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. 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

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

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

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

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-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

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. 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

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

condone\nthe delay and proceed to decide the appeals on merits.\n9.\nThe facts on all vital points are common in all the three years,\nrather, order of ld. CIT(A) is verbatim same except variation in the\ndates and quantum of the additions. Therefore, for the facility of\nreference, we are taking up facts from ITA No. 814/Chd/2023

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

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

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

DCIT CC-1, LUDHIANA vs. M/S OSWAL FASHION (P) LTD., LUDHIANA

In the result, the Revenue’s appeals in ITA Nos

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

condone the delay for which sufficient cause is shown, and admit both the Cross Objections for adjudication. 4. The assessee, in its Cross Objection for A.Y. 2008–09, has raised a legal ground challenging the validity of the addition made under section 68 of the Income-tax Act, 1961, on the ground that the said addition was made without