INCOME TAX OFFICER , PATIALA vs. SH. SEWA SINGH, PATIALA

In the result the appeal of the Revenue is dismissed

Bench: Dr Krinwant Sahay & Shri Paresh M. Joshiआयकर अपील सं./ Ita No. 696/Chd/2023 "नधा"रण वष" / Assessment Year: 2018-19 The Ito, Vs. Shri Sewa Singh, बनाम H. No. B-27,Focal Point, Patiala Patiala 147001 "थायी लेखा सं./Pan No: Abjpj5347B अपीलाथ"/ Appellant ""यथ"/ Repsondent ( Virtual Hearing ) "नधा"रती क" ओर से/Assessee By : None राज"व क" ओर से/ Revenue By : Shri Rahul Sohu, Jcit, Sr. Dr सुनवाई क" तार"ख/Date Of Hearing : 02.07.2024 उदघोषणा क" तार"ख/Date Of Pronouncement : 02 .07.2024 आदेश/Order

02 .07.2024 आदेश/Order Per Dr. Krinwant Sahay, A.M.: Appeal in this case has been filed by the Revenue against the order dated 29.07.2020 of the ld. Commissioner of Income Tax (Appeals), Patiala [herein referred to as ’the CIT(A)]. 2. Grounds of appeal are as under: - 1. Whether on the facts & in the circumstances of the case

SH. DINESH SOIN,LUDHIANA vs. ACIT, LUDHIANA

The appeals are partly allowed

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 order passed under Section 153A read with\nSection

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

The appeals are partly allowed

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 order passed under Section 153A read with\nSection

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

The appeals are partly allowed

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 order passed under Section 153A read with\nSection

RUPINDER KAUR,KHAMANO, FATEHGARH SAHIB vs. INCOME TAX OFFICER, INCOME TAX OFFICER, WARD SIRHIND

In the result, appeal of the Assessee is dismissed\n"आर

section 115BBE\nare not at all applicable as all the cash deposits\nare duly explainable and out of legitimate and\ngenuine sources of the assessee.\n7. That the appellant craves leave to add OR\namend the grounds of appeal before the appeal\nis finally heard and disposed off.\n3. At the outset, it has been pointed

DCIT, C-1(1) , CHANDIGARH vs. M/S FIDELITY INFORMATION SERVICES INDIA PVT. LTD., CHANDIGARH

In the result, the cross-objection filed by the assessee is dismissed

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

02,69,448 Service Foreign travelling The Hon'ble Tribunal agreement dated expenditure disallowed remanded the issue April 15, 2002 alleging that the back to the DRP, Delhi entered with Respondent is not to pass a speaking Second required to incur foreign order, proceedings yet Foundation Inc., travelling expenses. to be initiated by the USA DRP (copy of order

SHRI TEK CHAND,KARNAL vs. ITO-WARD-2, KAITHAL

In the result, appeal of the assessee is allowed

Bench: 02-04-2020. That The Appellant Prepared Appeal & Deposited Appeal Fee On 18-03-2020 As Per Challan Of Appeal Fee Attached With Appeal Form.

02-04-2020. That The Appellant prepared Appeal and deposited Appeal fee on 18-03-2020 as per challan of Appeal fee attached with Appeal form. That Appeal could not be receipted in the office of ITAT due to COVID-19 LOCKDOWN as all the Govt, offices were closed. That further appeal was sent by speed post

ACIT, CIRCLE 1(1), CHANDIGARH vs. M/S SML ISUZU LTD., CHANDIGARH

In the result, the appeal of the Revenue is hereby dismissed

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

Delay of 09 days condoned by consent of both the parties. Appeal then taken up for final hearing. Factual Matrix 4. The assessee is engaged in the business of manufacturing of commercial vehicles. The assessee e-filed its original return of income for A.Y. 2016-17 on 30.11.2016 declaring total income

JAGJIT SINGH ,PATIALA vs. INCOME TAX OFFICER, WARD-2, PATIALA , PATIALA

In the result we set aside the impugned order and remand the case back to the file of Ld

Bench: This Tribunal. The Assessee Is Aggrieved By The Order Bearing No. Itba/Nfac/S/250/2023- 24/1058720011(1) Dt. 13/12/2023 Of The Ld. Cit(A) Passed Under Section 250 Of The Act Which Is Hereinafter Referred To As The “Impugned Order”. The Relevant Assessment Year Is 2011-12 & The Corresponding Previous Year Period Is From 01/04/2010 To 31/03/2011. 2. Factual Matrix

02 05.2018 I I 05.20 18 Served but uncomplied with Penalty notice u/s 17.05.2018 25 05.2018 -do- 271(1)(b) Opportunity letter 04 06.2018 11 06.2018 -do- Show cause to penalty u/s 22 06 2018 28 06.2018 -do- 27l(1)(b) Notice u/s 142(1) 19.07.2018 26.07.2018 -do- Notice u/s 142(1) 06.08.2018 13.08.2018 -do- Notice

SH. SHAMSHER SINGH,PATIALA vs. ACIT, CENTRAL CIRCLE-2, CHANDIGARH

In the result, the appeals of the assessees stand allowed

Bench: Shri Sanjay Garg & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 381 & 382/Chd/2022 "नधा"रण वष" / Assessment Years: 2009-10 & 2011-12 Shamsher Singh, Vs. The Acit बनाम Central Circle-2, 11-A, Gen Chanda Singh Chandigarh Colony, Patiala 147001 "थायी लेखा सं./Pan No: Ahjps3586P अपीलाथ"/ Appellant ""यथ"/ Repsondent & आयकर अपील सं./ Ita Nos. 383 & 384/Chd/2023 "नधा"रण वष" / Assessment Years: 2009-10 & 2011-12 Vs. The Acit Saranjit Singh, बनाम Centralcircle-2, 11-A, Gen Chanda Chandigarh Singh Colony, Patiala 147001 "थायी लेखा सं./Pan No: Amwps9575J अपीलाथ"/ Appellant ""यथ"/ Repsondent ( Hybrid Hearing )

delay is condoned and we proceed to hear the appeals on merits. Since the facts and issue involved in the captioned appeals are 4. identical and are relating to same search action, therefore, these captioned appeals were heard together and are disposed of with this 381-382 & 383-384-Chd-2022 Shamsher Singh & Saranjit Singh, Patiala 3 common order. First

SH. SHAMSHER SINGH,PATIALA vs. ACIT, CENTRAL CIRCLE-2, CHANDIGARH

In the result, the appeals of the assessees stand allowed

Bench: Shri Sanjay Garg & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 381 & 382/Chd/2022 "नधा"रण वष" / Assessment Years: 2009-10 & 2011-12 Shamsher Singh, Vs. The Acit बनाम Central Circle-2, 11-A, Gen Chanda Singh Chandigarh Colony, Patiala 147001 "थायी लेखा सं./Pan No: Ahjps3586P अपीलाथ"/ Appellant ""यथ"/ Repsondent & आयकर अपील सं./ Ita Nos. 383 & 384/Chd/2023 "नधा"रण वष" / Assessment Years: 2009-10 & 2011-12 Vs. The Acit Saranjit Singh, बनाम Centralcircle-2, 11-A, Gen Chanda Chandigarh Singh Colony, Patiala 147001 "थायी लेखा सं./Pan No: Amwps9575J अपीलाथ"/ Appellant ""यथ"/ Repsondent ( Hybrid Hearing )

delay is condoned and we proceed to hear the appeals on merits. Since the facts and issue involved in the captioned appeals are 4. identical and are relating to same search action, therefore, these captioned appeals were heard together and are disposed of with this 381-382 & 383-384-Chd-2022 Shamsher Singh & Saranjit Singh, Patiala 3 common order. First

SH. SARANJIT SINGH,PATIALA vs. ACIT, CENTRAL CIRCLE -2, CHANDIGARH

In the result, the appeals of the assessees stand allowed

Bench: Shri Sanjay Garg & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 381 & 382/Chd/2022 "नधा"रण वष" / Assessment Years: 2009-10 & 2011-12 Shamsher Singh, Vs. The Acit बनाम Central Circle-2, 11-A, Gen Chanda Singh Chandigarh Colony, Patiala 147001 "थायी लेखा सं./Pan No: Ahjps3586P अपीलाथ"/ Appellant ""यथ"/ Repsondent & आयकर अपील सं./ Ita Nos. 383 & 384/Chd/2023 "नधा"रण वष" / Assessment Years: 2009-10 & 2011-12 Vs. The Acit Saranjit Singh, बनाम Centralcircle-2, 11-A, Gen Chanda Chandigarh Singh Colony, Patiala 147001 "थायी लेखा सं./Pan No: Amwps9575J अपीलाथ"/ Appellant ""यथ"/ Repsondent ( Hybrid Hearing )

delay is condoned and we proceed to hear the appeals on merits. Since the facts and issue involved in the captioned appeals are 4. identical and are relating to same search action, therefore, these captioned appeals were heard together and are disposed of with this 381-382 & 383-384-Chd-2022 Shamsher Singh & Saranjit Singh, Patiala 3 common order. First

SH. SARANJIT SINGH,PATIALA vs. ACIT, CENTRAL CIRCLE -2, CHANDIGARH

In the result, the appeals of the assessees stand allowed

Bench: Shri Sanjay Garg & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 381 & 382/Chd/2022 "नधा"रण वष" / Assessment Years: 2009-10 & 2011-12 Shamsher Singh, Vs. The Acit बनाम Central Circle-2, 11-A, Gen Chanda Singh Chandigarh Colony, Patiala 147001 "थायी लेखा सं./Pan No: Ahjps3586P अपीलाथ"/ Appellant ""यथ"/ Repsondent & आयकर अपील सं./ Ita Nos. 383 & 384/Chd/2023 "नधा"रण वष" / Assessment Years: 2009-10 & 2011-12 Vs. The Acit Saranjit Singh, बनाम Centralcircle-2, 11-A, Gen Chanda Chandigarh Singh Colony, Patiala 147001 "थायी लेखा सं./Pan No: Amwps9575J अपीलाथ"/ Appellant ""यथ"/ Repsondent ( Hybrid Hearing )

delay is condoned and we proceed to hear the appeals on merits. Since the facts and issue involved in the captioned appeals are 4. identical and are relating to same search action, therefore, these captioned appeals were heard together and are disposed of with this 381-382 & 383-384-Chd-2022 Shamsher Singh & Saranjit Singh, Patiala 3 common order. First

CHUHAR SINGH,CHUHAR SINGH vs. INCOME TAX OFFICER WARD 5 CHANDIGARH, CHANDIGARH

In the result, the appeal of the assessee is allowed for statistical purposes subject to the above condition

Bench: Cit(A). 3. That Learned Cit(A)(Nfac) Has Erred In Law & On Facts In Not Providing Any Reasonable Opportunity Of Being Heard As No Notice Was Received On Email-Id Provided In Form 35 The Appeal Form Before Cita. 4. That Learned Cit(A)(Nfac) Has Erred In Law & On Facts In Confirming The Additions Of Rs. 2,43,60,035/- U/S 69A On Account Of Unaccounted Cash Credit.

condoning the delay of 21 days in filing of appeal before CIT(A). 3. That learned CIT(A)(NFAC) has erred in law and on facts in not providing any reasonable opportunity of being heard as no notice was received on email-id provided in Form 35 the appeal form before CITA. 4. That learned CIT(A)(NFAC) has erred

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

SJVN LIMITED,SHIMLA HIMACHAL PRADESH vs. ACIT , SHIMLA

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

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

02,26,080/- under normal provisions of the Act and book profit of Rs. 19,05,26,62,664/- under the provisions of Section 115JB of the Act. The return of income was processed by the AO/CPC vide intimation dt. 22/12/2021 under section 143(1) of the Act accepting the returned income under normal provisions of the Act. However declared

INDER PAL SINGH LEGAL HEIR OF DECEASED SATNAM SINGH 171789, STREET NO.8, GURU TEG BAHADUR JAGRAON,PUNJAB vs. THE INCOME TAX OFFICER WARD-1 JAGRAON , PUNJAB

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

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

02 2/4/2017 To Cash 11 2,00,000 03 3/4/2017 To Cash 21 2,00,000 04 4/4/2017 To Cash 28 2,00,000 05 5/4/2017 To Cash 38 2,00,000 06 6/4/2017 To Cash 49 2,00,000 07 7/4/2017 To Cash 59 2,00,000 08 8/4/2017 To Cash 67 2,00,000 09 9/4/2017 To Cash

SHER SINGH,SANGRUR vs. INCOME TAX OFFICER, SANGRUR

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. MANOJ KUMAR AGGARWAL (Accountant Member)

section 115BBE of the Act are not applicable in the case of the appellant and special rate of tax u/s 11BBR of the Act 7 has been applied without giving any proper opportunity to the appellant. therefore, appellate order passed by the learned CIT(A) NFAC and assessment order passed by the learned income tax officer Sangrur is illegal, uncalled