S.P. SINGLA CONSTRUCTION PRIVATE LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CHANDIGARH

In the result, the appeal is allowed

Bench: SHRI MAHAVIR SINGH (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

132 of the Act and relevant assessment year is 2012-13 and further the re- opening notice is dated 20.03.2019, which is beyond four years. The only saving grace will remain for Department that if the Department proves that there is any failure on the part of the assessee to disclose fully and truly all material facts necessary

ROSHA ALLOYS P LIMITED, AMLOH ROAD, VILLAGE TURAN, MANDI GOBINDGARH,PUNJAB vs. DCIT CENTRAL CIRCLE 1, LUDHIANA, PUNJAB

In the result, the appeals filed by the Revenue are dismissed,\nwhereas the appeals of the assessee are allowed

depreciation\nallowance or any other\nallowance or deduction\nfor such assessment year\n(hereafter in this section\nand in sections 148 to 153\nreferred to as the\nrelevant assessment\nyear).\nUp to Finance Act 2020\n147. If the 5 [Assessing] Officer [has\nreason to believe”] that any income\nchargeable to tax has escaped\nassessment for any assessment year

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, LUDHIANA , LUDHIANA vs. ROSHA ALLOYS PVT. LTD., MANDI GOBINDGARH

In the result, the appeals filed by the Revenue are dismissed,\nwhereas the appeals of the assessee are allowed

depreciation\nallowance or any other\nallowance or deduction\nfor such assessment year\n(hereafter in this section\nand in sections 148 to 153\nreferred relevant\nyear).\nas the assessment\n147. If the 5 [Assessing] Officer [has\nreason to believe”] that any income\nchargeable to tax has escaped\nassessment for any assessment year,\nhe may, subject to the provisions\nof sections

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, LUDHIANA , LUDHIANA vs. ROSHA ALLOYS PVT. LTD., MANDI GOBINDGARH

In the result, the appeals filed by the Revenue are dismissed,\nwhereas the appeals of the assessee are allowed

depreciation\nallowance or any other\nallowance or deduction\nfor such assessment year\n(hereafter in this section\nand in sections 148 to 153\nreferred relevant\nyear).\nto\nas the\nassessment\nUp to Finance Act 2020\n147. If the 5 [Assessing] Officer [has\nreason to believe”] that any income\nchargeable to tax has escaped\nassessment for any assessment year

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, LUDHIANA , LUDHIANA vs. ROSHA ALLOYS PVT. LTD., MANDI GOBINDGARH

In the result, the appeals filed by the Revenue are dismissed,\nwhereas the appeals of the assessee are allowed

depreciation\nallowance or any other\nallowance or deduction\nfor such assessment year\n(hereafter in this section\nand in sections 148 to 153\nreferred to as the\nrelevant\nyear).\nassessment\nUp to Finance Act 2020\n147. If the 5 [Assessing] Officer [has\nreason to believe”] that any income\nchargeable to tax has escaped\nassessment for any assessment year

ACIT, CC-2, CHANDIGARH vs. M/S TJR PROPERTIES PVT. LTD., CHANDIGARH

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

132 of the Act in the case of the appellant -company, is perverse and wholly erroneous and therefore, the Order of assessment passed under Section 153A of the Act is without jurisdiction. 5. That the additions made in the assessment Order are not based on any corroborative and relevant incriminating material stated to have been unearthed during the course

M/S TJR PROPERTIES PVT. LTD.,CHANDIGARH vs. ACIT, CC-2, CHANDIGARH

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

132 of the Act in the case of the appellant -company, is perverse and wholly erroneous and therefore, the Order of assessment passed under Section 153A of the Act is without jurisdiction. 5. That the additions made in the assessment Order are not based on any corroborative and relevant incriminating material stated to have been unearthed during the course

M/S TJR PROPERTIES PVT. LTD.,CHANDIGARH vs. ACIT, CC-2, CHANDIGARH

In the result, the Appeal is partly allowed

Bench: Shri A.D. Jain & Shri Vikram Singh Yadav

132 of the Act in the case of the appellant -company, is perverse and wholly erroneous and therefore, the Order of assessment passed under Section 153A of the Act is without jurisdiction. 5. That the additions made in the assessment Order are not based on any corroborative and relevant incriminating material stated to have been unearthed during the course

ACIT, CC-2, CHANDIGARH vs. M/S TJR PROPERTIES PVT. LTD., CHANDIGARH

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

132 of the Act in the case of the appellant -company, is perverse and wholly erroneous and therefore, the Order of assessment passed under Section 153A of the Act is without jurisdiction. 5. That the additions made in the assessment Order are not based on any corroborative and relevant incriminating material stated to have been unearthed during the course

M/S TJR PROPERTIES PVT. LTD.,CHANDIGARH vs. ACIT, CC-2, CHANDIGARH

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

132 of the Act in the case of the appellant -company, is perverse and wholly erroneous and therefore, the Order of assessment passed under Section 153A of the Act is without jurisdiction. 5. That the additions made in the assessment Order are not based on any corroborative and relevant incriminating material stated to have been unearthed during the course

M/S SANJAY SINGAL HUF,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

Section 132(4) of the Act, by Shri Shrish Chandrakant Shah and Shri R.K. Kedia, were supported by seizure of a large number of incriminating documents, during the course of search proceedings carried out in their cases, including cash books reflecting flow of ITA 655/CHD/2023 & ITA 610/CHD/2023 A.Y. 2015-16 6 unaccounted cash from such beneficiaries, including the appellant

SANJAY SINGAL,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CC-1, CHANDIGARH

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

Section 132(4) of the Act, by Shri Shrish Chandrakant Shah and Shri R.K. Kedia, were supported by seizure of a large number of incriminating documents, during the course of search proceedings carried out in their cases, including cash books reflecting flow of ITA 655/CHD/2023 & ITA 610/CHD/2023 A.Y. 2015-16 6 unaccounted cash from such beneficiaries, including the appellant

M/S TJR PROPERTIES PVT. LTD.,CHANDIGARH vs. ACIT, CC-2, CHANDIGARH

In the result, the Appeal is partly allowed

Bench: Shri A.D. Jain & Shri Vikram Singh Yadav

132 of the Act in the case of the appellant-company, is perverse and wholly erroneous and therefore, the Order of assessment passed under section 153A of the Act is without jurisdiction. 5. That the learned C.I.T.(A) has wrongly upheld additions made in the assessment order which are not based on any corroborative and relevant incriminating material stated

KAKA SINGH ALIAS GULJAR SINGH,PATIALA vs. INCOME TAX OFFICER , PATIALA

section 57.\nThe said provision reads thus:\n\"57. Deductions.-The income chargeable under the head 'Income from other\nsources' shall be computed after making the following deductions, namely :.\n(iv) in the case of income of the nature referred to in clause (viii) of sub-\nsection (2) of section 56, a deduction of a sum equal to fifty

VIMAL ALLOYS PRIVATE LIMITED, MANDI GOBINDGARH,PUNJAB vs. JAO THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE, PATIALA, PUNJAB

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

132 and 133A of the Income Tax Act, 1961. During the search proceedings as one of the group concern of the WWG namely M/s. Futuristic Metal Trading Pvt ltd.(FMTPL), was surveyed by the department wherein an excel sheet namely ‘Cash & CH report 14.11.17.xlsx’ was found from the premises of the FMTPL, and the said excel sheet received was examined

SAS INFONET PRIVATE LIMITED ,CHANDIGARH vs. DCIT ACIT(CEN)-2, CHANDIGARH

In the result, the present appeal of the Assessee is allowed

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

132 of the Act was conducted on 28.01.2021 on the Desh Bhagat Educational Trust group, and the case of the assessee was centralized with the DCIT, Central Circle-II, Chandigarh. 4.1 The AO framed the assessment under section 153A read with section 143(3) of the Act on 30.03.2022 and made an aggregate addition of Rs.22,36,809/-, comprising

SAS INFONET PRIVATE LIMITED,CHANDIGARH vs. DCIT ACIT(CEN)-2, CHANDIGARH

In the result, the present appeal of the Assessee is allowed

Bench: the AO.

132 of the Act was conducted on 28.01.2021 on the Desh Bhagat Educational Trust group, and the case of the assessee was centralized with the DCIT, Central Circle-II, Chandigarh. 4.1 The AO framed the assessment under section 153A read with section 143(3) of the Act on 30.03.2022 and made an aggregate addition of Rs.22,36,809/-, comprising

KANDI FRIENDS EDUCATIONAL TRUST,ROPAR vs. DEPUTY COMMISSIONER OF INCOME TAX, CHANDIGARH

In the result, both the appeals are allowed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahay

132 to 184. Every year, the AO has asked for the details of honorarium paid to the members of the Management Committee and these honorariums have been allowed to the assessee. Thus, according to the ld. counsel for the assessee, the AO has committed an error by denying the benefit of Section 11. He put reliance upon the judgement

KANDI FRIENDS EDUCATIONAL TRUST,ROPAR vs. DEPUTY COMMISSION OF INCOME TAX, CL. 1, EXEMPTION, CHANDIGARH

In the result, both the appeals are allowed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahay

132 to 184. Every year, the AO has asked for the details of honorarium paid to the members of the Management Committee and these honorariums have been allowed to the assessee. Thus, according to the ld. counsel for the assessee, the AO has committed an error by denying the benefit of Section 11. He put reliance upon the judgement