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

M/S LITTLE KANHAYA KNITWEARS,LUDHIANA vs. DCIT, CC-3, LUDHIANA

In the result, appeal of Assessee is allowed for statistical purposes

Bench: Shri Vikram Singh Yadav & Shri Paresh M. Joshiआयकर अपील सं./ Ita No. 724/Chd/2022 "नधा"रण वष" / Assessment Year: 2018019 M/S Little Kanhya Vs. The Dcit बनाम Central Circle-3, Knitwears, Ludhiana Ram Gali, Madhpuri-1, Ludhiana 141008 "थायी लेखा सं./Pan No: Aaefl0415E अपीलाथ"/ Assessee ""यथ"/ Repsondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : Shri Parikshit Aggarwal, Ca राज"व क" ओर से/ Revenue By : Shri Vivek Vardhan, Jcit Sr. Dr सुनवाई क" तार"ख/Date Of Hearing : 30.12.2024 उदघोषणा क" तार"ख/Date Of Pronouncement : 21.01.2024 आदेश/Order

survey u/s 133A of the Act was carried out at the business premises of the Assessee firm on16.3.2017. Notice u/s 143(2) was issued on 26.3.2019 and served on the Assessee electronically. Notice u/s 142(i) along with detailed questionnaire was issued on 6.1.2021 for 15.1.2021 and served upon the Assessee firm electronically. The Assessee in response to the notice

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

JCIT(OSD)(TDS),CIRCLE, PANCHKULA vs. M/S LIBERTY SHOES LTD.,, KARNAL

In the result, the appeal of the Revenue is dismissed

Bench: Shri N.K. Saini & Shri R.L Negiआयकर अपील सं./Ita No. 268/Chd/2020 "नधा"रणवष" / Assessment Years : 2017-18 Joint Commissioner Of Income M/S Liberty Shoes Ltd., बनाम 13Th Mile Stone, Tax (Osd) (Tds) Circle Aaykar Bhawan, Sector 2 Liberty Puram, G.T. Road, Panchkula Kutail, Karnal Tan No: Rtkl00664G अपीलाथ"/Appellant ""यथ"/Respondent

133A(1) of the Act was conducted at the business premises of the assessee company on 19.10.2017. Perusal of relevant documents during the course of survey ITA No.268-Chd-2020- Liberty Shoes Limited, Karnal 2 proceedings and the post survey enquiry revealed that the assessee had not deducted tax at source on the payment of incentive to various dealers. Accordingly

SARU ENTERPRISES PRIVATE LIMITED,PATIALA vs. ACIT/DCIT, CEN. CIR., PATIALA

In the result, the appeal of the assessee is allowed

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

delay is hereby condoned and the appeal is admitted for adjudication. 4. Briefly the facts of the case are that the assessee is engaged in the business of undertaking civil projects for Military engineering services under the name and style of M/s Saru Enterprises Pvt. Ltd. and works as a MES contractor. A survey operation under section 133A was conducted

GULZAR MOHD,MALERKOTLA vs. PCIT (CENTRAL), LUDHIANA

In the result, appeal of the assessee is allowed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwal

delay is condoned. 3. Originally, assessee has raised six grounds of appeal but thereafter, he has filed an application for permission to raise two additional grounds of appeal. In brief, grievance of the assessee in all these grounds is that ld. CIT has erred in taking cognizance u/s 263 of the Income Tax Act and thereby setting aside the assessment

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

MAHAVIR TRADING COMPANY,PARWANOO vs. ACIT, CIRCLE, PARWANOO

The appeal stands partly allowed

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No. 435 /Chandi/2022 (िनधा"रणवष" / Assessment Year: 2005-06) M/S Mahavir Trading Company Acit-Circle Parwanoo बनाम/ Booth No. 18 Sector-1 Himachal Pardesh 173220 Vs. Parwanoo (Hp) 173220 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaefm-8949-E (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Neeraj Jain (Ca) – Ld. Ar ""थ"कीओरसे/Respondent By : Dr Ranjit Kaur (Addl. Cit) – Ld.Sr.Dr सुनवाईकीतारीख/Date Of Hearing : 26-06-2025 घोषणाकीतारीख /Date Of : 04-08-2025 Pronouncement आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2005-06 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), Shimla [Cit(A)] Dated 30-01-2020 In The Matter Of An Assessment Framed By Ld. Ao U/S 143(3) On 28-12-2007. This Is Second Round Of Appeal. In The First Round, The Assessment Was Confirmed By Ld. Cit(A) Vide Order Dated 26-05-2008. However, The Matter Was Remanded Back By Tribunal Vide Ita No.795/Chd/2009

delay is condoned and we proceed for adjudication of appeal on merits. Proceedings before lower authorities 2.1 The assessee is stated to be a partnership concern which is engaged in wholesale trading of karyana goods at Parwanoo. The assessee was subjected to survey on 02-11-2004 wherein the assessee surrendered a sum of Rs.30 Lacs. The same include surrender

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, , LUDHIANA vs. DEEPANKAR JAIN, LUDHIANA

In the result appeal of the Department is dismissed and Cross

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

condoned: Memo of appeal of the department received 27.03.2025 by the assessee Due date of filing Cross Objections 26.04.2025 Cross Objections filed on 19.06.2025 Delay 53 days 6. We have gone through the ground of Cross Objections and since the legal issue has been raised about the completion of search assessment u/s 143(3) and all the facts are borne

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.1230/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2019-20) 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.1592/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2019-20) 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 10.03.2026 : आदेश / O R D E R Per Bench 1.1 Aforesaid Cross-Appeals For Assessment Year (Ay) 2019-20Arises Out Of An Order Passed By Ld. Commissioner Of Income Tax (Appeals)-3

survey action u/s 133A which was conducted by the department at the site office viz. Mohali Citi 4 Centre, GMADA, Aerocity, Mohali wherein digital loose papers were found and impounded as Annexure-1 (Pages 16,17 & 18). The seized papers, inter-alia, contained list of customer’s names, sale price, unit and address along with welcome letter-cum-receipt allegedly

SARAF THE JEWELLERS, CHANDIGARH,CHANDIGARH vs. THE DEPUTY/ASSISTANT COMMISSIONER OF INCOME TAX CEN-2 CHANDIGARH, CHANDIGARH

Appeal stand dismissed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं. / Ita No.1230/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2019-20) 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.1592/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2019-20) 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 10.03.2026 : आदेश / O R D E R Per Bench 1.1 Aforesaid Cross-Appeals For Assessment Year (Ay) 2019-20Arises Out Of An Order Passed By Ld. Commissioner Of Income Tax (Appeals)-3

survey action u/s 133A which was conducted by the department at the site office viz. Mohali Citi 4 Centre, GMADA, Aerocity, Mohali wherein digital loose papers were found and impounded as Annexure-1 (Pages 16,17 & 18). The seized papers, inter-alia, contained list of customer’s names, sale price, unit and address along with welcome letter-cum-receipt allegedly

THE ASSISTANT EXCISE & TAXATION COMMISSIONER ,SHIMLA vs. ADDL. CIT, RANGE, SHIMLA

In the result, all four appeals filed by the assessee are allowed

Bench: Smt. Diva Singh & Shri Vikram Singh Yadavआयकरअपीलसं./Ita No.903 /Chd/2019 "नधा"रण वष" / Assessment Year :2007-08 The Assistant Excise & बनाम The Additional Cit, Taxation Commissioner, Tds Range, Nahan Shimla "थायीलेखासं./Pan/Tan No: Ptla12468B अपीलाथ"/Appellant ""यथ"/Respondent

delay so happened is hereby condoned and all these appeals are admitted for adjudication. ITA Nos. 903 to 905-Chd-2019 - Assistant Excise & Taxation Commissioner Nahan & Othrs 3 3. Since common issue relating to levy of penalty u/s 271CA is involved, all these appeals were heard together and are being disposed off by this consolidated order. With the consent

THE ASSISTANT EXCISE & TAXATION COMMISSIONER ,NAHAN vs. ADDL. CIT, RANGE, SHIMLA

In the result, all four appeals filed by the assessee are allowed

Bench: Smt. Diva Singh & Shri Vikram Singh Yadavआयकरअपीलसं./Ita No.903 /Chd/2019 "नधा"रण वष" / Assessment Year :2007-08 The Assistant Excise & बनाम The Additional Cit, Taxation Commissioner, Tds Range, Nahan Shimla "थायीलेखासं./Pan/Tan No: Ptla12468B अपीलाथ"/Appellant ""यथ"/Respondent

delay so happened is hereby condoned and all these appeals are admitted for adjudication. ITA Nos. 903 to 905-Chd-2019 - Assistant Excise & Taxation Commissioner Nahan & Othrs 3 3. Since common issue relating to levy of penalty u/s 271CA is involved, all these appeals were heard together and are being disposed off by this consolidated order. With the consent

THE ASSISTANT EXCISE & TAXATION COMMISSIONER ,SHIMLA vs. ADDL. CIT, RANGE, SHIMLA

In the result, all four appeals filed by the assessee are allowed

Bench: Smt. Diva Singh & Shri Vikram Singh Yadavआयकरअपीलसं./Ita No.903 /Chd/2019 "नधा"रण वष" / Assessment Year :2007-08 The Assistant Excise & बनाम The Additional Cit, Taxation Commissioner, Tds Range, Nahan Shimla "थायीलेखासं./Pan/Tan No: Ptla12468B अपीलाथ"/Appellant ""यथ"/Respondent

delay so happened is hereby condoned and all these appeals are admitted for adjudication. ITA Nos. 903 to 905-Chd-2019 - Assistant Excise & Taxation Commissioner Nahan & Othrs 3 3. Since common issue relating to levy of penalty u/s 271CA is involved, all these appeals were heard together and are being disposed off by this consolidated order. With the consent

THE ASSISTANT EXCISE & TAXATION COMMISSIONER ,NAHAN vs. ADDL. CIT, RANGE, SHIMLA

In the result, all four appeals filed by the assessee are allowed

Bench: Smt. Diva Singh & Shri Vikram Singh Yadavआयकरअपीलसं./Ita No.903 /Chd/2019 "नधा"रण वष" / Assessment Year :2007-08 The Assistant Excise & बनाम The Additional Cit, Taxation Commissioner, Tds Range, Nahan Shimla "थायीलेखासं./Pan/Tan No: Ptla12468B अपीलाथ"/Appellant ""यथ"/Respondent

delay so happened is hereby condoned and all these appeals are admitted for adjudication. ITA Nos. 903 to 905-Chd-2019 - Assistant Excise & Taxation Commissioner Nahan & Othrs 3 3. Since common issue relating to levy of penalty u/s 271CA is involved, all these appeals were heard together and are being disposed off by this consolidated order. With the consent

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

survey u/s 133A at assessee’s site office viz. Mohali Citi Centre, GMADA, Aerocity, Mohali, certain digital loose papers were found and impounded as Annexure-1 (Pages 16,17 & 18). The seized papers, inter-alia, contained list of customer’s names, sale price, unit and address along with welcome letter cum receipt allegedly issued by the assessee against sale