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

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

section 14A by\ninserting a non-obstante clause and Explanation will take effect from 1-\n4-2022 and cannot be presumed to have retrospective effect.\n34.1 The appellant also placed reliance on the judgment of the\nHon'ble Jurisdictional Punjab & Haryana High Court in the case of CIT\nVs. Deepak Mittal (2014) 361 ITR 131 to the effect that

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 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

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

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

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

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), CHANDIGARH, CHANDIGARH vs. UNIPRO TECHNO INFRASTRUCTURE PVT LTD, CHANDIGARH

In the result, the order of the ld CIT(A) is confirmed and the grounds of appeal taken by the Revenue are dismissed

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

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

THE HARYANA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT,PANCHKULA vs. DCIT, CIRCLE, PANCHKULA, PANCHKULA

Appeal is allowed

Bench: BEFORE: SHRI. RAJPALYADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

section 80P, we find no merit in interfering with the impugned order of the CIT(A). Accordingly, this ground of appeal is dismissed as not pressed. Ground No. 4: Deduction u/s 80P to the extent of interest earned from nationalized banks. 73. We noticed that since this issue is identical to the issue involved in ITA No. 588/Chandi/2024

THE HARYANA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT,PANCHKULA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE,, PANCHKULA

Appeal is allowed

Bench: BEFORE: SHRI. RAJPALYADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

section 80P, we find no merit in interfering with the impugned order of the CIT(A). Accordingly, this ground of appeal is dismissed as not pressed. Ground No. 4: Deduction u/s 80P to the extent of interest earned from nationalized banks. 73. We noticed that since this issue is identical to the issue involved in ITA No. 588/Chandi/2024

ASSISTANT COMMISSIONER OF INCOME TAX, PANCHKULA CIRCLE, PANCHKULA, PANCHKULA vs. THE HARYANA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT, PANCHKULA

Appeal is allowed

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

section 80P, we find no merit in interfering with the impugned order of the CIT(A). Accordingly, this ground of appeal is dismissed as not pressed. Ground No. 4: Deduction u/s 80P to the extent of interest earned from nationalized banks. 73. We noticed that since this issue is identical to the issue involved in ITA No. 588/Chandi/2024

THE HARYANA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT,PANCHKULA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE, PANCHKULA

Appeal is allowed

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

section 80P, we find no merit in interfering with the impugned order of the CIT(A). Accordingly, this ground of appeal is dismissed as not pressed. Ground No. 4: Deduction u/s 80P to the extent of interest earned from nationalized banks. 73. We noticed that since this issue is identical to the issue involved in ITA No. 588/Chandi/2024

ASSISTANT COMMISSIONER OF INCOME TAX, PANCHKULA CIRCLE, PANCHKULA, PANCHKULA vs. THE HARYANA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT, PANCHKULA

Appeal is allowed

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

section 80P, we find no merit in interfering with the impugned order of the CIT(A). Accordingly, this ground of appeal is dismissed as not pressed. Ground No. 4: Deduction u/s 80P to the extent of interest earned from nationalized banks. 73. We noticed that since this issue is identical to the issue involved in ITA No. 588/Chandi/2024