M/S HARYANA STATE INDUSTRIAL & INFRASTRUCTURE DEVELOPMENT CORPN.,,PANCHKULA vs. ACIT,, PANCHKULA

In the result, all the above appeals of the assessee are

Bench: The Itat. That In The First Round The Itat Had Held The Provisions Of Section 14A Of The Act, For The Purposes Of Disallowing Expenses Relating To Exempt Income, Applicable In The Facts Of The Present Cases On Noting That The Assessee Had Earned Exempt Income In The Form

section 14A was required to collect such material evidence to determine expenditure if any incurred by the assessee in relation to earning of exempt income. The Assessing Officer disallowed the entire tax exempt income which is not permissible as per settled position of law. In view of decision in CI1 vs. Deepak Mittal [2013138 taxmann.com 83/219 Taxman 314/120141361ITR 131

M/S METALMAN AUTO PVT. LTD.,LUDHIANA vs. ADDL. CIT, LUDHIANA

In the result, the appeal of the assessee is allowed

Bench: Shri Sanjay Garg & Ms. Annapurna Guptam/S Metalman Auto Pvt. Ltd., Vs. The Addl.C.I.T., E-127, Phase-V, Range-1, Focal Point, Ludhiana. Ludhiana. Pan: Aabcm5441M (Appellant) (Respondent)

131/- made by the Assessing Officer under this head.” 6. Before us, the Ld. counsel for assessee reiterated his contentions made before the CIT(Appeals) that in view of the sufficiency of funds available with him for making impugned investment no disallowance of interest was warranted as per the provisions of section

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

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

disallowance of expenses by invoking provisions of section 14A of the Act on the ground that the assessee company had made investment in shares/mutual funds, the income from which in the form of dividend or long term capital gains is exempt from tax under section 10(38) of the Act is directed to be deleted on the basis of same

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

131 to the effect that in the absence of any satisfaction recorded by the Assessing Officer as to why the calculation made by the assessee is not correct, the disallowance made by him on account of administrative expenses under Rule 8D of the Income Tax Rules is not as per law. In view of the above disallowance made

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)

disallowance of depreciation on vehicle to the extent of Rs. 9,11,4884/- without any justification. 15. That the appellant craves leave to add, alter, amend or withdraw any grounds of appeal before the final hearing. 2.1 The following additional Grounds have also been taken by the Assessee: 1. That the approval u/s 153D was granted by the JCIT without

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)

disallowance of depreciation on vehicle to the extent of Rs. 9,11,4884/- without any justification. 15. That the appellant craves leave to add, alter, amend or withdraw any grounds of appeal before the final hearing. 2.1 The following additional Grounds have also been taken by the Assessee: 1. That the approval u/s 153D was granted by the JCIT without

KANDI FRIENDS EDUCATIONAL TRUST,ROPAR vs. DEPUTY COMMISSIONER OF INCOME TAX, CHANDIGARH

In the result, both the appeals are allowed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahay

disallowed and excess of income 2,82,41,720 over expenditure Total Taxable Income 10,47,74,451 5. The assessee has taken eight grounds of appeal in assessment year 2014-15 and ten grounds of appeal in assessment year 2015-16. In brief, its grievance revolves around the additions noticed by us in the above table and rest

KANDI FRIENDS EDUCATIONAL TRUST,ROPAR vs. DEPUTY COMMISSION OF INCOME TAX, CL. 1, EXEMPTION, CHANDIGARH

In the result, both the appeals are allowed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahay

disallowed and excess of income 2,82,41,720 over expenditure Total Taxable Income 10,47,74,451 5. The assessee has taken eight grounds of appeal in assessment year 2014-15 and ten grounds of appeal in assessment year 2015-16. In brief, its grievance revolves around the additions noticed by us in the above table and rest

DCIT, C-1(1), CHANDIGARH vs. UNIPRO TECHNO INFRASTRUCTURE PRIVATE LIMITED, CHANDIGARH

In the result, appeal of the Department is dismissed

disallowed as it seems that you are furnishing inaccurate particulars. Please also furnish whether you have claimed such exemption u/s 80-lA in the previous year also or not? 12. Further at para 12 of Form No.10CCB, you have shown sales tax registration No. in which it has ascertained that you were got registered with sales tax on 09.07.2009. Please

M/S DIN DAYAL PURSOTAM LAL,SIRSA vs. PR.CIT, ROHTAK

Bench: SHRI A.D.JAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)

disallowance were made as per provision of section 40A(3) of the Act" are factually incorrect, legally misconceived, contrary to evidence on record; and in any case is vague, based on surmiseful considerations; and therefore unsustainable. 2.2 That the learned Principal Commissioner of Income Tax has erred in holding that it is a case of "lack of enquiry" and, further

M/S DIN DAYAL PURSOTAM LAL,SIRSA vs. PR.CIT, ROHTAK

Bench: SHRI A.D.JAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)

disallowance were made as per provision of section 40A(3) of the Act" are factually incorrect, legally misconceived, contrary to evidence on record; and in any case is vague, based on surmiseful considerations; and therefore unsustainable. 2.2 That the learned Principal Commissioner of Income Tax has erred in holding that it is a case of "lack of enquiry" and, further

M/S DIN DAYAL PURSOTAM LAL,SIRSA vs. PR.CIT, ROHTAK

Bench: SHRI A.D.JAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)

disallowance were made as per provision of section 40A(3) of the Act" are factually incorrect, legally misconceived, contrary to evidence on record; and in any case is vague, based on surmiseful considerations; and therefore unsustainable. 2.2 That the learned Principal Commissioner of Income Tax has erred in holding that it is a case of "lack of enquiry" and, further

M/S BRONZE LOGISTICS PVT. LTD.,LUDHIANA vs. DCIT, LUDHIANA

The appeal of the assessee is allowed

Bench: Ms. Diva Singh & Ms. Annapurna Guptaassessment Year: 2006-07 M/S Bronze Logistics P.Ltd., Vs. The Dcit, 863 Industrial Area-A, Circle Vii, Ludhiana. Ludhiana. Pan No. : Aabcb9505H

131 to 228. Thus it was submitted that infact there are two Audit Report available on record. One filed under section 44AB accompanied by Audit Report in the prescribed form in 3CA and the Report of the Special Auditor sought by the AO. It was argued that through the Report of the Special Auditor is without jurisdiction and thus invalid

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

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

disallowances, without any supporting\nmaterial, cannot be sustained in law. Accordingly, the additions\nsustained by the Ld. CIT(A) are directed to be deleted.\n20. The Ld. CIT(A) has confirmed an addition of Rs.34,110/- in\nrespect of jewellery for the assessment year 2020-21 by relying\nupon a jewellery bill dated 28th October 2020. Similarly

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

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

disallowances, without any supporting\nmaterial, cannot be sustained in law. Accordingly, the additions\nsustained by the Ld. CIT(A) are directed to be deleted.\n20. The Ld. CIT(A) has confirmed an addition of Rs.34,110/- in\nrespect of jewellery for the assessment year 2020-21 by relying\nupon a jewellery bill dated 28th October 2020. Similarly

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, LUDHIANA vs. MALBROS INTERNATIONAL PVT LTD, FARIDKOT

In the result, both the appeals and the Cross Objections are dismissed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 992 & 993/Chd/2024 "नधा"रण वष" / Assessment Years: 2017-18, 2016-17 The Dcit, Vs Malbros International Pvt. Ltd., Central Circle-2, Village – Mansoorwal, Teh-Zira, Ludhiana. Head Offices Old Cantt. Road, Faridkot. "थायी लेखा सं./Pan No: Aadcm7203R अपीलाथ"/Appellant ""यथ"/Respondent & C.O. Nos. 46 & 45/Chd/2024 In आयकर अपील सं./ Ita Nos. 992 & 993/Chd/2024 "नधा"रण वष" / Assessment Year: 2017-18, 2016-17 Malbros International Pvt. Ltd., The Dcit, Village – Mansoorwal, Teh-Zira, Vs Central Circle-2, Head Offices Old Cantt. Road, Ludhiana. Faridkot. "थायी लेखा सं./Pan No: Aadcm7203R अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Sudhir Sehgal, Advocate Revenue By : Smt. Kusum Bansal, Cit Dr Date Of Hearing : 14.05.2025 Date Of Pronouncement : 25.06.2025

section 131 - No enquiry in this regard was made and no evidence generally was made available by Assessing Officer - Whether since entire order of Assessing Officer was based merely on statement of Director of assessee without summoning or adducing additional/supplementary evidence of any other person corroborating allegation regarding bogus payments made by assessee, Tribunal was justified in deleting impugned addition

AMAN THUKRAL,LUDHIANA vs. INCOME TAX OFFICER WARD 2(1), LUDHIANA , LUDHIANA

Accordingly, Additional Ground No. 1 is allowed for statistical

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

disallowance of 50% of the purchases, we direct the Assessing Officer to estimate the profit element embedded in the disputed purchases and bring the same to tax. In our considered opinion, estimation of profit at 10% of the disputed purchases would meet the ends of justice. 26. The Assessing Officer is therefore directed to restrict the addition

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)

disallowing the 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

HIMACHAL PRADESH BOARD OF SCHOOL EDUCATION,KANGRA vs. DCIT (E), C-2, CHANDIGARH

In the result, appeals of the assessee are allowed for statistical purposes

Bench: Ms. Diva Singh & Dr.B.R.R.Kumar

131 of the Income Tax Act in answer to question No. 1 has categorically admitted that Board has received Rs. 24.66 Cr for distribution of free textbooks to the students belonging to reserved categories. The total book income on this issue was of Rs. 34.19 Cr which would clearly prove that assessee Board exists for the purpose of profit