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

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

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

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 6 administrative expenses under Rule 8D of the Income Tax Rules is not as per law. In view of the above disallowance made

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

131 (Punj. & Har.) holding that the window for disallowance is indicated in section 14A and is only to the extent of disallowing expenditure 'incurred by the assessee it relation to the tax exempt income', the disallowance under section 14A read with rule 3D as worked out by the Assessing Officer was not in accordance with law and as such working

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)

3. Brief facts relating to the issue raised in the above ground regarding disallowance of interest amounting to Rs.35,131/- u/s 36(l)(iii) of the IT Act, is that during the course of assessment proceedings, the Assessing Officer noticed that the assessee had made the following capital advances:- (a) Capital work in progress amounting to Rs.31

M/S HERITAGE EDUCATIONAL SOCIETY,CHANDIGARH vs. DCIT, C-1, (E), CHANDIGARH

disallowance of salary / honorarium paid to the trustees u/s 13(1)( c) read with sections 13(3) and 164(2) of the Income Tax Act, 1961 (in short 'the Act'), firstly, we shall deal with this issue. 4. The facts relating to this issue in brief are that the assessee trust / society is registered under Societies Registration

M/S HERITAGE EDUCATIONAL SOCIETY,CHANDIGARH vs. DCIT, C-1, (E), CHANDIGARH

disallowance of salary / honorarium paid to the trustees u/s 13(1)( c) read with sections 13(3) and 164(2) of the Income Tax Act, 1961 (in short 'the Act'), firstly, we shall deal with this issue. 4. The facts relating to this issue in brief are that the assessee trust / society is registered under Societies Registration

M/S HERITAGE EDUCATIONAL SOCIETY,CHANDIGARH vs. DCIT, C-1, (E), CHANDIGARH

disallowance of salary / honorarium paid to the trustees u/s 13(1)( c) read with sections 13(3) and 164(2) of the Income Tax Act, 1961 (in short 'the Act'), firstly, we shall deal with this issue. 4. The facts relating to this issue in brief are that the assessee trust / society is registered under Societies Registration

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

INCOME TAX OFFICER, KURUKSHETRA vs. JASVIR SINGH, VILLAGE DIWANA TEHSIL PEHOWA

In the result, appeal of the Revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 665/Chd/2023 "नधा"रण वष" / Assessment Year : 2013-14 Ito, Jasvir Singh, Kurukshetra बनाम Village Diwana Tehsil Pehowa, Vs. Distt. Kurukshetra 136128 "थायी लेखा सं./Pan No: Cnqps4895G अपीलाथ"/Appellant ""यथ"/Respondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : Sh. Parikshit Aggarwal, Ca राज"व क" ओर से/ Revenue By : Shri Manav Bansal, Cit Dr सुनवाई क" तार"ख/Date Of Hearing : 26.06.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 11.08.2025 आदेश/Order Per Krinwant Sahay, Am: Appeal In This Case Has Been Filed By The Revenue Against The Order Dated 12.09.2023 Of Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi.

Disallowance of the entire cash purchase results in abnormal trading profit for the assessee which it could never earn. There had never been any tax evasion with these transactions. The primary objective of enacting Section 40A(3) was to put a check on trading transactions with a mind to evade the liability to tax on income earned out of such

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(3) of Income Tax Act, 1961 “A survey under section 133A of Income Tax Act, 1961 was conducted at the business premises of the Cannon group of Industries having its offices at Delhi, Bombay and Ludhiana. The assessee is one of the concerns of this group of Industries and is engaged in manufacturing and trading of hosiery goods

M/S HEADMASTER SALOON PVT.LTD.,CHANDIGARH vs. DCIT-CIRCLE-1(1), CHANDIGARH

In the result, appeal of the assessee is allowed for statistical purposes

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

disallowed. Accordingly the assessee was /asked vide order sheet entry dt. 17/10/2016 to explain as to why these payments be not allowed as these payments have been made in the contravention of the provisions of Section 40A(3). In response the Counsel 11 submitted that although the surrendered income was to cover up for all discrepancies, however the amount

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

THE SIKH EDUCATIONAL SOCIETY,PATIALA vs. ADDL. CIT, RANGE, PATIALA

Bench: The Ld. Cit(A) Against Assessment Order Dt. 30/03/2013 Which Was Passed By Additional Commissioner Of Income Tax, Patiala Range, Patiala, Punjab Which Order Is Hereinafter Referred To As “Ao’S Order”.

disallowed vide this office letter dated 22-3-2013, which is reproduced below :- " In connection with the assessment for the A.Y. 2010-11, you are required to furnish the reply on the following points/ queries:- 2. During the course of assessment proceedings, it is noticed that :- (i) Despite affording number of opportunities , you have failed to produce the books