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)

undisclosed sources and which was brought to tax by invoking the provisions of Section 68 of the Act. The AO further did not allow the set off of the income so assessed against the brought forward losses/ unabsorbed depreciation

ANISH GARG,PATIALA vs. ITO WARD-4, PATIALA

In the result, the appeal of the assessee is allowed

undisclosed income into exempt income. How the AO has reached\nsuch a conclusive finding and basis thereof is again not borne out from the\nreasons so recorded by him. (Para 15)\n5.6 Further, reliance was drawn to the decision of the Hon'ble Bombay High\nCourt in case of M/s Hemant Traders vs. ITO (in Writ Petition

M/S SINGH CONSTRUCTION CO.,PATIALA vs. ACIT, CIRCLE, PATIAL

In the result, the appeal of the assessee is dismissed

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

undisclosed income. Penalty proceedings u/s 271(1)(c) of the Income Tax Act, 1961 are initiated for concealment or furnishing inaccurate particulars of income.” 10. Against the said findings and the order of the AO, the assessee moved in appeal before the Ld. CIT(A) wherein the Ld. CIT(A) directed the AO to apply net profit of 5.74% which

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

undisclosed income u/s 68 of the Income Tax Act, 1961 without even issuing any show cause notice to the appellant company for treating it as a shell company. Also, the Learned Assessing Officer neither issued a show cause notice nor mentioned a single word about shell company in any of the questionnaires sent by ITA 4/CHD/2023

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)

undisclosed income u/s 68 of the Income Tax Act, 1961, without even issuing any Show Cause Notice to the assessee company for treating it as a shell company. Also, the ld. Assessing Officer neither issued a Show Cause Notice nor mentioned a single word about shell company in any of the questionnaires sent by him on 14.08.2019 (page

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)

undisclosed income u/s 68 of the Income Tax Act, 1961, without even issuing any Show Cause Notice to the assessee company for treating it as a shell company. Also, the ld. Assessing Officer neither issued a Show Cause Notice nor mentioned a single word about shell company in any of the questionnaires sent by him on 14.08.2019 (page

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)

undisclosed sources, therefore, the substantive addition in the hands of the assessee company was not justified. The issue is squarely covered by the various decisions including the decision of the Hon’ble Apex Court in the case of “CIT vs Bharat Engineering & Construction Co.” (supra) as referred to above by the ld. Counsel for the assessee in the written submissions

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)

undisclosed sources, therefore, the substantive addition in the hands of the assessee company was not justified. The issue is squarely covered by the various decisions including the decision of the Hon’ble Apex Court in the case of “CIT vs Bharat Engineering & Construction Co.” (supra) as referred to above by the ld. Counsel for the assessee in the written submissions

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)

undisclosed sources, therefore, the substantive addition in the hands of the assessee company was not justified. The issue is squarely covered by the various decisions including the decision of the Hon’ble Apex Court in the case of “CIT vs Bharat Engineering & Construction Co.” (supra) as referred to above by the ld. Counsel for the assessee in the written submissions

DEPUTY COMMISSIONER OF INCOME TAX, CHANDIGARH vs. WINSOME TEXTILE INDUSTRIES LTD, CHANDIGARH

undisclosed sources and which was brought to\ntax by invoking the provisions of Section 68 of the Act. The AO further did not\nallow the set off of the income so assessed against the brought forward losses/\nunabsorbed depreciation

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

undisclosed income u/s 68 of the Income Tax Act, 1961 without even issuing any show cause notice to the appellant company for treating it as a shell company. Also, the Learned Assessing Officer neither issued a show cause notice nor mentioned a single word about shell company in any of the questionnaires sent by him on 19.08.2019 (page

SHRI BALBIR SINGH VERMA,SHIMLA vs. PR.CIT, SHIMLA

In the result, appeal of the Assessee is allowed

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

depreciation, maintenance costs, and insurance for vehicles, one of which was a Toyota Fortuner. The AO suspected that the vehicles might have been used partly for personal purposes and not entirely for business. As a result, and in line with decisions made in previous years, the AO disallowed an amount of Rs.60,000 on an ad-hoc basis from

SANJEEV KUMAR GOYAL,FATEHABAD vs. DCIT, CC-2, LUDHIANA

In the result, the appeal of the assesse is allowed

Bench: This Hon’Ble Tribunal Under Section 253 Of The Income Tax Act, 1961 As Amended From Time To Time. 2. The Assessee Is Aggrieved By The Order Of The Ld. Cit(A) Dt. 20/01/2023 In Appeal No. 10853/2018-19/It/Cit(A)-5/Ldh/2021-22 For The A.Y. 2019-20 Under Section 250(6) Of The Income Tax Act, 1961 Which Was Dismissed. Therefore The Present Second Appeal Under Section 253 Of The Income Tax Act, 1961 Before Us Against The Aforesaid Order Dt. 20/01/2023 Which Is Hereinafter Referred To As The Impugned Order.

depreciation during the year under consideration. During the assessment proceedings the assessee has not produced any bills/vouchers/ proof of payment/ copy of accounts of the building as Capital Work in Progress to substantiate the claim of source of investment made for the construction of building. The onus to prove the sources of the surrender income lies entirely on the assessee

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

undisclosed\ninvestments or income. A plea was also raised for telescoping the surrendered stock\nagainst other alleged unaccounted sales and receipts. Reliance was placed on certain\njudicial precedents where surrendered stock had been treated as business income.\n5.2\nAfter considering these submissions, the Ld. CIT(A) had accepted the assessee's\ncontention and held that the surrendered amount of Rs.2

INCOME TAX OFFICER, MOHALI PUNJAB vs. TAJ LAND DEVELOPEFRS AND PROMOTERS PRIVATE LIMITED , SECTOR MOHALI PUNJAB

In the result, appeal is dismissed

undisclosed income.\"\n\nHarjeet Singh Vs ITO (ITAT Delhi), order dated 12.11.2018, in ITA No.\n2013/DEU2015\n\"In my considered opinion, the basis of reopening itself is based on wrong\nfacts therefore, the same cannot be upheld. I accordingly set aside the notice\nu/s 148 of the Act the reassessment based on such notice deserves to be\nquashed. Since

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)

undisclosed income u/s 68 of the Income Tax Act. We find that such additions, as rightly contended on behalf of the assessee, are not at all sustainable in the eye of the law. Such addition was made without putting the assessee to show cause thereagainst. Also, the assessee was wrongly treated as a shell company, without any query in this

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)

undisclosed income u/s 68 of the Income Tax Act. We find that such additions, as rightly contended on behalf of the assessee, are not at all sustainable in the eye of the law. Such addition was made without putting the assessee to show cause thereagainst. Also, the assessee was wrongly treated as a shell company, without any query in this

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

undisclosed debtors. Since the facts are identical to that in the case of Famina Knit Fobs (supra), and no distinguishing facts have been brought to our notice by the Ld. DR, the decision rendered in that case will also apply to the present case, following which we hold that the Ld. CIT{A) had rightly treated the surrendered income

SH. JASPREET SINGH MAUJ,LUDHIANA vs. DCIT/ACIT, CC-1, LUDHIANA

In the result, the appeal is allowed

Bench: Shri Aakash Deep Jainand Shri Vikram Singh Yadav

undisclosed professional income; that the assessee had also paid due tax thereon, @ 30% plus surcharge etc.; and there was nothing on record that the assessee had received any unexplained income; that the surrender had been made just on estimation basis that the assessee might have received some professional receipts, it might not have been accounted for; that even the CBDT