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

unexplained cash credit u/s 68, the assessee contended that it furnished complete details of all the lenders including name, address, confirmation, PAN and bank statements. The loans were received through normal banking channels. There was no material to suggest that the same represent assessee’s unaccounted money. No enquiry was made from any of the lender parties and there

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

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

unexplained cash credit u/s 68 as tabulated below: - No. Name of Amount of Repayment Repayment Documents furnished by the Lender Loan (Rs.) during AY during AY assessee 2020-21 2021-22 1. Shri Ajaib Rs.60.00 Lacs Copy of account, Assessee’s bank Singh s/o statement, Aadhar Card, PAN and death Basta Singh certificate 2. Gagan Sharma Rs.25.00 Lacs --- 3. Gora

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

unexplained cash credit u/s 68 as tabulated below: - No. Name of Amount of Repayment Repayment Documents furnished by the Lender Loan (Rs.) during AY during AY assessee 2020-21 2021-22 1. Shri Ajaib Rs.60.00 Lacs Copy of account, Assessee’s bank Singh s/o statement, Aadhar Card, PAN and death Basta Singh certificate 2. Gagan Sharma Rs.25.00 Lacs --- 3. Gora

SHRI SATISH SOIN,LUDHIANA vs. ACIT, CC-II, LUDHIANA

In the result, appeal of the assessee is allowed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 303/Chd/2019 "नधा"रण वष" / Assessment Year : 2012-13 Shri Satish Soin, बनाम The Acit, House No.31, Garden Enclave, Central Circle-2, Vs South City-Ii, Ludhiana. Ludhiana. "थायी लेखा सं./Pan /Tan No: Advps6254N अपीलाथ"/Appellant ""यथ"/Respondent "नधा"रती क" ओर से/Assessee By : Shri Ashwani Kumar & Ms. Muskan Garg, Cas राज"व क" ओर से/ Revenue By : Smt. Kusum Bansal, Cit Dr तार"ख/Date Of Hearing : 26.05.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 23.07.2025 Hybrid Hearing आदेश/Order Per Rajpal Yadav, Vp

condone the delay and proceed to decide the appeals on merit. 7. Both the appellants have raised an additional ground of appeal vide which, it has been pleaded that original assessment order passed under Section 153A read with Section 143(3) of the Act was required to be approved by the Commissioner of Income Tax under Section 153D. This approval

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

delay could be condoned for maximum period of 3 years from due date and in case of breach of conditions of allotment letter, 10% of total price plus interest due till date would be forfeited and the site or building would be liable to be resumed. These facts are borne out of allotment letter as issued by GMADA

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

delay could be condoned for maximum period of 3 years from due date and in case of breach of conditions of allotment letter, 10% of total price plus interest due till date would be forfeited and the site or building would be liable to be resumed. These facts are borne out of allotment letter as issued by GMADA

SMT. JAGDEEP KAUR,LUDHIANA vs. ITO, WARD 6(4), LUDHIANA

In the result, appeal of the Assessee is dismissed

Bench: This Hon’Ble Tribunal Under Section 253 Of The Income Tax Act, 1961. 3. The Assessee Is Aggrieved By Din & Order No. Itba/Nfac/S/250/2022- 23/1048105767(1) Dt. 20/12/2022 Which Was Passed By The Ld. Cit(A) Nfac, Delhi Under Section 250 Of The Income Tax Act, 1961. The Said First Appeal Was Dismissed By The Ld. Cit(A). Therefore Assessee Is Before Us. The Said Order Of The Ld. Cit(A) Is Hereinafter Referred To As The “Impugned Order”. 4. In Form No. 36 The Assessee Interalia Has Take Up Following Grounds Of Appeal Against The Impugned Order Which Are Reproduced Below:

credit u/s 68 has been passed by your office vide order dt. 24/12/2018. The assessment order was delivered to the assessee on 05/03/2019 by the department after tracing the latest available address of the assessee on the basis of mobile/phone number fo the assessee / her husband. Notices issued u/s 148/142(1) of the Income Tax Act were not served

BANGA HOSPITALS PRIVATE LIMITED,MANDI vs. ITO, MANDI

In the result, appeal of the Assessee is partly allowed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

condone the delay for which sufficient cause is shown, and admit the appeal for adjudication. 4. In the present appeal Assessee has raised the following grounds: On the facts and in the circumstances of the case and in law the Ld. Commissioner of Income Tax (Appeals) NFAC erred in passing the order without appreciating the facts, documentary evidences produced

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 read with\nSection

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 read with\nSection

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 read with\nSection

INCOME TAX OFFICER, WARD-1(3), LUDHIANA, LUDHIANA vs. SHREE BALAJI PROCESSORS, LUDHIANA

In the result, appeal of the Revenue is dismissed whereas, the 29

Bench: Shri A.D. Jain & Dr Krinwant Sahayआयकर अपील सं./ Ita No. 499/Chd/2023 "नधा"रण वष" / Assessment Year : 2017-18 The Ito, Vs. Shree Balaji Processors, बनाम Ward-1(3), Tajpur Road, Ludhiana Opp. Central Jail, Ludhiana 141010 "थायी लेखा सं./Pan No: Actfs8428B अपीलाथ"/ Appellant ""यथ"/ Repsondent & C.O. No. 09/Chd/2024 ( In आयकर अपील सं./ Ita No. 499/Chd/2023) "नधा"रण वष" / Assessment Year : 2017-18 Shree Balaji Processors, Vs. The Ito, बनाम Tajpur Road, Ward-1(3), Opp. Central Jail, Ludhiana Ludhiana 141010 "थायी लेखा सं./Pan No: Actfs8428B अपीलाथ"/ Appellant ""यथ"/ Repsondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : Shri Sudhir Sehgal, Advocate राज"व क" ओर से/ Revenue By : Smt. Kusum Bansal, Cit Dr सुनवाई क" तार"ख/Date Of Hearing : 26.06.2024 उदघोषणा क" तार"ख/Date Of Pronouncement : 20.08.2024

credit limit as per the regular business requirement and for the daily working capital requirements and as mentioned earlier the cash deposited has been utilized for the payment of the creditors. Moreover, the cash withdrawn from the bank accounts of the assessee is again an individual and business decision and the same can depend on various factors such a requirement

SUKHWINDER SINGH,AMBALA CANTT vs. INCOME TAX OFFICER, AMBALA

The appeal of the assessee is treated as allowed for

Bench: SHRI A.D.JAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)

condoning the appeal on ground of reasonable cause. However, the notices were issued at the assessee's earlier address at Ambala however; he shifted to Delhi with his family long back. 3. That the Ld. AO has erred in law by treating the cash deposits of Rs. 69,29,878/- as unexplained credits under section 68, whereas the same were

THE MULLANA AGRICULTURE COOP SOCIETY LIMITED,AMBALA CITY vs. ITO, WARD-5, AMBALA

Bench: SHRI A.D.JAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)

unexplained cash credit u/s 68 of the Income Tax Act. ITA 274/CHD/2023 A.Y. 2017-18 2 2. At the outset, it is noted that there is a delay in filing the present appeal of 233 days. In this regard, the assessee has filed an application dated 28.12.2023 explaining the reasons/circumstances for occurring the delay in filing of the appeal

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

condonation of delay.\n3. It has been submitted before us that in the Cross Objections, assessee\nhas raised a jurisdictional issue on the ground that no Warrant of\nAuthorization was issued to conduct the search upon the premises of the\nassessee. According to the ld. Counsel for the assessee, the Warrant of\nAuthorization was issued in the name

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

condonation of delay.\n3.\nIt has been submitted before us that in the Cross Objections, assessee\nhas raised a jurisdictional issue on the ground that no Warrant of\nAuthorization was issued to conduct the search upon the premises of the\nassessee. According to the ld. Counsel for the assessee, the Warrant of\nAuthorization was issued in the name

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

condonation of delay.\n3. It has been submitted before us that in the Cross Objections, assessee\nhas raised a jurisdictional issue on the ground that no Warrant of\nAuthorization was issued to conduct the search upon the premises of the\nassessee. According to the ld. Counsel for the assessee, the Warrant of\nAuthorization was issued in the name

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

condonation of delay.\n3.\nIt has been submitted before us that in the Cross Objections, assessee\nhas raised a jurisdictional issue on the ground that no Warrant of\nAuthorization was issued to conduct the search upon the premises of the\nassessee. According to the ld. Counsel for the assessee, the Warrant of\nAuthorization was issued in the name