PREM SINGH,CHAMBA vs. ACIT CIRCLE PALAMPUR, PALAMPUR

In the result, the appeal for AY 2017-18 stands partly allowed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No. 946/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2015-16) & 2. आयकर अपील सं. / Ita No. 947/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2017-18) Shri Prem Singh Dcit Circle, Palampur बनाम/ The Palace. Chamba Himachal Pradesh - 176061 Vs. Himachal Pradesh – 176310 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aampr-8876-P (अपीलाथ"/Appellant) : (""थ" / Respondent) Assessee By : Shri Ajay Jain (Ca) – Ld. Ar Revenue By : Shri Bharat Bhushan Garg (Cit) (Virtual) - Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 13-11-2025 घोषणाकीतारीख /Date Of Pronouncement : 13-01-2026 आदेश / O R D E R Manoj Kumar Aggarwal () 1. The Assessee Is In Further Appeals Before Us For Assessment Years (Ay) 2015-16 & 2017-18 Which Arises Out Of Separate Orders Of Learned First Appellate Authority. First, We Take Up Appeal For Assessment Year (Ay) 2015-16 Which Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), Nfac [Cit(A)] Dated 22-07-2025 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S 143(3) Of The Act On 29-12-2017. The Assessee Is Aggrieved By Computation Of Capital

Disallowing claim of Rs.5,37,533 spent on account of property tax and claimed as deduction while calculating the capital gain on account of expenditure incurred wholly and exclusively in connection with transfer of the house

JANTA LAND PROMOTERS PRIVATE LIMITED ,MOHALI vs. INCOME TAX OFFICER WARD 6(1) CHANDIGARH , MOHALI

In the result, appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 907/Chd/2024 "नधा"रण वष" / Assessment Year : 2017-18 बनाम M/S Janta Land Promoters Pvt.Ltd. The Ito, Sco 39-42, Sector 82, Ward 6(1), Vs Mohali. Chandigarh. "थायी लेखा सं./Pan /Tan No: Aabcj3450D अपीलाथ"/Appellant ""यथ"/Respondent "नधा"रती क" ओर से/Assessee By : Shri Pankaj Bhalla, Ca राज"व क" ओर से/ Revenue By : Shri Vivek Vardhan, Addl. Cit, Sr.Dr तार"ख/Date Of Hearing : 07.05.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 30.07.2025

disallowance will not be made. Accordingly, this ground of appeal is partly allowed. 5.1 As far as assessment of notional rent qua inventory of flats unsold, the assessee has filed written submissions. ITA 907/CHD/2024 A.Y. 2017-18 4 6. The assessee company is engaged in the business of Real Estate as a Colonizer and Developer of Sectors in the State

DCIT, CIRCLE, PATIALA vs. M/S PUNJAB STATE POWER CORPORATION LTD., PATIALA

In the result, ground no. 1 & 3 of the Revenue’s appeal is allowed and ground no

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

disallowed the deduction by holding that the payment of income-tax could not be for the purpose of business. It was claimed before the Tribunal that if the tax liability had not been discharged, then the entire business would have crippled and therefore, interest on such overdraft account be allowed as an expenditure for business purposes. The Tribunal refused

SH. RAJINDER SINGH BEDI,CHANDIGARH vs. DCIT (INTL. TAXATION), CHANDIGARH

In the result, appeal of the assessee is allowed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 538/Chd/2022 "नधा"रण वष" / Assessment Year: 2018-19 Shri Rajinder Singh Bedi, The Dcit, (Int.Taxation ), 1368, Sector 40-B, Vs Chandigarh. Chandigarh. "थायी लेखा सं./Pan No: Afwpb3355A अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Sudhir Sehgal, Advocate Revenue By : Smt. Kusum Bansal, Cit, Dr Date Of Hearing : 09.04.2025 Date Of Pronouncement : 04.06.2025 Hybrid Hearing O R D E R

house bearing No. 845 Sector 38-A, Chandigarh was originally allotted to Smt. Joginder Kaur on 03.04.1987. The assessee got 100% share of this property from his mother on 24.06.2010. He has sold the property for a total consideration of Rs.3,88,00,000/- during the accounting year relevant to assessment year 2018-19. Thus, the dispute relates to correct

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), CHANDIGARH, CHANDIGARH vs. DEEP KAUR PANNU THROUGH L/H RANJI SINGH PANNU & GURBILAS PLATO SINGH PANNU, CHANDIGARH

In the result, appeal of the Revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 987/Chd/2024 "नधा"रण वष" / Assessment Year : 2016-17 Dcit, Deep Kaur Pannu, Circle 1(1), बनाम # 1070, Chandigarh Sector 15-B, Vs. Chandigarh "थायी लेखा सं./Pan No: Abmpk1575B अपीलाथ"/Appellant ""यथ"/Respondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : Sh. Manoj Goyal, Ca राज"व क" ओर से/ Revenue By : Shri Manav Bansal, Cit Dr सुनवाई क" तार"ख/Date Of Hearing : 22.05.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 07.08.2025 आदेश/Order Per Krinwant Sahay, Am: Appeal In This Case Has Been Filed By The Revenue Against The Order Dated 24.7.2024 Of Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi.

disallowing deduction under section 54F by ignoring the fact that fractional ownership right in one residential property cannot be equated to ownership of one residential house

ASSISSTANT COMMISSONER OF INCOME TAX, CIRCLE-1, EXEMPTION, CHANDIGARH, CHANDIGARH vs. HERITAGE EDUCATIONAL SOCIETY, C/O DELHI PUBLIC SCHOOL

In the result, all the appeals filed by the Department

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

house properties, have invested in mutual funds and have sold properties. All these activities demand time and commitment and when this fact is seem alongwith the fact that the members are not available in school for most of the time, it can safely be concluded that the members have not been giving the time and commitment to the society

ASSISSTANT COMMISSIONER OF INCOME TAX, CIRCLE-1,EXEMPTION,CHANDIGARH, CHANDIGARH vs. HERITAGE EDUCATIONAL SOCIETY, C/O DELHI PUBLIC SCHOOL

In the result, all the appeals filed by the Department

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

house properties, have invested in mutual funds and have sold properties. All these activities demand time and commitment and when this fact is seem alongwith the fact that the members are not available in school for most of the time, it can safely be concluded that the members have not been giving the time and commitment to the society

ASSISSTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, CHANDIGARH, CHANDIGARH vs. HERITAGE EDUCATION SOCIETY , C/O DELHI PUBLIC SCHOOL

In the result, all the appeals filed by the Department

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

house properties, have invested in mutual funds and have sold properties. All these activities demand time and commitment and when this fact is seem alongwith the fact that the members are not available in school for most of the time, it can safely be concluded that the members have not been giving the time and commitment to the society

ASSISSTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, EXEMPTION, CHANDIGARH, CHANDIGARH vs. HERITAGE EDUCATIONAL SOCIETY, C/O DELHI PUBLIC SCHOOL

In the result, all the appeals filed by the Department

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

house properties, have invested in mutual funds and have sold properties. All these activities demand time and commitment and when this fact is seem alongwith the fact that the members are not available in school for most of the time, it can safely be concluded that the members have not been giving the time and commitment to the society

BABITA JAIN,AMBALA CITY vs. INCOME TAX OFFICER ,WARD -1 AMBALA, AMBALA CANTT

In the result, appeal of the assessee is allowed as and by way of remand back to the file of Ld

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

disallowed in absence of documentary proof despite of the fact that learned AO has never asked for justification and proof of same. 6. That learned AO has rejected the submissions of assessee and therefore made an addition of Rs. 49,22,248/- as business income and Rs. 52,248/- on account of loss from house property

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), CHANDIGARH vs. POONAM KHETRAPAL SINGH, CHANDIGARH

In the result, appeal is dismissed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 1000/Chd/2024 "नधा"रण वष" / Assessment Year : 2021-22 Dcit, Poonam Khetrapal Singh, बनाम Circle 1(1), H. No 816, Sector 16, Chandigarh Chandigarh. Vs. "थायी लेखा सं./Pan No: Anqps6367R अपीलाथ"/Appellant ""यथ"/Respondent ( Hybrid Hearing ) "नधा"रती क" ओर से/Assessee By : Sh. Ashish Kumar Singh, Advocate राज"व क" ओर से/ Revenue By : Smt Kusum Bansal, Cit Dr (Virtual Mode) सुनवाई क" तार"ख/Date Of Hearing : 15-05-2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 06-08-2025 आदेश/Order Per Krinwant Sahay, Am: Appeal In This Case Has Been Filed By The Revenue Against The Order Dated 29.7.2024 Of Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi.

disallowing the same and charging capital gain on the same amount. 6. The Ld. CIT(A) has very clearly given his findings that in case the Assessee does not purchase a new property or get constructed a new house

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)

house property and salary as a sitting MLA from HP Vidhan Sabha. Key issues examined included deductions claimed under Section 24(b) for interest on borrowed capital, motor car expenses, loans and advances, unsecured loans, and additional income of Rs. 1,25,00,000/- declared post a survey under Section 133A conducted on 04.03.2015. 3.2 Regarding Interest Claimed under Section

SH. AMAN SETH,LUDHIANA vs. ITO, W-1(1), LUDHIANA

In the result, appeal filed by the assessee is allowed for statistical purposes

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

Properties Ltd, M/s Punjab Apparel Park, advance for purchase of Plot, Insu. by Allahabad Bank, flat booking with Jaypee and residential house on advance given may not be disallowed

THE PUNJAB STATE FEDERATION OF COOPERATIVE HOUSE BUILDING SOCIETIES LTD.,CHANDIGARH vs. ACIT, CHANDIGARH

In the result, both the above appeals of the Assessee are dismissed

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

disallowances made may be allowed in the facts and circumstances of the case. 4. The assessee, Punjab State Co-operative House Building Federation Ltd., filed its return of income for AY 2012-13 declaring taxable income of Rs.26,43,040/- after claiming deduction under Chapter VI-A, mainly section 80P, amounting to Rs.8,66,76,909. The assessee

THE PUNJAB STATE FEDERATION OF COOPERATIVE HOUSE BUILDING SOCIETIES LTD.,CHANDIGARH vs. DCIT, CHANDIGARH

In the result, both the above appeals of the Assessee are dismissed

Bench: the appeal is finally heard.

disallowances made may be allowed in the facts and circumstances of the case. 4. The assessee, Punjab State Co-operative House Building Federation Ltd., filed its return of income for AY 2012-13 declaring taxable income of Rs.26,43,040/- after claiming deduction under Chapter VI-A, mainly section 80P, amounting to Rs.8,66,76,909. The assessee

SHRI PRINCEPREETJIT SINGH,RANJIT NAGAR vs. PR.CIT-1, CHANDIGARH

In the result, appeal of the assessee is allowed

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

house and claimed the deduction u/s 54F for the purchase/construction of property on 11 a proportionate basis. Thereafter, ‘A’ carried out the construction on the property purchased and the map was also approved for the construction. The investment in construction was modest, and ‘A’ submitted sufficient documentary evidence including construction bills and approved building map. Copy of construction bills

SANJEEV KUMAR KATHURIA,YAMUNA NAGAR vs. INCOME TAX OFFICER WARD 1 , YAMUNANAGAR

In the result, the appeal of the assessee is allowed

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

house. 2. The PCIT has wrongly enhanced the scope of scrutiny assessment while faming order under section 263 of Income Tax Act. 3. Briefly the facts of the case are that the assessee filed his return of income declaring total income of Rs. 69,52,590/-. Subsequently, return of income was selected for complete scrutiny and notice under section

DESH MITTER GAIND,PANCHKULA vs. INCOME TAX OFFICER, WARD-1, PANCHKULA, PANCHKULA, HARYANA

Bench: This Tribunal. The Assessee Is Aggrieved By The Order Of Cit(A) Bearing No. Itba/Nfac/S/250/2023-

disallowances made are discussed as under:- ITA 454/CHD/2023 A.Y. 2011-12 4 From the perusal of sale deed, it was noticed that (i) the assessee had sold a residential property bearing No. 595, Sector 6, Panchkula for a consideration of Rs.2,42.00,000/- whereas the value of stamp duty was assessed by the valuation authority on the value of Rs.3