DEVI DAYAL,KAITHAL vs. INCOME TAX OFFICER, WARD-1 , KAITHAL

In the result, appeal is allowed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 899/Chd/2024 "नधा"रण वष" / Assessment Year: 2008-09 Shri Devi Dayal, Vs The Ito, Pundri Anaj Mandi, Ward – 1, Kaithal-Haryana 136026. Kaithal. "थायी लेखा सं./Pan No: Aajpd5851H अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Parikshit Aggarwal, Ca & Ms. Shruti Khandelwal, Advocate Revenue By : Shri Manav Bansal, Cit, Dr Date Of Hearing : 30.07.2025 Date Of Pronouncement : 08.09.2025

condone the delay and proceed to decide the appeal on merit. 7. A perusal of the ground of appeal would reveal that assessee has taken five grounds of appeal, however, his grievance revolves around two-fold of issues, namely ; a) The ld. CIT (Appeals) has erred in upholding the re- opening of assessment, A.Y.2008-09 6 b) The ld. CIT (Appeals

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

condone the delay and proceed to decide the appeals on merit. 4. As the facts, issues and circumstances in both the appeals are identical, therefore, we take the facts mainly from ITA No. 321/CHD/2019 assessment year 2010-11. The other relevant facts from ITA 322/CHD/2019 for assessment year 2011-12 would be taken note according to requirement. 5. The assessee

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

condone the delay and proceed to decide the appeals on merit. 4. As the facts, issues and circumstances in both the appeals are identical, therefore, we take the facts mainly from ITA No. 321/CHD/2019 assessment year 2010-11. The other relevant facts from ITA 322/CHD/2019 for assessment year 2011-12 would be taken note according to requirement. 5. The assessee

SH. PAWAN GARG,LUDHIANA vs. ACIT, C-2, LUDHIANA

The appeal of the assessee stands allowed

Bench: Shri N.K. Saini & Shri Sudhanshu Srivastavaआयकर अपील सं./ Ita No. 1475/Chd/2018 "नधा"रण वष" / Assessment Year : 2014-15

delay is condoned and the appeal is admitted. 5.0 It is seen from the records that assessee is a partner in a firm engaged in the dyeing and finishing of textile yarn. The return of income was filed declaring an income of Rs. 8,11,800/-. The assessee’s case was selected for scrutiny under CASS and during the course

SH. MAHESH CHUGH,CHANDIGARH vs. PR.CIT-2, CHANDIGARH

In the result, the appeal of the assessee is allowed

delay is, accordingly, condoned. Ordered accordingly. 4. The ld. AR, accordingly, was directed to address the grievance of the assessee in the appeal filed. On behalf of the assessee, it was submitted at the outset that the assessee does not wish to specifically press ground No. 2 as the issue would stand addressed by the other grounds. ITA 104 /CHD/2021

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

The appeals are partly allowed

gain anything. Their\ndemand would become final.\nTherefore, it was not an\nintentional delay, rather due to some financial implications,\nthe appeals could not be filed within time. We condone the\ndelay and proceed to decide the appeals on merit.\n7. Both the appellants have raised an additional ground of\nappeal vide which, it has been pleaded that original\nassessment

SH. DINESH SOIN,LUDHIANA vs. ACIT, LUDHIANA

The appeals are partly allowed

gain anything. Their\ndemand would become final.\nTherefore, it was not an\nintentional delay, rather due to some financial implications,\nthe appeals could not be filed within time. We condone the\ndelay and proceed to decide the appeals on merit.\n7.\nBoth the appellants have raised an additional ground of\nappeal vide which, it has been pleaded that original\nassessment

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

The appeals are partly allowed

gain anything. Their\ndemand would become final.\nTherefore, it was not an\nintentional delay, rather due to some financial implications,\nthe appeals could not be filed within time. We condone the\ndelay and proceed to decide the appeals on merit.\n7. Both the appellants have raised an additional ground of\nappeal vide which, it has been pleaded that original\nassessment

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, LUDHIANA , LUDHIANA vs. ROSHA ALLOYS PVT. LTD., MANDI GOBINDGARH

In the result, the appeals filed by the Revenue are dismissed,\nwhereas the appeals of the assessee are allowed

long term\ncapital gain from the sale of shares, which manifests the contradiction.\nNothing more is necessary to specify as the matter is as apparent as\ncan be. Therefore, this is a clear case of issuing notices based on\ndisclosure in the existing Return of Income filed by the Assessee but on\nincorrect premise of nondisclosure. There

ROSHA ALLOYS P LIMITED, AMLOH ROAD, VILLAGE TURAN, MANDI GOBINDGARH,PUNJAB vs. DCIT CENTRAL CIRCLE 1, LUDHIANA, PUNJAB

In the result, the appeals filed by the Revenue are dismissed,\nwhereas the appeals of the assessee are allowed

long term\ncapital gain from the sale of shares, which manifests the contradiction.\nNothing more is necessary to specify as the matter is as apparent as\ncan be. Therefore, this is a clear case of issuing notices based on\ndisclosure in the existing Return of Income filed by the Assessee but on\nincorrect premise of nondisclosure. There

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, LUDHIANA , LUDHIANA vs. ROSHA ALLOYS PVT. LTD., MANDI GOBINDGARH

In the result, the appeals filed by the Revenue are dismissed,\nwhereas the appeals of the assessee are allowed

long term\ncapital gain from the sale of shares, which manifests the contradiction.\nNothing more is necessary to specify as the matter is as apparent as\ncan be. Therefore, this is a clear case of issuing notices based on\ndisclosure in the existing Return of Income filed by the Assessee but on\nincorrect premise of nondisclosure. There

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, LUDHIANA , LUDHIANA vs. ROSHA ALLOYS PVT. LTD., MANDI GOBINDGARH

In the result, the appeals filed by the Revenue are dismissed,\nwhereas the appeals of the assessee are allowed

long term\ncapital gain from the sale of shares, which manifests the contradiction.\nNothing more is necessary to specify as the matter is as apparent as\ncan be. Therefore, this is a clear case of issuing notices based on\ndisclosure in the existing Return of Income filed by the Assessee but on\nincorrect premise of nondisclosure. There

RAMA RANI,CHANDIGARH vs. DCIT,CIRCLE 1(1), CHANDIGARH, CHANDIGARH

The appeal stand allowed in terms of our above order

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No. 933/Chandi/2024 (िनधा"रणवष" / Assessment Year: 2015-16 Ms. Rama Rani Dcit बनाम/ Vs. H. No 1058, Popular Enclave Circle 1(1), Sector 48-B, Chandigarh Chandigarh. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aerpr-2072-Q (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Ravinder Krishan (Advocate)– Ld. Ar ""थ"कीओरसे/Respondent By : Sh. Rajat Kumar Kureel (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 30-06-2025 घोषणाकीतारीख /Date Of Pronouncement : 04-07-2025 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 Assessment Year (Ay) 2015-16 Vide Impugned Order Dated 14-03-2024 Proposing Revision Of Assessment As Framed By Ld. Ao U/S.147 Of The Act On 29-03-2022. The Registry Has Noted Delay Of 98 Days In The Appeal, The Condonation Of Which Has Been Sought By Ld. Ar On The Strength Of Condonation Petition Which Is Accompanied By An Affidavit Of The Assessee. It Has Been Stated That The Assessee Was Not In India When

condonation petition which is accompanied by an affidavit of the assessee. It has been stated that the assessee was not in India when the order was served by the department. The supporting documents have also been attached. Upon perusal of the same, we are of the opinion that the assessee has established sufficient cause to explain the delay and accordingly

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

gain time then ITA No.992 & 993/CHD/2024 & CO 46 & 45/CHD/2024 A.Y.2017-18 & 2016-17 6 the court should lean against acceptance of the explanation. While condoning delay the Could should not forget the opposite party altogether. It must be borne in mind that he is a looser and he too would have incurred quiet a large litigation expenses. It would

BAHADUR SINGH,ZIRAKPUR PUNJAB vs. COMMISSIONER OF INCOME TAX (APPEALS), INCOME TAX DEPARTMENT DELHI

In the result, the matter is set-aside to the file of the AO for fresh adjudication as per law after providing reasonable opportunity to the assessee

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

delay is hereby condoned and the appeal of the assessee is admitted for adjudication. 3. Briefly, the facts of the case are that the assessment was completed under section 147 r.w.s 144 r.w.s 144B of the Act vide order dt. 22/03/2022 wherein the AO brought the tax a sum of Rs. 7,60,75,592/- under Section

BAHADUR SINGH ,ZIRAKPUR vs. ITO WARD 3(5), CHANDIGARH

In the result, appeal of the Assesee is allowed for statistical purposes

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

condone the delay for which sufficient cause is shown, and admit the appeal for adjudication. 4. In the present appeal Assessee has raised the following grounds: 1. That the Ld. Commissioner of Income Tax-(Appeals) has wrongly upheld addition of Rs. 1,41,53,773 without giving any reasonable opportunity of being heard it is requested to set aside

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

condone the delay and proceed to decide the appeals on merits. 9. The facts on all vital points are common in all the three years, rather, order of ld. CIT(A) is verbatim same except variation in the dates and quantum of the additions. Therefore, for the facility of reference, we are taking up facts from ITA No. 814/Chd/2023

BAHADUR SINGH,ZIRAKPUR PUNJAB vs. COMMISSIONER OF INCOME TAX APPEALS, DELHI

The appeal of the assessee is allowed for statistical purposes

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ I.T.A. No. 571/Chd/2024 "नधा"रण वष" / Assessment Year: 2011-12

Long Term Capital Gains in the return filed u/s 148 of the 1.T. Act. 3. That the Assessing Officer has grossly erred by not accepting the agreement to sell executed with the persons to whom the Appellant had agree to sell his land as well as the Affidavits given by the purchasers. The Assessing Officer has made addition