SH. ABHISHEK BANSAL,BARNALA vs. PR. CIT, PATIALA

In the result, the Assessee’s appeal is partly allowed

Bench: Shri A.D. Jain & Dr Krinwant Sahayआयकर अपील सं./ Ita No. 131/Chd/2023 "नधा"रण वष" / Assessment Year : 2017-18 Abhishek Bansal, Vs. Pr. Commissioner बनाम Prop. M/S Lifeline Multi Income Tax, Specialilty Hospitality, 25 Acre Patiala Extn., Near Fountain Chowk, Barnala, Punjab "थायी लेखा सं./Pan No: Acgpb5740E अपीलाथ" ./ Appellant ""यथ" / Respondent ( Hybrid Mode ) "नधा"रती क" ओर से/Assessee By : Sh. Sudhir Sehgal, Advocate राज"व क" ओर से/ Revenue By : Shri Rohit Sharma, Cit Dr सुनवाई क" तार"ख/Date Of Hearing : 09.05.2024 उदघोषणा क" तार"ख/Date Of Pronouncement : 13.06.2024 आदेश/Order Per Dr. Krinwant Sahay, A.M.:

delay in filing the appeal is hereby condoned and we proceed to hear the appeal on merits. 5. The appeal has been filed on the following grounds: - 1. That the Ld. PCIT, Patiala has erred in issuing notice u/s 263 and, thereby, holding that the assessment as framed by the Assessing Officer 131-Chd-2023 – Shri Abhishek Bansal, Barnala

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

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2, LUDHIANA vs. KAPIL ROMANA, BATHINDA

In the result, appeals filed by the Revenue as well as Cross Objections of the Assessee are dismissed

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

69C r.w.s. 115BBEof the Income Tax Act, 1961? 5. That the Ld. CIT(A) has ignored the facts that the entry of Dr. Jagjeet Chawla on the said page was cross-referred to another seized page i.e. ledger of account of doctor Jagjeet Chawla for the period 01.04.2016 to 06.02.2019 and it was found that the entry of balance amounting

DEPUTY COMMISSIONER OF INCOME TAX , LUDHIANA vs. KAPIL ROMANA , BATHINDA

In the result, appeals filed by the Revenue as well as Cross Objections of the Assessee are dismissed

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

69C r.w.s. 115BBEof the Income Tax Act, 1961? 5. That the Ld. CIT(A) has ignored the facts that the entry of Dr. Jagjeet Chawla on the said page was cross-referred to another seized page i.e. ledger of account of doctor Jagjeet Chawla for the period 01.04.2016 to 06.02.2019 and it was found that the entry of balance amounting

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

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.1231/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2020-21) 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.1593/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2020-21) 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 11.03.2026 : आदेश / O R D E R Per Bench

Section 115BBE of the difference of the alleged cost of construction is not sustainable. 5. That CIT(A) has erred in making the addition of Rs.2,07,40,000/- on account of unsecured loan u/s 68 and applying the provisions of Sec.115BBE of the Income Tax Act and this addition was not called for as no incriminating evidence in respect

SARAF THE JEWELLER, CHANDIGARH,CHANDIGARH vs. THE DCIT/ACIT CENTRAL CIRCLE- 2, CHANDIGARH, CHANDIGARH

Appeal stand dismissed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं. / Ita No.1232/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2021-22) 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.1594/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2021-22) 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) Assessee By : Sh. Sudhir Sehgal (Advocate) & Sh. Sahil Ratra (Advocate) – Ld. Ars Revenue By : Sh. Abhishek Pal Garg (Cit) & Dr. Ranjit Kaur (Addl. Cit) – Ld. Drs सुनवाईकीतारीख/Date Of Hearing : 12.02.2026 घोषणाकीतारीख /Date Of Pronouncement 12.03.2026 : आदेश / O R D E R Per Bench

Section 115BBE on such addition is not justified. 6. That the finding of CIT(A) in conforming the above addition of cash is contrary, since already having accepted the contention of the assessee about the availability of amount of short stock as per books of account and, as such, the confirmation of addition is against the facts and circumstances

SARAF THE JEWELLER, CHANDIGARH,CHANDIGARH vs. THE DCIT/ACIT CENTRAL CIRCLE -2, CHANDIGARH, CHANDIGARH

Appeal stand dismissed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं. / Ita No.1231/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2020-21) 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.1593/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2020-21) 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 11.03.2026 : आदेश / O R D E R Per Bench

Section 115BBE of the difference of the alleged cost of construction is not sustainable. 5. That CIT(A) has erred in making the addition of Rs.2,07,40,000/- on account of unsecured loan u/s 68 and applying the provisions of Sec.115BBE of the Income Tax Act and this addition was not called for as no incriminating evidence in respect

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.1232/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2021-22) 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.1594/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2021-22) 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) Assessee By : Sh. Sudhir Sehgal (Advocate) & Sh. Sahil Ratra (Advocate) – Ld. Ars Revenue By : Sh. Abhishek Pal Garg (Cit) & Dr. Ranjit Kaur (Addl. Cit) – Ld. Drs सुनवाईकीतारीख/Date Of Hearing : 12.02.2026 घोषणाकीतारीख /Date Of Pronouncement 12.03.2026 : आदेश / O R D E R Per Bench

Section 115BBE on such addition is not justified. 6. That the finding of CIT(A) in conforming the above addition of cash is contrary, since already having accepted the contention of the assessee about the availability of amount of short stock as per books of account and, as such, the confirmation of addition is against the facts and circumstances

DEPUTY COMMISSIONER OF INCOME TAX, CHANDIGARH vs. VAISHALI AGGARWAL, CHANDIGARH

In the result, all the appeals of the Revenue as well as

Bench: Shri Sanjay Garg & Shri Krinwant Sahay

Section 132 of the Income Tax Act, 1961 on 15.11.2017 in Scott Edil group of cases. 3. The Revenue’s appeal in alongwith corresponding Cross Objection of the assessee ITA Nos. 501 to 504, 507 to 509/CHD/2023 & C.O.Nos. 10 to 13, 18 to 20/CHD/2024. 3 C.O.No. 10/CHD/2024 are taken as lead cases for the purpose of narration of facts

DEPUTY COMMISSIONER OF INCOME TAX,, CHANDIGARH vs. SANJEEV AGGARWAL , CHANDIGARH

In the result, all the appeals of the Revenue as well as

Bench: Shri Sanjay Garg & Shri Krinwant Sahay

Section 132 of the Income Tax Act, 1961 on 15.11.2017 in Scott Edil group of cases. 3. The Revenue’s appeal in alongwith corresponding Cross Objection of the assessee ITA Nos. 501 to 504, 507 to 509/CHD/2023 & C.O.Nos. 10 to 13, 18 to 20/CHD/2024. 3 C.O.No. 10/CHD/2024 are taken as lead cases for the purpose of narration of facts

MOHIT FURNACE PRIVATE LIMITED,LUDHIANA vs. ASSESSMENT UNIT, FACELESS

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)

section 250 of the Act, which is hereinafter referred to as the “impugned order”. 2. At the outset, it is noted that there is delay of 03 days in filing the appeal by the Assessee as pointed out by the Registry. 3. Since the assessee has shown sufficient cause for delay in filing the appeal, therefore delay of 03 days