DCIT, C-V, LUDHIANA vs. M/S HERO CYCLES LTD., LUDHIANA

In the result, appeal of the Department is dismissed and the appeal of the assessee is allowed

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 588/Chd/2018 निर्धारण वर्ष / Assessment Years : 2012-13 The DCIT C-V, Ludhiana बनाम M/s Hero Cycles Ltd. Hero Nagar, G.T. Road Ludhiana स्थायी लेखा सं./PAN NO: AAACH4073P अपीलार्थी/Appellant प्रत्यर्थी / Respondent आयकर अपील सं. / ITA No. 473/Chd/2018 निर्धारण वर्ष / Assessment Years : 2012-13 M/s Hero Cycles Ltd. Hero Nagar, G.T. Road Ludhiana बनाम The ACIT C-V, Ludhiana स्थायी लेखा सं./PAN NO: AAACH4073P

116 10189726.03 Total 25,11,55,479.45 7.8.2 Disallowance of interest on advance to Hero Exports Date Amount No. of Days Disalowance @ 11.25% 01/04/2011 546100000.00 365 6,14,36,250 Thus, total disallowance works out to Rs. 31,25,91,729/-. Less: Disallowance already made by the assessee: Rs. 22,86,36,462/ Disallowance to be made

DCIT, C-5, LUDHIANA vs. M/S HERO CYCLES LTD., LUDHIANA

In the result, appeal of the Department is dismissed and the Cross

section 36 (i)(iii) of the Act as the assessee company has shown huge assets under the head capital work in progress is directed to be deleted on the basis of same reasoning and logic as adopted by the Honourable ITAT, Chandigarh in the case of the assessee company itself for the A.Ys. 2009-10 and 2010-11 while deleting

M/S HIMACHAL FASHION PVT. LTD.,LUDHIANA vs. ITO, W-6(3), LUDHIANA

In the result, the appeal of the Assessee is allowed

Bench: Shri Krinwant Sahay & Shri Paresh M. Joshiआयकर अपील सं./ Ita No. 8/Chd/2020 िनधा"रण वष" / Assessment Year: 2012-13

section 139(1) of the Income-tax Act, 1961. 3. An opportunity was given to assessee company vide this office letter dated 16.03.2015 to show cause why the deduction u/s. 80-IC of Rs.75,17,116/- should not be disallowed

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

disallowed by the AO have in fact been found to be actively engaged in rendering their respective services as is proved from the fact that during the course of survey on the assessee and the post survey enquiries, ail these parties have given their statements vis- a- vi s the salary being drawn by them from the Society

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

disallowed by the AO have in fact been found to be actively engaged in rendering their respective services as is proved from the fact that during the course of survey on the assessee and the post survey enquiries, ail these parties have given their statements vis- a- vi s the salary being drawn by them from the Society

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

disallowed by the AO have in fact been found to be actively engaged in rendering their respective services as is proved from the fact that during the course of survey on the assessee and the post survey enquiries, ail these parties have given their statements vis- a- vi s the salary being drawn by them from the Society

DCIT,CIRCLE-1(EXEMPTION), CHANDIGARH vs. M/S MANAV MANGAL SCHOOL( MANAV MANGAL SOCIETY), CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

disallowed by the AO have in fact been found to be actively engaged in rendering their respective services as is proved from the fact that during the course of survey on the assessee and the post survey enquiries, ail these parties have given their statements vis- a- vi s the salary being drawn by them from the Society

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

disallowed by the AO have in fact been found to be actively engaged in rendering their respective services as is proved from the fact that during the course of survey on the assessee and the post survey enquiries, ail these parties have given their statements vis- a- vi s the salary being drawn by them from the Society

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

disallowed by the AO have in fact been found to be actively engaged in rendering their respective services as is proved from the fact that during the course of survey on the assessee and the post survey enquiries, ail these parties have given their statements vis- a- vi s the salary being drawn by them from the Society

M/S MANAV MANGAL SOCIETY,CHANDIGARH vs. DCIT, C-1, (E), CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

disallowed by the AO have in fact been found to be actively engaged in rendering their respective services as is proved from the fact that during the course of survey on the assessee and the post survey enquiries, ail these parties have given their statements vis- a- vi s the salary being drawn by them from the Society

M/S MANAV MANGAL SOCIETY,CHANDIGARH vs. DCIT, C-1, (E), CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

disallowed by the AO have in fact been found to be actively engaged in rendering their respective services as is proved from the fact that during the course of survey on the assessee and the post survey enquiries, ail these parties have given their statements vis- a- vi s the salary being drawn by them from the Society

DCIT, C-4(1), CHANDIGARH vs. M/S PUNJAB AGRO INDUSTRIES CORP. LTD., CHANDIGARH

In the result, appeal of the Revenue is hereby dismissed

Bench: Smt. Diva Singh & Dr. B.R.R. Kumarassessment Year: 2013-14

section 14A (in Rs.) 2013-14 220000 10700000 5. The Ld. CIT(A) confirmed the addition on the grounds that the assessee has failed to establish that the investments have been made out of surplus funds in the earlier years. 6. Before us, the Ld. AR has submitted that the funds invested are to the tune of Rs. 48.53 Crores

SHRI GURU RAM DASS EDUCATIONAL SOCIETY,MOHALI vs. PR.CIT(CENTRAL) GURGAON, AT CHANDIGARH

disallowed and added to income and the total income so calculated is taxed at maximum marginal rate as per section 164(2) of the Act. 5.17 As regards to the submissions of the assessee that the issue of cancellation of registration under section 12AA of the Act shall be dealt upon by the CIT(E) only

CHANDIGARH EDUCATIONAL SOCIETY,MOHALI vs. PR.CIT(CENTRAL)-GURGAON, AT CHANDIGARH

disallowed and added to income and the total income so calculated is taxed at maximum marginal rate as per section 164(2) of the Act. 5.17 As regards to the submissions of the assessee that the issue of cancellation of registration under section 12AA of the Act shall be dealt upon by the CIT(E) only

CHANDIGARH EDUCATIONAL TRUST,MOHALI vs. PR.CIT-CENTRAL,GURGAON, AT CHANDIGARH

disallowed and added to income and the total income so calculated is taxed at maximum marginal rate as per section 164(2) of the Act. 5.17 As regards to the submissions of the assessee that the issue of cancellation of registration under section 12AA of the Act shall be dealt upon by the CIT(E) only

A.K.MULTIMETALS PRIVATE LIMITED,MANDI GOBINDGARH vs. ACIT,CIRCLE, MANDI GOBIND GARH

In the result, appeal of the Assessee is allowed

section 40A(2)(b) of the Act. Now, the assessee is in appeal. 7. The Ld. Counsel for the assessee reiterated the submissions made before the authorities below and further submitted that all the loans taken by the assessee were old loans on which interest was paid at the rate of 12% in the earlier years also, which had been

ACIT, CC-2, CHANDIGARH vs. SHRI KARAJ SINGH, YAMUNA NAGAR

In the result, the revenue’s appeal ITA No

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No. 726/Chandi/2022 (िनधा"रण वष" / Assessment Year: 2018-19) Acit-Central Circle 2 Shri Karaj Singh बनाम/ Cr Building Sector 17 H. No 1379, Modern Colony, Near Iti Vs. Chandigarh 160017 Yamuna Nagar (Haryana) "ायीलेखासं./जीआइआरसं./Pan/Gir No. Atups-5528-A (अपीलाथ"/Appellant) (""थ" / Respondent) : & 2. Co. No. 16/Chandi/2024 [In Ita No. 726/Chandi/2022 (िनधा"रण वष" / Assessment Year: 2018-19) Shri Karaj Singh Acit-Central Circle 2 बनाम/ H. No 1379, Modern Colony, Near Iti, Cr Building Sector 17 Vs. Yamuna Nagar (Haryana) Chandigarh 160017 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Atups-5528-A (Cross-Objector) : (Respondent) Revenue By : Smt. Kusum Bansal (Cit) – Ld. Dr Assessee By : Shri Dhruv Goel (Ca) - Ld. Ar सुनवाईकीतारीख/Date Of Hearing : 18-09-2025 घोषणाकीतारीख /Date Of Pronouncement : 08/10/2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1.1 Aforesaid Appeal By Revenue For Assessment Year (Ay) 2018-19 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals)- 3, Gurgaon [Cit(A)] Dated 26-09-2022 In The Matter Of An Assessment

Section 143(3) of the Act deserve to be quashed as such. 6. That the authorities below have erred in making/confirming additions without providing adequate opportunity of being heard to the assessee and without adhering to the principles of natural justice. 7. The assessee craves leave to add, amend, alter, substitute or revise any of the above-mentioned grounds before

ACIT, C-5(1), CHANDIGARH vs. M/S INDRASON PRECISION ENGINEERING (P) LTD., CHANDIGARH

Bench: Shri Sanjay Garg & Ms. Annapurna Gupta

116’ and further of the Hon'ble Allahabad High Court in the case of ‘CIT Vs. M/s Shivam Motors (P) Ltd’ (2014) 272 CTR (All) 277 and various other case laws. In all the above referred to case laws, the Hon'ble High Courts have been unanimous to hold that no disallowance is attracted

ACIT, C-5(1), CHANDIGARH vs. M/S INDRASON PRECISION ENGINEERING (P) LTD., CHANDIGARH

Bench: Shri Sanjay Garg & Ms. Annapurna Gupta

116’ and further of the Hon'ble Allahabad High Court in the case of ‘CIT Vs. M/s Shivam Motors (P) Ltd’ (2014) 272 CTR (All) 277 and various other case laws. In all the above referred to case laws, the Hon'ble High Courts have been unanimous to hold that no disallowance is attracted