjustified. 4. That the Ld. Commissioner of Income Tax (Appeals) has further

SH. SURINDER KUMAR,RAJPURA vs. ACIT, CIRCLE, PATIALA

In the result, all the three captioned appeals are allowed

Bench: Shri Sanjay Gargआयकर अपील सं./ Ita No. 433 /Chd/2023 "नधा"रण वष" / Assessment Year : 2018-19 बनाम Shri Mohinder Kumar, The Acit, #371, Dalima Vihar, Circle, Rajpaura 140401 Patiala Punjab "थायी लेखा सं./Pan No: Aenpk2131D अपीलाथ"/Appellant ""यथ"/Respondent

Capital Gains which is arbitrary and unjustified. 433 to 435 -Chd-2024 Mohinder Singh, Rajpura & Ors, Rajpura 3 3. That the Ld. Commissioner of Income Tax (Appeals) has further erred in upholding the denial of deduction of Rs. 3,54,788/- claimed u/s 54B which is arbitrary and unjustified. 4. That the Ld. Commissioner of Income Tax (Appeals) has further

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

In the result, all the above appeals are allowed

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 939/Chd/2025 निर्धारण वर्ष / Assessment Year : 2016-17 Shri Aniket Singal बनाम The DCIT 4, Amritashergil Marg, New Delhi- 110003 Central Circle-1 Chandigarh स्थायी लेखा सं./ PAN NO: CZCPS6126E अपीलार्थी/Appellant प्रत्यर्थी / Respondent आयकर अपील सं. / ITA No. 1145/Chd/2025 निर्धारण वर्ष / Assessment Year : 2017-18 Smt. Aarti Singal बनाम The DCIT 53, Jor Bagh, New Delhi-110003 Central Circle-1 Chandigarh स

survey u/s 133A 7 of the I.T. Act, 1961 on the BPSL Group on 27.12.2012. A search and seizure operation u/s 132 of the I.T. Act, 1961 was also conducted by the DI (Investigation), Ahmedabad in the case of Sh. Shrish Chandrakant Shah (SCS) on 09.04.2013. Another search and seizure operation u/s

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

In the result, all the above appeals are allowed

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 939/Chd/2025 निर्धारण वर्ष / Assessment Year : 2016-17 Shri Aniket Singal बनाम The DCIT Central Circle-1 Chandigarh 4, Amritashergil Marg, New Delhi- 110003 स्थायी लेखा सं./ PAN NO: CZCPS6126E अपीलार्थी/Appellant प्रत्यर्थी / Respondent आयकर अपील सं. / ITA No. 1145/Chd/2025 निर्धारण वर्ष / Assessment Year : 2017-18 Smt. Aarti Singal बनाम The DCIT Central Circle-1 Chandigarh 53, Jor Bagh, New Delhi-110003 स

survey u/s 133A 7 of the I.T. Act, 1961 on the BPSL Group on 27.12.2012. A search and seizure operation u/s 132 of the I.T. Act, 1961 was also conducted by the DI (Investigation), Ahmedabad in the case of Sh. Shrish Chandrakant Shah (SCS) on 09.04.2013. Another search and seizure operation u/s

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

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

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.

capital gains, nor is it income from "other sources" because the provisions of sections 69,69A, 69B and 69C treat unexplained investment, unexplained money, bullion, etc., and unexplained expenditure as deemed income where the nature and source of investment, acquisition or expenditure, as the case may be, have not been explained or satisfactorily explained, Therefore, in these cases, the source

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

133A was conducted at the premises of the assessee and detailed physical verification of the stock in possession of the assessee was made. The assessee has neither recorded the investment in stock in the books nor the assessee has explained the sources of the same during the survey and assessment proceedings. 5.7 Further, the assessee failed to provide the sources

TARLOCHAN SINGH ,BHAWANIGARH vs. DCIT, CENTRAL CIRCLE, PATIALA

In the result, the appeal of the assessee is partly allowed

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

133A of Income Tax Act 1961 the appellant surrendered the amount on following grounds. 1. Rs. 14,70,000.00 on account of capital introduced in capital account which was noticed at the time of survey. 2. Rs. 17,07,029.00 on account of excess stock found during the course of survey. 3. Rs.2,16,341.00 on account of difference

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)

capital account and Rs. 11,00,000/- in the name of M/s. Asha Telecom Pvt. Ltd. as liabilities. But it did not furnish any information regarding sources of these credits and neither any confirmation from M/s. Asha Telecom Pvt. Ltd. was furnished. Similarly, Para 8 of the questionnaire remained unanswered. Vide Para 9 of its reply, it was stated that

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)

capital account and Rs. 11,00,000/- in the name of M/s. Asha Telecom Pvt. Ltd. as liabilities. But it did not furnish any information regarding sources of these credits and neither any confirmation from M/s. Asha Telecom Pvt. Ltd. was furnished. Similarly, Para 8 of the questionnaire remained unanswered. Vide Para 9 of its reply, it was stated that

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)

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

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

survey u/s 133A\nof the I.T. Act, 1961 on the BPSL Group on 27.12.2012. A search and seizure\noperation u/s 132 of the I.T. Act, 1961 was also conducted by the DI\n(Investigation), Ahmedabad in the case of Sh. Shrish Chandrakant Shah (SCS)\non 09.04.2013. Another search and seizure operation u/s 132(1) of the I.T. Act,\n1961