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

153C was also automatic in respect of “other persons\" based\non seized material. However, the legal position has now been\nsettled by the Hon'ble Supreme Court in the landmark judgment of\nPrincipal CIT v. Abhisar Buildwell Pvt. Ltd., reported in 150\nTaxmann.com 257, wherein it was categorically held that:-\n\"In respect of completed or non-pending assessment years

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

153C was also automatic in respect of “other persons" based on seized material. However, the legal position has now been\nsettled by the Hon'ble Supreme Court in the landmark judgment of\nPrincipal CIT v. Abhisar Buildwell Pvt. Ltd., reported in 150\nTaxmann.com 257, wherein it was categorically held that:-\n\"In respect of completed or non-pending assessment years

RAJESH KHANNA,NEELKANTH PLYWOOD, YAMUNANAGAR vs. INCOME TAX OFFICER, WARD-3, INCOME TAX OFFICER, YAMUNANAGAR

In the result, the assessee's appeal in ITA

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

153C ITA 62, 230/CHD/2024 & S.A.11/CHD/2024 A.Y.2018-19 14 of the Act were not invoked and instead, the re-opening has been initiated u/s 147 of the Act after 01.04.2021, which is specifically barred by the second proviso to Section 149 of the Act. In this regard, reliance has been sought to be placed on the order dated 19.03.2024, rendered

INCOME TAX OFFICER, YAMUNA NAGAR vs. RAJESH KHANNA, YAMUNA NAGAR

In the result, the assessee's appeal in ITA

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

153C ITA 62, 230/CHD/2024 & S.A.11/CHD/2024 A.Y.2018-19 14 of the Act were not invoked and instead, the re-opening has been initiated u/s 147 of the Act after 01.04.2021, which is specifically barred by the second proviso to Section 149 of the Act. In this regard, reliance has been sought to be placed on the order dated 19.03.2024, rendered

KHANNA INFRABUILD PRIVATE LIMITED ,LUDHIANA vs. THE DEPUTY COMMISSIONER OF INCOME TAX (CENTRAL CIRCLE)-2, LUDHIANA, LUDHIANA

In the result, the ground of appeal is allowed

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

153C of the Act. However, the department did not act on the said documents. Even otherwise, the said slip was a third party document, which was never confronted to the assessee. The difference of the amount mentioned in the said slip was also meager as compared to the additions made by the Assessing Officer. Thirdly, since the said document

KHANNA INFRABUILD PRIVATE LIMITED ,LUDHIANA vs. THE DEPUTY COMMISSIONER OF INCOME TAX (CENTRAL CIRCLE)-2 LUDHIANA, LUDHIANA

In the result, the ground of appeal is allowed

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

153C of the Act. However, the department did not act on the said documents. Even otherwise, the said slip was a third party document, which was never confronted to the assessee. The difference of the amount mentioned in the said slip was also meager as compared to the additions made by the Assessing Officer. Thirdly, since the said document

KHANNA INFRABUILD PRIVATE LIMITED 2000-1A, SUKHDEV NAGAR FEROZEPUR ROAD, LUDHIANA,LUDHIANA vs. THE DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2 LUDHIANA, LUDHIANA

In the result, the ground of appeal is allowed

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

153C of the Act. However, the department did not act on the said documents. Even otherwise, the said slip was a third party document, which was never confronted to the assessee. The difference of the amount mentioned in the said slip was also meager as compared to the additions made by the Assessing Officer. Thirdly, since the said document