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

condone the alleged delay and proceed to decide the Cross Objections on merit in both the assessment years. 7. The Revenue has taken four grounds of appeal in each ITA No.992 & 993/CHD/2024 & CO 46 & 45/CHD/2024 A.Y.2017-18 & 2016-17 7 assessment year. In brief, its grievance revolves around a single issue and the issues pleaded in rest of the grounds

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

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

condonation of delay. Appeal is therefore taken up for final hearing. Factual Matrix 4. The assessee is engaged in the business of manufacturing of commercial vehicles and is a public limited company. For the year under consideration which is A.Y. 2015-16 and the corresponding previous year period is from 01/04/2014 to 31/03/2015, the assessee company filed its return

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\nare dismissed

condone the alleged delay\nand proceed to decide the Cross Objections on merit in both\nthe assessment years.\n7. The Revenue has taken four grounds of appeal in each\n assessment year. In brief, its grievance revolves around a\nsingle issue and the issues pleaded in rest of the grounds are\nperipheral arguments qua the central point. The common\nissue

M/S DIN DAYAL PURSOTAM LAL,SIRSA vs. PR.CIT, ROHTAK

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

delay is hereby condoned and appeal of the assessee is admitted for adjudication. 6. Ground Nos. 3, 4 and 4.1 are not pressed. Accordingly, these grounds are rejected. 7. Ground No.1 is general and needs no adjudication. 8. Apropos Ground Nos.2 to 2.7, the facts are that the ld. PCIT issued a Show Cause Notice dated 06.08.2019 to the assessee

M/S DIN DAYAL PURSOTAM LAL,SIRSA vs. PR.CIT, ROHTAK

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

delay is hereby condoned and appeal of the assessee is admitted for adjudication. 6. Ground Nos. 3, 4 and 4.1 are not pressed. Accordingly, these grounds are rejected. 7. Ground No.1 is general and needs no adjudication. 8. Apropos Ground Nos.2 to 2.7, the facts are that the ld. PCIT issued a Show Cause Notice dated 06.08.2019 to the assessee

M/S DIN DAYAL PURSOTAM LAL,SIRSA vs. PR.CIT, ROHTAK

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

delay is hereby condoned and appeal of the assessee is admitted for adjudication. 6. Ground Nos. 3, 4 and 4.1 are not pressed. Accordingly, these grounds are rejected. 7. Ground No.1 is general and needs no adjudication. 8. Apropos Ground Nos.2 to 2.7, the facts are that the ld. PCIT issued a Show Cause Notice dated 06.08.2019 to the assessee

EMSON TOOLS MFG. CORPN. LTD.,LUDHIANA vs. ACIT/DCIT- 1, LUDHIANA

In the result, both the appeals of the assessees are allowed

condone the delay which was beyond the control of the assessee and the appeal is admitted. 5. Following grounds have been raised in this appeal. 1. That the Ld. CIT(A) has erred in law and facts of the case in upholding addition of Rs. 1188745/- towards late deposit of EPF without appreciating that it has been deposited before filing

INCOME TAX OFFICER, WARD-1(3), LUDHIANA, LUDHIANA vs. SHREE BALAJI PROCESSORS, LUDHIANA

In the result, appeal of the Revenue is dismissed whereas, the 29

Bench: Shri A.D. Jain & Dr Krinwant Sahayआयकर अपील सं./ Ita No. 499/Chd/2023 "नधा"रण वष" / Assessment Year : 2017-18 The Ito, Vs. Shree Balaji Processors, बनाम Ward-1(3), Tajpur Road, Ludhiana Opp. Central Jail, Ludhiana 141010 "थायी लेखा सं./Pan No: Actfs8428B अपीलाथ"/ Appellant ""यथ"/ Repsondent & C.O. No. 09/Chd/2024 ( In आयकर अपील सं./ Ita No. 499/Chd/2023) "नधा"रण वष" / Assessment Year : 2017-18 Shree Balaji Processors, Vs. The Ito, बनाम Tajpur Road, Ward-1(3), Opp. Central Jail, Ludhiana Ludhiana 141010 "थायी लेखा सं./Pan No: Actfs8428B अपीलाथ"/ Appellant ""यथ"/ Repsondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : Shri Sudhir Sehgal, Advocate राज"व क" ओर से/ Revenue By : Smt. Kusum Bansal, Cit Dr सुनवाई क" तार"ख/Date Of Hearing : 26.06.2024 उदघोषणा क" तार"ख/Date Of Pronouncement : 20.08.2024

114 Taxman 219 (Delhi)(Mag.), g) NITISHA SILK MILLS (P.) LTD. v. ITO [IT Apped No. 896 (Ahd.) of 2011, dated 20-7-2012] h) M/s Singhal Exim Pvt. Ltd. v. ITO ITA No. 6520/Del/2018 decided by ITAT Delhi on 12.04.2019 Therefore, the allegation made by the AO regarding the identity of the buyers is invalid and certainly

DCIT,CIRCLE-I, LUDHIANA, LUDHIANA vs. ADINATH TEXTILES LIMITED, LUDHIANA

In the result both the appeal filed by the Revenue and Cross objection filed by the Assessee are dismissed

Bench: the appeal is finally heard or disposed off.

condone the delay. 6. The Departmental Representative argued that the original return was processed u/s 143(1) and the proceedings were initiated by issue of notice u/s 148 by recording the reasons and thereafter, the notice u/s 142(1) was issued. It was stated that certain information was received from the office of DCIT, Central Circle, Kolkata that on account

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

ST. JOHN AMBULANCE (INDIA) HARYANA STATE CENTRE,CHANDIGARH vs. INCOME TAX OFFICER, WARD-2(1), CHANDIGARH

In the result, both the above appeals of the Assessee are allowed for statistical purposes

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

114 /Chd/ 2025 िनधा"रण वष" / Assessment Year : 2023-24 St. John Ambulance (India) बनाम The ITO Haryana State Centre Ward-2(1) Red Cross Bhawan Haryana, Sector- Chandigarh 16, Chandigarh "ायी लेखा सं./PAN NO: ABGAS4405B अपीलाथ"/Appellant ""थ"/Respondent िनधा"रती की ओर से/Assessee by : Ms. Shruti Khandelwal, Advocate and Shri Parikshit Aggarwal, C.A राज" की ओर

ST. JOHN AMBULANCE (INDIA) HARYANA STATE CENTRE,CHANDIGARH vs. INCOME TAX OFFICER, WARD-2(1) CIT EXEMPTIONS, CHANDIGARH

In the result, both the above appeals of the Assessee are allowed for statistical purposes

114 /Chd/ 2025 िनधा"रण वष" / Assessment Year : 2023-24 St. John Ambulance (India) बनाम The ITO Haryana State Centre Ward-2(1) Red Cross Bhawan Haryana, Sector- Chandigarh 16, Chandigarh "ायी लेखा सं./PAN NO: ABGAS4405B अपीलाथ"/Appellant ""थ"/Respondent िनधा"रती की ओर से/Assessee by : Ms. Shruti Khandelwal, Advocate and Shri Parikshit Aggarwal, C.A राज" की ओर

SARAF THE JEWELLERS, CHANDIGARH,CHANDIGARH vs. THE DEPUTY/ASSISTANT COMMISSIONER OF INCOME TAX CEN-2 CHANDIGARH, CHANDIGARH

Appeal stand dismissed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं. / Ita No.1230/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2019-20) Saraf The Jeweller Dcit / Acit (Central)-2 बनाम/ Sco 45, Pocket No.1 C.R. Building Nac Showroom, Manimajra Himalaya Marg, Vs. Chandigarh – 160101 Sector-17E, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकरअपीलसं. / Ita No.1592/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2019-20) Dcit / Acit (Central)-2 Saraf The Jeweller बनाम/ C.R. Building Sco 45, Pocket No.1 Himalaya Marg, Nac Showroom, Manimajra Vs. Sector-17E, Chandigarh Chandigarh – 160101 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/Appellant Sh. Sudhir Sehgal (Advocate) & Sh. Sahil Ratra (Advocate) – Ld. Ars By : ""थ"कीओरसे/Respondent By : Sh. Abhishek Pal Garg (Cit) & Dr. Ranjit Kaur (Addl. Cit) – Ld. Drs सुनवाईकीतारीख/Date Of Hearing : 12.02.2026 घोषणाकीतारीख /Date Of Pronouncement 10.03.2026 : आदेश / O R D E R Per Bench 1.1 Aforesaid Cross-Appeals For Assessment Year (Ay) 2019-20Arises Out Of An Order Passed By Ld. Commissioner Of Income Tax (Appeals)-3

Section 65B of the Indian Evidence Act in respect of digital data on the basis of which, certain uncalled for addition have been made and also at best for the sake of argument, it is stated that only appropriate net profit ratio could be applied on such alleged suppression of receipts, rather than confirming the entire addition of Rs.8

ASSISTANT COMMISSIONER OF INCOME TAX, CHANDIGARH vs. SARAF THE JEWELLERS, PUNJAB

Appeal stand dismissed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं. / Ita No.1230/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2019-20) Saraf The Jeweller Dcit / Acit (Central)-2 बनाम/ Sco 45, Pocket No.1 C.R. Building Nac Showroom, Manimajra Himalaya Marg, Vs. Chandigarh – 160101 Sector-17E, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकरअपीलसं. / Ita No.1592/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2019-20) Dcit / Acit (Central)-2 Saraf The Jeweller बनाम/ C.R. Building Sco 45, Pocket No.1 Himalaya Marg, Nac Showroom, Manimajra Vs. Sector-17E, Chandigarh Chandigarh – 160101 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/Appellant Sh. Sudhir Sehgal (Advocate) & Sh. Sahil Ratra (Advocate) – Ld. Ars By : ""थ"कीओरसे/Respondent By : Sh. Abhishek Pal Garg (Cit) & Dr. Ranjit Kaur (Addl. Cit) – Ld. Drs सुनवाईकीतारीख/Date Of Hearing : 12.02.2026 घोषणाकीतारीख /Date Of Pronouncement 10.03.2026 : आदेश / O R D E R Per Bench 1.1 Aforesaid Cross-Appeals For Assessment Year (Ay) 2019-20Arises Out Of An Order Passed By Ld. Commissioner Of Income Tax (Appeals)-3

Section 65B of the Indian Evidence Act in respect of digital data on the basis of which, certain uncalled for addition have been made and also at best for the sake of argument, it is stated that only appropriate net profit ratio could be applied on such alleged suppression of receipts, rather than confirming the entire addition of Rs.8

PARAMJIT SINGH,SIRSA vs. PR.CIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

condone the delay in filing these appeals. 3. We shall take appeal of the assessee in ITA No. 167/Chd/2023 for A.Y 2018-19 as a lead case for discussion wherein assessee has raised the following effective grounds: 1. That on law, facts & circumstances of the case, the Worthy Pr. CIT has grossly erred assuming jurisdiction u/s 263 even when

BIMLA DEVI,JAGADHRI vs. PR.CIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

condone the delay in filing these appeals. 3. We shall take appeal of the assessee in ITA No. 167/Chd/2023 for A.Y 2018-19 as a lead case for discussion wherein assessee has raised the following effective grounds: 1. That on law, facts & circumstances of the case, the Worthy Pr. CIT has grossly erred assuming jurisdiction u/s 263 even when

SH. GURDEEP SINGH MAHAL,SIRSA vs. PR.CIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

condone the delay in filing these appeals. 3. We shall take appeal of the assessee in ITA No. 167/Chd/2023 for A.Y 2018-19 as a lead case for discussion wherein assessee has raised the following effective grounds: 1. That on law, facts & circumstances of the case, the Worthy Pr. CIT has grossly erred assuming jurisdiction u/s 263 even when

RAKESH KUMAR,JAGADHRI vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, PANCHKULA

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

condone the delay in filing these appeals. 3. We shall take appeal of the assessee in ITA No. 167/Chd/2023 for A.Y 2018-19 as a lead case for discussion wherein assessee has raised the following effective grounds: 1. That on law, facts & circumstances of the case, the Worthy Pr. CIT has grossly erred assuming jurisdiction u/s 263 even when