ACIT, CIRCLE 5(1),, CHANDIGARH vs. M/S VENUS REMEDIES LTD.,, CHANDIGARH

The appeal of the revenue stand dismissed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No.742/Chandi/2009 (िनधा"रणवष" / Assessment Year: 2006-07) Acit Circle 5(1) M/S Venus Remedies Ltd. बनाम/ Vs. Sco 40-41, Sector 17-A Sco 39, Sector – 26 Chandigarh – 160017 Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaacv-6524-H (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant : Sh. Parikshit Aggarwal (Ca), Sh. Jaspal Sharma (Advocate)&Ms. Shruti Khandelwal (Advocate) – By Ld. Ars ""थ"कीओरसे/Respondent By : Sh. Yamini (Cit) - Ld. Dr (Virtual) सुनवाईकीतारीख/Date Of Hearing : 02.02.2026 घोषणाकीतारीख /Date Of Pronouncement : 09.03.2026 आदेश / O R D E R Manoj Kumar Aggarwal () 1.1 Aforesaid Appeal For Assessment Year (Ay) 2006-07 Has Come Up For Hearing Before Us Pursuant To The Directions Of Hon’Ble Punjab & Haryana High Court In Revenue’S Appeal Ita No.81-2012 Dated 25-07-2024 Wherein Following Substantial Questions Of Law Were Determined: - 1. Weather On The Facts & In The Circumstances Of The Case, The Hon’Ble Itat Was Right In Upholding The Decision Of Ld. Cit(A) Who Directed The Ao To Reallocate The Expenses On Sales Ratio & To Reduce The Addition To Rs.142.24 Lacs As Against The Addition Of Rs.7,61,96,306/- On Account Of Unexplained Expenditure U/S 69C?

Depreciation of Rs.1,63,04,928/-, Capital Expenditure on R&D u/s 35(2) of Rs.3,00,67,328/- and deferred revenue expenses on scientific research u/s 35(2) of Rs.1,55,36,344/- to the Baddi unit for purposes of determining deduction u/s 80IC, when the assessee had not produced separate books of accounts for the two units

ITO, WARD-6(1), MOHALI vs. QUARKCITY INDIA PVT. LTD., MPHALI

In the result, the appeal filed by the Revenue is dismissed

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

63,92,824/- (Rs. 66,06,128 - Rs. 2,13,304) as claimed by the Assessee Company were relating to depreciation of rented building, furniture and fixtures, hardware and software, office equipment's and vehicles deployed in the rented building. These assets have no direct or indirect connection with CWIP & PWIP. The necessary material in this regard was produced before

ITO, WARD-6(1), MOHALI vs. QUARKCITY INDIA PVT. LTD., MPHALI

In the result, the appeal filed by the Revenue is dismissed

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

63,92,824/- (Rs. 66,06,128 - Rs. 2,13,304) as claimed by the Assessee Company were relating to depreciation of rented building, furniture and fixtures, hardware and software, office equipment's and vehicles deployed in the rented building. These assets have no direct or indirect connection with CWIP & PWIP. The necessary material in this regard was produced before

ITO, WARD-6(1), MOHALI vs. QUARKCITY INDIA PVT. LTD., MPHALI

In the result, the appeal filed by the Revenue is dismissed

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

63,92,824/- (Rs. 66,06,128 - Rs. 2,13,304) as claimed by the Assessee Company were relating to depreciation of rented building, furniture and fixtures, hardware and software, office equipment's and vehicles deployed in the rented building. These assets have no direct or indirect connection with CWIP & PWIP. The necessary material in this regard was produced before

ITO, WARD-6(1), MOHALI vs. QUARKCITY INDIA PVT. LTD., MOHALI

In the result, the appeal filed by the Revenue is dismissed

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

63,92,824/- (Rs. 66,06,128 - Rs. 2,13,304) as claimed by the Assessee Company were relating to depreciation of rented building, furniture and fixtures, hardware and software, office equipment's and vehicles deployed in the rented building. These assets have no direct or indirect connection with CWIP & PWIP. The necessary material in this regard was produced before

ITO, WARD-6(1), MOHALI vs. QUARKCITY INDIA PVT. LTD., MPHALI

In the result, the appeal filed by the Revenue is dismissed

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

63,92,824/- (Rs. 66,06,128 - Rs. 2,13,304) as claimed by the Assessee Company were relating to depreciation of rented building, furniture and fixtures, hardware and software, office equipment's and vehicles deployed in the rented building. These assets have no direct or indirect connection with CWIP & PWIP. The necessary material in this regard was produced before

ITO, WARD-6(1), MOHALI vs. QUARKCITY INDIA PVT. LTD., MOHALI

In the result, the appeal filed by the Revenue is dismissed

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

63,92,824/- (Rs. 66,06,128 - Rs. 2,13,304) as claimed by the Assessee Company were relating to depreciation of rented building, furniture and fixtures, hardware and software, office equipment's and vehicles deployed in the rented building. These assets have no direct or indirect connection with CWIP & PWIP. The necessary material in this regard was produced before

ITO, WARD-6(1), MOHALI vs. QUARKCITY INDIA PVT. LTD., MOHALI

In the result, the appeal filed by the Revenue is dismissed

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

63,92,824/- (Rs. 66,06,128 - Rs. 2,13,304) as claimed by the Assessee Company were relating to depreciation of rented building, furniture and fixtures, hardware and software, office equipment's and vehicles deployed in the rented building. These assets have no direct or indirect connection with CWIP & PWIP. The necessary material in this regard was produced before

ITO, WARD-6(1), MOHALI vs. QUARKCITY INDIA PVT. LTD., MOHALI

In the result, the appeal filed by the Revenue is dismissed

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

63,92,824/- (Rs. 66,06,128 - Rs. 2,13,304) as claimed by the Assessee Company were relating to depreciation of rented building, furniture and fixtures, hardware and software, office equipment's and vehicles deployed in the rented building. These assets have no direct or indirect connection with CWIP & PWIP. The necessary material in this regard was produced before

ITO, WARD-6(1), MOHALI vs. QUARKCITY INDIA PVT. LTD., MOHALI

In the result, the appeal filed by the Revenue is dismissed

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

63,92,824/- (Rs. 66,06,128 - Rs. 2,13,304) as claimed by the Assessee Company were relating to depreciation of rented building, furniture and fixtures, hardware and software, office equipment's and vehicles deployed in the rented building. These assets have no direct or indirect connection with CWIP & PWIP. The necessary material in this regard was produced before

SBS BIOTECH UNIT II,SIRMOUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX-1, CHANDIGARH

In the result, the appeal of the assessee is allowed

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

depreciation in any year), as on the first day of the previous year in which the substantial expansion is undertaken." 9. The circular makes it clear that section 80IC of the Act was inserted to give effect to the new package announced by the Union Cabinet. The circular further clarifies that this section provides for deduction for a period

WINSOME TEXTILE INDUSTRIES LIMITED,CHANDIGARH vs. ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-4(1), CHANDIGARH, CHANDIGARH

In the result, the appeal of the assessee is partly allowed and the appeal of the Revenue is dismissed

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

depreciation allowance or any other allowance, as the case may be, for the A.Y. concerned". A bare perusal of the above provisions the AO has power to extend his enquiry beyond reasons recorded on the issue which came to his knowledge during the course of pending proceedings. During the course of pending proceedings it came to the notice

CEIGALL INDIA LIMITED, LUDHIANA,LUDHIANA vs. PRINCIPAL COMMISSIONER OF INCOME TAX, LUDHIANA, LUDHIANA

In the result, the appeal of the assessee stands allowed

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

depreciation as per provisions of Income Tax Act. 5.6 From the summary of the findings of the Ld. PCIT reproduced hereinabove we can safely conclude that The AO did conduct enquiries on all scrutiny issues, considered assessee’s  submissions, and recorded findings. The PCIT has not demonstrated what specific further enquiry was  necessary or how AO’s view was unsustainable

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)

63,625 21 Swastik Construction ABFFS5101G 4,99,85,804 22 Unique Construction AABFU7844B 23,78,145 Jai Durga Engineering and 23 Construction AAFFJ0221R 30,75,446 24 SS Construction Engineering ABCFS4260N 25,88,301 Hind Construction Engineers 25 Contractors AADFH9919A 42,00,000 India Engineers and 26 Contractors AABF1869E 53,08,069 Balaji Engineers and 27 Contractors AAIFB1217A

SH. GURINDER MAKKAR,LUDHIANA vs. DCIT, CC-3, LUDHIANA

In the result, the appeal of the assessee is disposed off in light of aforesaid directions

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

63,130/- including the surrendered income. 3.1 During the course of assessment proceedings, the AO observed that the surrender relates to unexplained investment which is covered under section under section 69/69B/69C and accordingly a show cause was issued as to why the surrender amount of Rs. 50,53,000/- should not be taxed as per the provisions of Section 115BBE

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

63,80,000/- by applying the\naverage of annual power consumption for the six years and by failing to\nobtain the reasons for substantial increase in the turnover and decrease in\naverage annual power consumption after the period of search i.e. for AY\n2021-22 & AY 2022-23?\n4.\nWhether on facts and circumstances of the case

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

63,80,000/- by applying the\naverage of annual power consumption for the six years and by failing to\nobtain the reasons for substantial increase in the turnover and decrease in\naverage annual power consumption after the period of search i.e. for AY\n2021-22 & AY 2022-23?\n4.\nWhether on facts and circumstances of the case

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

63,80,000/- by applying the\naverage of annual power consumption for the six years and by failing to\nobtain the reasons for substantial increase in the turnover and decrease in\naverage annual power consumption after the period of search i.e. for AY\n2021-22 & AY 2022-23?\n4.\nWhether on facts and circumstances of the case