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

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

JONANG BUDDHIST EDUCATIONAL SOCIETY,KANGRA, HIMACHAL PRADESH vs. COMMISSIONER OF INCOME TAX, EXEMPTIONS, CHANDIGARH , CHANDIGARH

In the result, Assessee’s appeal is dismissed

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Krinwant Sahay, Am आयकर अपील सं./ Ita No.1350/Chd/2025 (िनधा"रण वष" / Assessment Year: 2025-26) Jonang Buddhist Educational Commissioner Of Society Income बनाम/ C/O Tejmohan Singh, Advocate Tax Exemptions, Vs. #527, Sector 10-D, Chandigarh Chandigarh 160011 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aafaj-8024-M (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ : Sh. Tej Mohan Singh (Advocate) Appellant By ""थ"कीओरसे/Respondent : Sh. Manav Bansal (Cit) Dr By सुनवाईकीतारीख/Date Of Hearing : 16-12-2025 घोषणाकीतारीख /Date Of : 07- 01-2026 Pronouncement आदेश / O R D E R Krinwant Sahay () Appeal In This Case Has Been Filed By The Assessee Against The Order Dated 03.09.2025 Passed By The Ld.

2. That the Ld. Commissioner of Income Tax has erred in law as well as facts in rejecting the approval sought under Section 80G of the Act only on the basis that the application was not filed within the time limit prescribed in respect of application filed under clause (iii) of first proviso to sub-section (5) of Section

HARBLAS SINGH,AMBALA vs. INCOME TAX OFFICER, AMBALA

In the result, the appeal is dismissed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 568/Chd/2024 "नधा"रण वष" / Assessment Year : 2014-15 Shri Harblas Singh, Vs The Ito, 29/30, Parry Hotel, Ward – 1, Bank Road, Ambala. Ambala. "थायी लेखा सं./Pan No: Bzwps4348R अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Rohit Bector, Ca Revenue By : Shri Vivek Vardhan, Addl. Cit, Sr.Dr Date Of Hearing : 24.06.2025 Date Of Pronouncement : 26.06.2025

2 assessee has filed an application for condonation of delay u/s 253 sub-section (4) of the Income Tax Act and also filed his affidavit. The reasons pleaded in the application are that assessee is a semi-literate agriculturist. His agriculture land was compulsorily acquired on which he has received compensation. In order to claim refund, he has filed

JARNAIL SINGH GILL,JAGRAON vs. INCOME TAX OFFICER, WARD-1, JAGRAON

In the result, the appeal of the assessee is partly allowed

Bench: The Tribunal & The Matter Was Remanded Back To Ao For Fresh Adjudication. Thereafter, The Assessment Order Was Passed

2. At the outset, there is a delay in filing of the appeal as pointed out by the Registry. After hearing both the parties and the considering the affidavit of the assessee placed on record, I find that there was reasonable cause in the delayed filing of the appeal, the same is hereby condoned and the appeal is admitted

SUKHMINDER SINGH SO JOGINDER SINGH VILLAGE AND POST OFFICE UDHAMGARH, JAGADHRI YAMUNANAGAR ,HARYANA vs. ASSESSING OFFICER NFAC DELHI JURISDICTIONAL ASSESSING OFFICER INCOME TAX OFFICER WARD-5 YAMUNANAGAR, HARYANA

In the result, appeal of the assessee is dismissed as withdrawn

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 647/Chd/2024 "नधा"रण वष" / Assessment Year : 2018-19 Sukhminder Singh, The Ito, बनाम S/O Joginder Singh, Ward 5, Village & Po Udhamgarh, Yamunanagar Vs. Jagadhri Yamunanagar "थायी लेखा सं./Pan No: Bpsps7167A अपीलाथ"/Appellant ""यथ"/Respondent ( Hybrid Mode ) "नधा""रती क" ओर से/Assessee By : None (Withdrawal Application) राज"व क" ओर से/ Revenue By : Shri Rohit Sharma, Cit Dr सुनवाई क" तार"ख/Date Of Hearing : 06.02.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 24.02.2025 आदेश/Order Per Krinwant Sahay, Am : Appeal In This Case Has Been Filed By The Assessee Against The Order Dated 15.03.2024 Of Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’], For The Assessment Year 2018-19. 2. It Is Seen From The Record That The Registry Has Pointed Out A Delay Of 08 Days (09 Days As Per Assessee) In Filing Of 647-Chd-2024 Sukhminder Singh, Jagdhari

2 the appeal. The Assessee has submitted that an Application for condonation of delay, which is reproduced as under: 647-Chd-2024 Sukhminder Singh, Jagdhari 3 3. We have considered the issue brought on record and gone through the contents of the affidavit for condonation of delay and we feel it appropriate to condone the delay because of the nature

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)

254 2,00,000 40 19/5/2017 To Cash 258 2,00,000 41 15/2/2018 To Cash 1039 2,00,000 42 16/2/2018 To Cash 1042 2,00,000 43 17/2/2018 To Cash 1045 2,00,000 44 18/2/2018 To Cash '1048 2,00,000 45 19/2/2018 To Cash 1050 2,00,000 46 20/2/2018 To Cash 1054 2

MEWA SINGH,PANCHKULA vs. ITO WARD-2, PANCHKULA

In the result, appeal of the assessee is dismissed as withdrawn

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 448/Chd/2022 "नधा"रण वष" / Assessment Year : 2015-16 Mewa Singh, Ito, बनाम C/O M K Aggarwal & Ward No.2, Associates Panchkula Vs. Sco 1, First Floor, Sector 11, Panchkula 134113 "थायी लेखा सं./ Pan No: Adhps5879H अपीलाथ"/Appellant ""यथ"/Respondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : None (Withdrawal Application) राज"व क" ओर से/ Revenue By : Shri Vivek Vardhan, Addl. Cit, Sr. Dr सुनवाई क" तार"ख/Date Of Hearing : 20.05.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 20.05.2025 आदेश/Order Per Bench : Appeal In This Case Has Been Filed By The Assessee Against The Order Dated 15.03.2022 Of Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, For The Assessment Year 2015- 16. 2. The Registry Has Pointed Out That There Is A Delay Of Four Days In Filing Of The Appeal Before The Tribunal. The Counsel

2 of the Assessee has filed an Affidavit on behalf of the Assessee, making prayer for condonation of delay. The affidavit of the Assessee is as under:- 448-Chd-2024 Mewa Singh, Panchkula 3 4. We have considered the facts and reasoning furnished by the Assessee. In view of the explanation and reasoning given in the affidavit, the delay

PUNJAB NATIONAL BANK,DAL LAKE DHARAMSHALA CANTT vs. JOINT COMMISSIONER OF INCOME TAX (OSD) TDS, PANCHKULA

In the result, appeal of the assessee is dismissed as withdrawn

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 415/Chd/2023 "नधा"रण वष" / Assessment Year : 2013-14 Punjab National Bank, The Jcit बनाम Dal Lake Dharmshala (Osd)Tds, Cantt. Sector 2, Vs. Tehsil Dharmshala 176216 Panchkula "थायी लेखा सं./Pan No: Ptlpi2710F अपीलाथ"/Appellant ""यथ"/Respondent ( Physical Hearing ) "नधा""रती क" ओर से/Assessee By : None (Withdrawal Application) राज"व क" ओर से/ Revenue By : Dr. Ranjit Kaur, Addl. Cit, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 29.01.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 30.01.2025 आदेश/Order Per Krinwant Sahay, Am : Appeal In This Case Has Been Filed By The Assessee Against The Order Dated 22.02.2023 Of Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’], For The Assessment Year 2013-14. 2. The Registry Has Pointed Out That There Was A Delay Of 66 Days In Filing Of The Appeal Before The Tribunal. The Ld. Counsel For The Assessee Has Filed A Letter Giving Detailed

2 reasoning along with affidavit dated 19.07.2023 for condonation of delay, which is reproduced as under:- 415-Chd-2023 Punajb National Bank, Dharmshala 415-Chd-2023 Punajb National Bank, Dharmshala 4 3. In the affidavit, the Branch Manager of the Punjab National Bank (PNB), Dharmshala has intimated that the delay was because the Branch Manager of the Dal Lake branch

MILITARY HOSPITAL PALAMPUR (KV) ,HOLTA PALAMPUR vs. ITO (TDS), PALAMPUR

In the result, both the appeals of the assessee are dismissed as withdrawn

Bench: Sh. Rajpal Yadav, Hon’Ble Vice- & Sh. Krinwant Sahay, Hon’Ble(Hybrid Hearing) I.T.A. Nos.268 & 269/Chandi/2023 Assessment Years: 2015-16 & 2016-17

condone the delay in both the appeals. 2. During the proceedings, the ld. AR appeared on the behalf of the Assessee and submitted a common application dated 24.04.2025 with the request for withdrawal of these appeals on the ground that the Assessee has opted to take benefit under the Direct Tax 'Vivad Se Vishwas Scheme 2024’ and sought permission

MILITARY HOSPITAL PALAMPUR (KV) ,HOLTA PALAMPUR vs. ITO TDS, PALAMPUR

In the result, both the appeals of the assessee are dismissed as withdrawn

Bench: Sh. Rajpal Yadav, Hon’Ble Vice- & Sh. Krinwant Sahay, Hon’Ble(Hybrid Hearing) I.T.A. Nos.268 & 269/Chandi/2023 Assessment Years: 2015-16 & 2016-17

condone the delay in both the appeals. 2. During the proceedings, the ld. AR appeared on the behalf of the Assessee and submitted a common application dated 24.04.2025 with the request for withdrawal of these appeals on the ground that the Assessee has opted to take benefit under the Direct Tax 'Vivad Se Vishwas Scheme 2024’ and sought permission

PUNJAB NATIONAL BANK,DAL LAKE DHARAMSHALA CANTT vs. DY. COMMISISONER OF INCOME TAX (TDS), PANCHKULA

In the result, appeal of the assessee is dismissed as withdrawn

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 414/Chd/2023 "नधा"रण वष" / Assessment Year : 2012-13 Punjab National Bank, The Dcit (Tds), Dal Lake Dharmshala बनाम Sector 2, Cantt. Panchkula Vs. Tehsil Dharmshala, Distt. Kangra 176216 "थायी लेखा सं./Pan No: Ptlpi2710F अपीलाथ"/Appellant ""यथ"/Respondent ( Physical Hearing ) "नधा""रती क" ओर से/Assessee By : None (Withdrawal Application) राज"व क" ओर से/ Revenue By : Dr. Ranjit Kaur, Addl. Cit, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 29.01.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 30.01.2025 आदेश/Order Per Krinwant Sahay, Am : Appeal In This Case Has Been Filed By The Assessee Against The Order Dated 20.03.2023 Of Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’], For The Assessment Year 2012-13. 2. The Registry Has Pointed Out That There Is A Delay Of 40 Days In Filing Of The Appeal Before The Tribunal. The Ld.

2 Counsel for the Assessee has filed a letter dated 23.7.2024 for condonation of delay on behalf of Punjab National Bank, Dharmshala, which is reproduced as under:- 414-Chd-2023 Punjab National Bank, Dharmshala 3. In the affidavit, the Branch Manager of the Punjab National Bank (PNB), Dharmshala has intimated that the delay was because the Branch Manager

M/S CREDO ASSETS PVT. LTD.,RUPNAGAR PUNJAB vs. DCIT/ACIT(CEN)-1 CHD, CHANDIGARH

The appeals stand partly allowed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No.487/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2013-14) M/S Singla Builders & Promoters Ltd. Dcit / Acit Central-1 बनाम/ Plot No 1265, Sector 82, Industrial Area C.R. Building, Sector 17 Vs. Rupnagar (Punjab) 140308 Chandigarh-160017 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaocs-6503-M (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकर अपील सं. / Ita No.482/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2017-18) & 3. आयकर अपील सं. / Ita No.484/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2018-19) M/S Credo Assets Private Ltd. Dcit / Acit Central-1 बनाम/ Plot No 1265-C, Sector 82, Industrial Area C.R. Building, Sector 17 Vs. Rupnagar (Punjab) 140308 Chandigarh-160017 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aafcc-6400-L (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Parikshit Aggarwal (Ca) & Smt. Shruti Khandelwal (Ca) – Ld. Ars ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) & Shri Rajat Kumar Kureel (Cit) – Ld. Drs (Virtual) Date Of Final Hearing : 27-01-2026 Date Of Pronouncement : 03-02-2026

254 CTR 392), it was held that seized material could be relied upon to draw inference that there could be similar transactions. Therefore, findings in respect of unaccounted expenditure incurred outside the books of account for some financial year could be extrapolated in respect of other projects being developed by the assessee for different assessment years. 4.17 In terms

M/S SINGLA BUILDERS AND PROMOTERS LIMITED,RUPNAGAR, PUNJAB vs. DCIT/ACIT(CEN)-1 CHD, CHANDIGARH

The appeals stand partly allowed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No.487/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2013-14) M/S Singla Builders & Promoters Ltd. Dcit / Acit Central-1 बनाम/ Plot No 1265, Sector 82, Industrial Area C.R. Building, Sector 17 Vs. Rupnagar (Punjab) 140308 Chandigarh-160017 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaocs-6503-M (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकर अपील सं. / Ita No.482/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2017-18) & 3. आयकर अपील सं. / Ita No.484/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2018-19) M/S Credo Assets Private Ltd. Dcit / Acit Central-1 बनाम/ Plot No 1265-C, Sector 82, Industrial Area C.R. Building, Sector 17 Vs. Rupnagar (Punjab) 140308 Chandigarh-160017 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aafcc-6400-L (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Parikshit Aggarwal (Ca) & Smt. Shruti Khandelwal (Ca) – Ld. Ars ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) & Shri Rajat Kumar Kureel (Cit) – Ld. Drs (Virtual) Date Of Final Hearing : 27-01-2026 Date Of Pronouncement : 03-02-2026

254 CTR 392), it was held that seized material could be relied upon to draw inference that there could be similar transactions. Therefore, findings in respect of unaccounted expenditure incurred outside the books of account for some financial year could be extrapolated in respect of other projects being developed by the assessee for different assessment years. 4.17 In terms

M/S CREDO ASSETS PVT. LTD.,RUPNAGAR PUNJAB vs. DCIT/ACIT(CEN)-1 CHD, CHANDIGARH

The appeals stand partly allowed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No.487/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2013-14) M/S Singla Builders & Promoters Ltd. Dcit / Acit Central-1 बनाम/ Plot No 1265, Sector 82, Industrial Area C.R. Building, Sector 17 Vs. Rupnagar (Punjab) 140308 Chandigarh-160017 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaocs-6503-M (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकर अपील सं. / Ita No.482/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2017-18) & 3. आयकर अपील सं. / Ita No.484/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2018-19) M/S Credo Assets Private Ltd. Dcit / Acit Central-1 बनाम/ Plot No 1265-C, Sector 82, Industrial Area C.R. Building, Sector 17 Vs. Rupnagar (Punjab) 140308 Chandigarh-160017 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aafcc-6400-L (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Parikshit Aggarwal (Ca) & Smt. Shruti Khandelwal (Ca) – Ld. Ars ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) & Shri Rajat Kumar Kureel (Cit) – Ld. Drs (Virtual) Date Of Final Hearing : 27-01-2026 Date Of Pronouncement : 03-02-2026

254 CTR 392), it was held that seized material could be relied upon to draw inference that there could be similar transactions. Therefore, findings in respect of unaccounted expenditure incurred outside the books of account for some financial year could be extrapolated in respect of other projects being developed by the assessee for different assessment years. 4.17 In terms

JANTA LAND PROMOTERS PRIVATE LIMITED ,MOHALI vs. INCOME TAX OFFICER WARD 6(1) CHANDIGARH , MOHALI

In the result, appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 907/Chd/2024 "नधा"रण वष" / Assessment Year : 2017-18 बनाम M/S Janta Land Promoters Pvt.Ltd. The Ito, Sco 39-42, Sector 82, Ward 6(1), Vs Mohali. Chandigarh. "थायी लेखा सं./Pan /Tan No: Aabcj3450D अपीलाथ"/Appellant ""यथ"/Respondent "नधा"रती क" ओर से/Assessee By : Shri Pankaj Bhalla, Ca राज"व क" ओर से/ Revenue By : Shri Vivek Vardhan, Addl. Cit, Sr.Dr तार"ख/Date Of Hearing : 07.05.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 30.07.2025

condone the delay and proceed to decide it on merit. 3. The assessee has taken five grounds of appeal which contain sub-grounds, however, its grievance revolves around two issues, namely, ld. CIT (Appeals) has erred in confirming the addition made with the aid of Section 36(1)(va) of the Act with regard to the, (a) Employees’ contribution