ATUL GLOBAL PVT. LTD.,LUDHIANA vs. ITO, WARD 1 (1),, LUDHIANA

In the result, both the appeals of the assessees are allowed

section 139(1) of the Act. When the matter was taken to the Ld. CIT(A) the said disallowance was sustained. 5. Now the assessee is in appeal. 6. The contention of the assessee in the written submission was that the employees’ contribution to ESI and PF collected by the assessee from its employees had been deposited before

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

DCIT-CC-III, LUDHIANA vs. M/S LAXMI ENERGY & FOODS LTD.,, CHANDIGARH

In the result, the appeal of the Revenue is dismissed

Bench: Shri A.D. Jain & Dr Krinwant Sahayआयकर अपील सं./ Ita No. 33/Chd/2021 "नधा"रण वष" / Assessment Year: 2011-12 The Dcit, Vs. M/S Laxmi Energy & Foods बनाम Ltd., Central Circle-Iii, Sco 18-19, Sector 9-D, Ludhiana Ludhiana "थायी लेखा सं./Pan No: Aaacl3147J अपीलाथ"/ Appellant ""यथ"/ Repsondent ( Hybrid Mode ) "नधा"रती क" ओर से/Assessee By : Sh. Sudhir Sehgal, Advocate राज"व क" ओर से/ Revenue By : Shri Rohit Sharma, Cit Dr सुनवाई क" तार"ख/Date Of Hearing : 06.06.2024 उदघोषणा क" तार"ख/Date Of Pronouncement : 10.07.2024 आदेश/Order Per Dr. Krinwant Sahay, A.M.:

133 & 134/Chd/2019 and order dated 05.09.2019. (iii) Along with the same reliance is also placed on the following judgments: - (a) Joint Investment Pvt. Ltd. vs CIT (Del. HC) as reported in ITA 117/2015 - "By no stretch of imagination can section 14A or Rule 8D be interpreted so as to mean that the entire tax exempt income is be disallowed

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

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

ASTT. COMMISSIONER OF INCOME TAX, CIRCLE-4, LUDHIANA, AAYAKAR BHAWAN vs. WARYAM STEEL CASTING PRIVATE LIMITED, KANGANWAL ROAD

In the result, appeal of the assessee is allowed and the Cross appeal of the Revenue is dismissed

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

Section 133(6) to Rahul Pratap Singh, which went unanswered, and the Verification Unit confirmed the lack of transactions with the assessee. The AO also observed irregularities in the bill numbers issued by GSTC, which were non-sequential, and concluded that the transportation bills were unreliable. Consequently, the AO disallowed

WARYAM STEEL CASTINGS PRIVATE LIMITED,LUDHIANA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-4, LUDHIANA

In the result, appeal of the assessee is allowed and the Cross appeal of the Revenue is dismissed

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

Section 133(6) to Rahul Pratap Singh, which went unanswered, and the Verification Unit confirmed the lack of transactions with the assessee. The AO also observed irregularities in the bill numbers issued by GSTC, which were non-sequential, and concluded that the transportation bills were unreliable. Consequently, the AO disallowed

KHANNA INFRABUILD PRIVATE LIMITED ,LUDHIANA vs. THE DEPUTY COMMISSIONER OF INCOME TAX (CENTRAL CIRCLE)-2, LUDHIANA, LUDHIANA

In the result, the ground of appeal is allowed

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

disallowed without giving specific finding. 14. That the assessee craves leave to add, amend, alter any ground or grounds of appeal before the appeal is finally heard or disposed off.” 6. With the consent of the parties, the case of the assessee in ITA No.633/Chd/2023 was taken as the lead case wherein the brief facts of the case are that

KHANNA INFRABUILD PRIVATE LIMITED ,LUDHIANA vs. THE DEPUTY COMMISSIONER OF INCOME TAX (CENTRAL CIRCLE)-2 LUDHIANA, LUDHIANA

In the result, the ground of appeal is allowed

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

disallowed without giving specific finding. 14. That the assessee craves leave to add, amend, alter any ground or grounds of appeal before the appeal is finally heard or disposed off.” 6. With the consent of the parties, the case of the assessee in ITA No.633/Chd/2023 was taken as the lead case wherein the brief facts of the case are that

KHANNA INFRABUILD PRIVATE LIMITED 2000-1A, SUKHDEV NAGAR FEROZEPUR ROAD, LUDHIANA,LUDHIANA vs. THE DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2 LUDHIANA, LUDHIANA

In the result, the ground of appeal is allowed

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

disallowed without giving specific finding. 14. That the assessee craves leave to add, amend, alter any ground or grounds of appeal before the appeal is finally heard or disposed off.” 6. With the consent of the parties, the case of the assessee in ITA No.633/Chd/2023 was taken as the lead case wherein the brief facts of the case are that

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

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 was made by the AO under the provisions of Section 40A(3) of the Act; that therefore, the assessment order was an erroneous order prejudicial to the interests of the Revenue, which was rightly set aside by the ld. PCIT, remitting the matter to the AO for fresh assessment. 9.5. The first issue is as to whether

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 was made by the AO under the provisions of Section 40A(3) of the Act; that therefore, the assessment order was an erroneous order prejudicial to the interests of the Revenue, which was rightly set aside by the ld. PCIT, remitting the matter to the AO for fresh assessment. 9.5. The first issue is as to whether

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 was made by the AO under the provisions of Section 40A(3) of the Act; that therefore, the assessment order was an erroneous order prejudicial to the interests of the Revenue, which was rightly set aside by the ld. PCIT, remitting the matter to the AO for fresh assessment. 9.5. The first issue is as to whether

DEEPAK KUMAR PROP. M/S URVI ENTERPRISES MANDIGOBINDGARH,MANDI GOBINDGARH vs. THE ASSESSMENT UNIT NFAC DELHI JAO THE INCOME TAX OFFICER WARD-2 MANDI GOBINDGARH, MANDI GOBINDGARH

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

section 133(6) of the Act were issued to the said parties to verify the transactions entered into by the assessee. It is observed that no compliance was made by most of the parties. In certain cases, notices could not be served due to incomplete or incorrect addresses, while in other cases, despite service of notices, no reply was received

INCOME TAX OFFICER, NEW LIBRA KOTHI, RAILWAY ROAD, SIRHIND vs. BHAGWAN DASS, AMLOH ROAD, MANDI GOBINDGARH

In the result, appeal of the Revenue is dismissed

disallowed in full.\n3.3 A major issue considered by the Assessing Officer was the genuineness of\npurchases aggregating to Rs.5,07,64,711/- from several suppliers who were flagged\nas non-genuine. Notices under section 133

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

section 156 is not provided. 1. Deviation from consistency by the Learned AO 1.4 This action of the Learned AO, completely violates the principles of consistency, appreciated by the Hon'ble Courts in various decisions, extracts for which are discussed hereunder:- a) CIT Vs. Dalmia Dadri Cement Lid. [1970] 77 ITR 410 (P&H) b) Berger Paints India

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

section 156 is not provided. 1. Deviation from consistency by the Learned AO 1.4 This action of the Learned AO, completely violates the principles of consistency, appreciated by the Hon'ble Courts in various decisions, extracts for which are discussed hereunder:- a) CIT Vs. Dalmia Dadri Cement Lid. [1970] 77 ITR 410 (P&H) b) Berger Paints India