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

Section 148B is illegal and unsustainable, as a single approval\norder dated 30.03.2023 was issued for all three assessment years-AYS\n2018-19 to 2020-21 vide letter no.2384.\n2. That the reopening is bad in law in, as much as, neither in the\nreasons recorded by the AO nor in the approval granted by the Ld.\nPCIT

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

Section 1488 is illegal and unsustainable, as a single approval\norder dated 30.03.2023 was issued for all three assessment years-AYS\n2018-19 to 2020-21 vide letter no.2384.\n2. That the reopening is bad in law in, as much as, neither in the\nreasons recorded by the AO nor in the approval granted by the Ld.\nPCIT

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

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.

delay of 35 days in filing the appeal by the assessee is condoned and the appeal is admitted. 6. Following grounds have been raised in this appeal : 1. The Appellant Sh. Tek Chand aged 70 year old is a Farmer and He and his Brother Sh. Ram Diya sold their Agri land of Rs. 60,22,000 on dated

THE BAROT CO-OPERATIVE MULTIPURPOSE SOCIETY LIMITED,MANDI vs. INCOME TAX OFFICER, MANDI

The appeal of the Assessee is allowed for statistical purposes

Bench: Dr Krinwant Sahay & Shri Paresh M. Joshiआयकर अपील सं./ Ita No. 671/Chd/2023 "नधा"रण वष" / Assessment Year: 2017-18 The Barot Cooperative Vs. The Ito, बनाम Mandi Multipurpose Society Limited, Mandi, Himachal Pradesh 176120 "थायी लेखा सं./Pan No: Aacat9554D अपीलाथ"/ Appellant ""यथ"/ Repsondent ( Hybrid Hearing ) "नधा"रती क" ओर से/Assessee By : Shri Ashwani Kumar, Ca राज"व क" ओर से/ Revenue By : Shri Rahul Sohu, Jcit, Sr. Dr सुनवाई क" तार"ख/Date Of Hearing : 01.07.2024 उदघोषणा क" तार"ख/Date Of Pronouncement : 04.07.2024 आदेश/Order

delay in filing of the appeal. 3. The brief facts of the case are as under:- “Based on information received from DDIT(lnv.), Shimla, the assessment proceedings was taken up for AY 2017-18 u/s.143(3) in the case of M/s. H.P. Co-operative Bank Ltd.,(AABFH7694E) by ACIT. Shimla Circle. Information gathered during investigation relating to large

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

The appeal of the assessee is allowed for statistical purposes

condone the delay caused in filing the above said Appeal, as there is no mistake on the part of the above said Assessee but the mistake has been on the part of the Counsel of the Assessee.” 7. Further an affidavit of the Ld. counsel for assessee admitting to his mistake on oath was also filed before

SMT. SHASHI JAIN,LUDHIANA vs. ITO, LUDHIANA

The appeal of the assessee is allowed for statistical purposes

condone the delay caused in filing the above said Appeal, as there is no mistake on the part of the above said Assessee but the mistake has been on the part of the Counsel of the Assessee.” 7. Further an affidavit of the Ld. counsel for assessee admitting to his mistake on oath was also filed before

SH. BALWAN SINGH,PANCHKULA vs. ITO, CHANDIGARH

The appeal of the assessee is allowed in above terms

Bench: Shri Sanjay Garg & Ms. Annapurna Gupta

condoning the delay in filing of the same, vide their order dated 28-02-13. The assessee filed appeal against the said order of the ITAT to the Hon’ble High Court, who vide their order in ITA No. 359/2013 dt. 18/03/2014 set aside the order of the ITAT and remanded the appeal back to the ITAT to decide

GOLDEN WINES, 2673 PHASE-1, BASANT AVENUE, DUGRI,LUDHIANA vs. NARESH KUMAR MEENA, ITO WARD-6(3) LUDHIANA, CURRENT JURISDICTIONAL A.O. ITO WARD-6(1), LUDHIANA, LUDHIANA

In the result, all these appeals are allowed for statistical purposes

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

Section 249 of the Income-tax Act, 1961 Commissioner (Appeals) Form of appeal and limitation - Whether though a party is required to explain each day's delay and to show that it was prevented by sufficient cause in filing appeal in time, yet power to condone delay has to be exercised in a pragmatic manner to advance substantial justice Held

GOLDEN WINES, 2673 PHASE-1, BASANT AVENUE, DUGRI,LUDHIANA vs. NARESH KUMAR MEENA, ITO WARD-6(3) LUDHIANA, CURRENT JURISDICTIONAL A.O. ITO WARD-6(1), LUDHIANA, LUDHIANA

In the result, all these appeals are allowed for statistical purposes

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

Section 249 of the Income-tax Act, 1961 Commissioner (Appeals) Form of appeal and limitation - Whether though a party is required to explain each day's delay and to show that it was prevented by sufficient cause in filing appeal in time, yet power to condone delay has to be exercised in a pragmatic manner to advance substantial justice Held

GOLDEN WINES, 2673 PHASE-1, BASANT AVENUE, DUGRI,LUDHIANA vs. NARESH KUMAR MEENA, ITO WARD6(3), LUDHIANA, CURRENT JURISDICTIONAL A,O, ITO WARD 6(1), LUDHIANA, LUDHIANA

In the result, all these appeals are allowed for statistical purposes

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

Section 249 of the Income-tax Act, 1961 Commissioner (Appeals) Form of appeal and limitation - Whether though a party is required to explain each day's delay and to show that it was prevented by sufficient cause in filing appeal in time, yet power to condone delay has to be exercised in a pragmatic manner to advance substantial justice Held

GOLDEN WINES, 2673 PHASE-1, BASANT AVENUE, DUGRI,LUDHIANA vs. NARESH KUMAR MEENA,ITO WARD 6(3), LUDHIANA,CURRENT JURISDICTIONAL A.O. ITO WARD 6(1), LUDHIANA, LUDHIANA

In the result, all these appeals are allowed for statistical purposes

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

Section 249 of the Income-tax Act, 1961 Commissioner (Appeals) Form of appeal and limitation - Whether though a party is required to explain each day's delay and to show that it was prevented by sufficient cause in filing appeal in time, yet power to condone delay has to be exercised in a pragmatic manner to advance substantial justice Held

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

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 quantum appeal

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

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 quantum appeal

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

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 quantum appeal

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

condoning the delay of 383 days and dismissing the appeal being time barred. In the second fold, the grievance of the assessee is that ld. CIT(A) has erred in confirming the addition of Rs.9,94,578/- which was added by the AO with the aid of Section 68 of the Income Tax Act. ITA No.728&729/CHD/2024 A.Y.2011-12

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

condoning the delay of 383 days and dismissing the appeal being time barred. In the second fold, the grievance of the assessee is that ld. CIT(A) has erred in confirming the addition of Rs.9,94,578/- which was added by the AO with the aid of Section 68 of the Income Tax Act. ITA No.728&729/CHD/2024 A.Y.2011-12

SAHEED DARSHAN FILLING STATION,LUDHIANA vs. INCOME TAX OFFICER (ITO), WARD 3, KHANNA, KHANNA

In the result, appeal of the assessee is allowed and Stay Application is dismissed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 1736/Chd/2025 "नधा"रण वष" / Assessment Year: 2018-19 Shaheed Darshan Filling Station, The Ito, Village-Iraq, Kohara Road, Vs Ward-3, Machhiwara, So-Irak, Ludhiana. Khanna. "थायी लेखा सं./Pan No: Aarfs1129H अपीलाथ"/Appellant ""यथ"/Respondent & S.A. No. 5/Chd/2026 In आयकर अपील सं./ Ita No. 1736/Chd/2025 "नधा"रण वष" / Assessment Year: 2018-19 Shaheed Darshan Filling Station, The Ito, Village-Iraq, Kohara Road, Vs Ward-3, Machhiwara, So-Irak, Ludhiana. Khanna. "थायी लेखा सं./Pan No: Aarfs1129H अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Sifatpreet Singh, Ca & Shri Amanjot Singh, Ca Revenue By : Dr. Ranjit Kaur, Addl. Cit Sr. Dr Date Of Hearing : 28.01.2026 Date Of Pronouncement : 03.02.2026 Physical Hearing O R D E R Per Raj Pal Yadav, Vp

Section 5 of the Limitation Act should receive a liberal construction so as to advance substantial justice vide Shakuntala Devi lain Vs. Kuntal Kumari [AIR 1969 SC 575] and State of West Bengal Vs. The Administrator, Howrah Municipality [AIR 1972 SC ITA No.1736/CHD/2025 & SA-5/CHD/2026 A.Y.2018-19 6 749]. It must be remembered that in every case of delay there