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

147 and completion of\nassessment by the Assessing Officer is void abinitio, since no\nsatisfaction appears to have been recorded by the AO and as such\napproval as may have been granted by the Higher Authority is non-est\nand as such the assessment as framed by the AO deserves to be\nquashed.\n2. That though

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

147 and completion of\nassessment by the Assessing Officer is void abinitio, since no\nsatisfaction appears to have been recorded by the AO and as such\napproval as may have been granted by the Higher Authority is non-est\nand as such the assessment as framed by the AO deserves to be\nquashed.\n2. That though

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

147 and completion of\nassessment by the Assessing Officer is void abinitio, since no\nsatisfaction appears to have been recorded by the AO and as such\napproval as may have been granted by the Higher Authority is non-est\nand as such the assessment as framed by the AO deserves to be\nquashed.\n2. That though

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

147 and completion of\nassessment by the Assessing Officer is void abinitio, since no\nsatisfaction appears to have been recorded by the AO and as such\napproval as may have been granted by the Higher Authority is non-est\nand as such the assessment as framed by the AO deserves to be\nquashed.\n2. That though

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2, LUDHIANA vs. AB ALCOBEV PRIVATE LIMITED, DELHI

In the result, appeals of Revenue are dismissed, Cross\nObjections of the assessee for

condone the delay in filing Cross\nObjection because there was no malafide intention. The\nassessee has not adopted a delaying strategy to litigate with\nthe Revenue.\n10.1 Apart from above, we are of the view that since legal\nissues are being raised by the assessee in its Cross\nObjections, therefore, Rule 27 of ITAT Rules empowers it as a\nrespondent

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2,, LUDHIANA vs. AB ALCOBEV PRIVATE LIMITED, DELHI

In the result, appeals of Revenue are dismissed, Cross\nObjections of the assessee for

condone the delay in filing Cross\nObjection because there was no malafide intention. The\nassessee has not adopted a delaying strategy to litigate with\nthe Revenue.\n10.1 Apart from above, we are of the view that since legal\nissues are being raised by the assessee in its Cross\nObjections, therefore, Rule 27 of ITAT Rules empowers it as a\nrespondent

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2, LUDHIANA , LUDHIANA vs. AB ALCOBEV PRIVATE LIMITED, DELHI

In the result, appeals of Revenue are dismissed, Cross\nObjections of the assessee for

condone the delay in filing Cross\nObjection because there was no malafide intention. The\nassessee has not adopted a delaying strategy to litigate with\nthe Revenue.\n10.1 Apart from above, we are of the view that since legal\nissues are being raised by the assessee in its Cross\nObjections, therefore, Rule 27 of ITAT Rules empowers it as a\nrespondent

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2 LUDHIANA, LUDHIANA vs. AB ALCOBEV PRIVATE LIMITED , DELHI

In the result, appeals of Revenue are dismissed, Cross\nObjections of the assessee for

condone the delay in filing Cross\nObjection because there was no malafide intention. The\nassessee has not adopted a delaying strategy to litigate with\nthe Revenue.\n10.1 Apart from above, we are of the view that since legal\nissues are being raised by the assessee in its Cross\nObjections, therefore, Rule 27 of ITAT Rules empowers it as a\nrespondent

THE GHARTHOON AGRI CULTURAL SERVICE SOCIETY ,KANGRA, HIMACHAL PRADESH vs. INCOME TAX OFFICER, WARD - PALAMPUR, HIMACHAL PRADESH , PALAMPUR

In the result, appeal is allowed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwal

147 read with Section 144/144B of the Income Tax Act, ITA No. 927/CHD/2025 emerges out of a penalty proceeding u/s 271(1)(b) and ITA No.926/CHD/2025 emerges out from a penalty proceeding u/s 271(1)(c) of the Income Tax Act, whereas ITA No.928/CHD/2025 emerges out from penalty proceeding u/s 271F of the Income Tax Act. 3. First, we take

THE GHARTHOON AGRI CULTURAL SERVICES SOCIETY,PALAMPUR, HIMACHAL PRADESH vs. INCOME TAX OFFICER, WARD - PALAMPUR, HIMACHAL PRADESH , PALAMPUR

In the result, appeal is allowed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwal

147 read with Section 144/144B of the Income Tax Act, ITA No. 927/CHD/2025 emerges out of a penalty proceeding u/s 271(1)(b) and ITA No.926/CHD/2025 emerges out from a penalty proceeding u/s 271(1)(c) of the Income Tax Act, whereas ITA No.928/CHD/2025 emerges out from penalty proceeding u/s 271F of the Income Tax Act. 3. First, we take

THE GHARTHOON AGRI CULTURAL SERVICES SOCIETY,KANGRA, HIMACHAL PRADESH vs. INCOME TAX OFFICER, WARD - PALAMPUR, HIMACHAL PRADESH, PALAMPUR

In the result, appeal is allowed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwal

147 read with Section 144/144B of the Income Tax Act, ITA No. 927/CHD/2025 emerges out of a penalty proceeding u/s 271(1)(b) and ITA No.926/CHD/2025 emerges out from a penalty proceeding u/s 271(1)(c) of the Income Tax Act, whereas ITA No.928/CHD/2025 emerges out from penalty proceeding u/s 271F of the Income Tax Act. 3. First, we take

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

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

section 263 of the Act. ITA 146,147 & 148/CHD/2021 A.Y. 2011-12, 2015-16 & 2016-17 3 2.6 That while passing the order u/s 263 of the Act the learned Principal Commission of Income Tax cannot travel beyond the show cause notice and. therefore, findings and observations and also the material relied upon not referred in the show cause notice

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

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

section 263 of the Act. ITA 146,147 & 148/CHD/2021 A.Y. 2011-12, 2015-16 & 2016-17 3 2.6 That while passing the order u/s 263 of the Act the learned Principal Commission of Income Tax cannot travel beyond the show cause notice and. therefore, findings and observations and also the material relied upon not referred in the show cause notice

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

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

section 263 of the Act. ITA 146,147 & 148/CHD/2021 A.Y. 2011-12, 2015-16 & 2016-17 3 2.6 That while passing the order u/s 263 of the Act the learned Principal Commission of Income Tax cannot travel beyond the show cause notice and. therefore, findings and observations and also the material relied upon not referred in the show cause notice

JATINDER NATH,LUDHIANA vs. INCOME TAX OFFICER, WARD-6(4), LUDHIANA, LUDHIANA

In the result, both appeals are allowed for statistical

Bench: Shri Rajpal Yadav & Shri Krinwant Sahay

147 read with Section 144 of the Income Tax Act whereas ITA No.729/CHD/2024 ITA No.728&729/CHD/2024 A.Y.2011-12 2 emanates from a penalty order dated 20.06.2019 passed under Section 271(1)(c) of the Act. The ld. First Appellate Authority has decided quantum appeal as well as penalty appeal by way of separate orders on 30.04.2024. First we take quantum appeal

JATINDER NATH,LUDHIANA vs. INCOME TAX OFFICER, WARD-6(4), LUDHIANA, RISHI NAGAR, LUDHIANA

In the result, both appeals are allowed for statistical

Bench: Shri Rajpal Yadav & Shri Krinwant Sahay

147 read with Section 144 of the Income Tax Act whereas ITA No.729/CHD/2024 ITA No.728&729/CHD/2024 A.Y.2011-12 2 emanates from a penalty order dated 20.06.2019 passed under Section 271(1)(c) of the Act. The ld. First Appellate Authority has decided quantum appeal as well as penalty appeal by way of separate orders on 30.04.2024. First we take quantum appeal

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)

delay in filing the cross- objection is condoned and the same is hereby admitted for necessary adjudication. 26. Now, coming to the various grounds of appeal taken by the assessee in its cross-objection so filed, it is noted that the assessee has effectively challenged the action of the AO in levying interest amounting

SMT. SHASHI JAIN,LUDHIANA vs. ITO, W-VII(2), LUDHIANA

The appeal of the assessee is allowed for statistical purposes

condoning the delay, nor any explanation given for the delay. The CIT(A) further upheld the order of the A.O. on merits holding that the addition made was justified since the assessee was unable to prove the genuineness of the gift received. The CIT(A) also upheld the validity of the order passed u/s 147 of the Act, stating that

SMT. SHASHI JAIN,LUDHIANA vs. ITO, LUDHIANA

The appeal of the assessee is allowed for statistical purposes

condoning the delay, nor any explanation given for the delay. The CIT(A) further upheld the order of the A.O. on merits holding that the addition made was justified since the assessee was unable to prove the genuineness of the gift received. The CIT(A) also upheld the validity of the order passed u/s 147 of the Act, stating that