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)

depreciation of such building would result in double taxation. 6.9 It was submitted that as the assessee has duly paid tax on all such amount of surrender made by the assessee, therefore, making additions of the same amount to the total income of the assessee are wholly invalid as it results 'double taxation and therefore, against the principles of natural

M/S SEL MANUFACTURING CO. LTD.,LUDHIANA vs. DCIT, CC-3, LUDHIANA

In the result, appeal is allowed

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

69C. 3. That he further gravely erred in making an addition of Rs. 16,27,714/- representing 2% of alleged bogus purchase of Rs. 8,13,85,737/-. 2. The following Additional Ground has also been raised: “That the order dated 29.12.2018 passed under section 250(6) of the Income Tax Act, 1961 by the learned Commissioner of Income

SH. MOHIT MITTAL PROP. MITTAL ENTERPRISES,LUDHIANA, PUNJAB vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE - 1 LUDHIANA, LUDHIANA, PUNJAB

In the result, appeal is allowed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahay

69C and 69D, the provisions of Section II5BBE are not attracted in this case. 10. In view of the above, the action of the lower authorities in invoking provisions of Section II5BBE on the surrender income of Rs. 15 lacs is set aside and the AO is directed to compute the said surrendered A.Y.2020-21 9 income under normal provisions

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

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

Section 69C of the Act, on account of alleged unaccounted ITA 655/CHD/2023 & ITA 610/CHD/2023 A.Y. 2015-16 33 commission paid by the assessee at the rate of 6.5% for the purpose of earning the Long Term Capital Gain. 7. The first observation of the ld. CIT(A), as challenged before us, is that the share price of M/s Maa Jagdambe

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 69C of the Act, on account of alleged unaccounted ITA 655/CHD/2023 & ITA 610/CHD/2023 A.Y. 2015-16 33 commission paid by the assessee at the rate of 6.5% for the purpose of earning the Long Term Capital Gain. 7. The first observation of the ld. CIT(A), as challenged before us, is that the share price of M/s Maa Jagdambe

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?

section 69C comes to Rs.16.38 crores.” 7. In our view, the order passed by the ld. CIT(A) in this behalf is quite reasonable. He is right in his observation that the NP rate in respect of Baddi unit was higher than Panchkula unit because the assessee had not properly allocated the expenses to Baddi unit

LAKHVIR KAUR,MOHALI, CHANDIGARH vs. DCIT/ACIT(CEN)-2 CHD, CHANDIGARH

In the result, both the above appeals of the Assessee are\nallowed

depreciation and interest on car loan.\n7. That on the facts and circumstances of the case, the Ld.\nAdditional Commissioner of Income Tax, Range Central failed to\napply due application of mind in giving approval u/s 153D of the\nAct and as such the order deserves to be quashed on this ground\nalone.\n8. That the appellant craves leave

LAKHVIR KAUR,MOHALI vs. DCIT/ACIT(CEN)-2, CHANDIGARH

In the result, both the above appeals of the Assessee are\nallowed

depreciation and interest on car loan.\n7. That on the facts and circumstances of the case, the Ld.\nAdditional Commissioner of Income Tax, Range Central failed to\napply due application of mind in giving approval u/s 153D of the\nAct and as such the order deserves to be quashed on this ground\nalone.\n8. That the appellant craves leave

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, LUDHIANA, LUDHIANA vs. GPG CATTLE FEED PVT. LTD., MOGA

In the result, the Revenue appeal is partly allowed and the Cross Objection of\nthe assessee is dismissed

69C as the\ncase may be.\"\nThe Hon'ble Bench further relied upon the Judgment of Khurana Mills Pvt. Ltd. of\nChandigarh Bench and finally held in para 10 as under:-\n“10. In the case of Sant Steel & Alloys (supra) the Hon'ble Tribunal found\non factual basis that the amount received by the assessee is an\naccommodation entry

M/S ASHA TECHNOLOGIES,SIRMOUR vs. ADDL. CIT, SOLAN

In the result, both the above appeals of the Assessee are partly allowed as aforesaid in respect of impugned orders dt

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

section 40A(3) of Income Tax Act 1961 .Therefore, this amount of Rs 1,23,299/- is added back to the income of the assessee being unexplained cash credit since the same are not reflected in assessee's regular books of accounts on those relevant dates.. Since the above transaction also violated the provisions of section

M/S ASHA TECHNOLOGIES,KALA AMB vs. ITO, SIRMOUR

In the result, both the above appeals of the Assessee are partly allowed as aforesaid in respect of impugned orders dt

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

section 40A(3) of Income Tax Act 1961 .Therefore, this amount of Rs 1,23,299/- is added back to the income of the assessee being unexplained cash credit since the same are not reflected in assessee's regular books of accounts on those relevant dates.. Since the above transaction also violated the provisions of section

DY. COMMISSIONER OF INCOME TAX, PATIALA vs. DSG PAPERS PVT. LTD., PATIALA

In the result, respective appeals are disposed off in light of aforesaid\ndirection

Section 65B of the Indian Evidence Act, 1872.\"\n25. It was argued before us that this ground being legal ground and the same was also before the Ld. CIT(A) was filed, for which, the detailed submissions was filed at para 14 page 47, of his order and then further, submissions were also made, at page

DY. COMMISSIONER OF INCOME TAX, PATIALA vs. DSG PAPERS PVT. LTD., PATIALA

In the result, respective appeals are disposed off in light of aforesaid direction

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

Section 65B of the Indian Evidence Act, 1872.” 25. It was argued before us that this ground being legal ground and the same was also before the Ld. CIT(A) was filed, for which, the detailed submissions was filed at para 14 page 47, of his order and then further, submissions were also made, at page

DY. COMMISSIONER OF INCOME TAX, PATIALA vs. DSG PAPERS PVT. LTD., PATIALA

In the result, respective appeals are disposed off in light of aforesaid\ndirection

Section 65B of the\nIndian Evidence Act, 1872.\"\n\n25. It was argued before us that this ground being legal ground and the\nsame was also before the Ld. CIT(A) was filed, for which, the detailed\nsubmissions was filed at para 14 page 47, of his order and then further,\nsubmissions were also made, at page

DY. COMMISSIONER OF INCOME TAX, PATIALA vs. DSG PAPERS PVT. LTD., PATIALA

In the result, respective appeals are disposed off in light of aforesaid\ndirection

Section 65B of the\nIndian Evidence Act, 1872.\n25. It was argued before us that this ground being legal ground and the\nsame was also before the Ld. CIT(A) was filed, for which, the detailed\nsubmissions was filed at para 14 page 47, of his order and then further,\nsubmissions were also made, at page

DEPUTY COMMISSIONER OF INCOME TAX, PATIALA vs. DSG PAPERS PVT. LTD., PATIALA

In the result, respective appeals are disposed off in light of aforesaid direction

Section 65B of the Indian Evidence Act, 1872.\"\n\n25. It was argued before us that this ground being legal ground and the same was also before the Ld. CIT(A) was filed, for which, the detailed submissions was filed at para 14 page 47, of his order and then further, submissions were also made, at page

DY. COMMISSIONER OF INCOME TAX, PATIALA vs. DSG PAPERS PVT. LTD., PATIALA

In the result, respective appeals are disposed off in light of aforesaid\ndirection

Section 65B of the\nIndian Evidence Act, 1872.\"\n25. It was argued before us that this ground being legal ground and the\nsame was also before the Ld. CIT(A) was filed, for which, the detailed\nsubmissions was filed at para 14 page 47, of his order and then further,\nsubmissions were also made, at page

DSG PAPERS PVT LTD #6, GREEN VIEW COLONY,PATIALA vs. THE DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE PATIALA, PATIALA

In the result, respective appeals are disposed off in light of aforesaid\ndirection

Section 65B of the Indian Evidence Act, 1872.\"\n25. It was argued before us that this ground being legal ground and the same was also before the Ld. CIT(A) was filed, for which, the detailed submissions was filed at para 14 page 47, of his order and then further, submissions were also made, at page

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, PATIALA, PATIALA vs. DSG PAPERS PVT. LTD., PATIALA

In the result, respective appeals are disposed off in light of aforesaid\ndirection

Section 65B of the\nIndian Evidence Act, 1872.\"\n25. It was argued before us that this ground being legal ground and the\nsame was also before the Ld. CIT(A) was filed, for which, the detailed\nsubmissions was filed at para 14 page 47, of his order and then further,\nsubmissions were also made, at page