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 5 of the Limitation Act should receive a liberal construction so as to advance substantial justice vide Shakuntala Devi lain Vs. Kuntal Kumari [AIR 1969 SC 575] and State of West Bengal Vs. The Administrator, Howrah Municipality [AIR 1972 SC 749]. It must be remembered that in every case of delay there can be some lapse on the part

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\nare dismissed

Section 5 of the Limitation Act should receive a\nliberal construction so as to advance substantial\njustice vide Shakuntala Devi lain Vs. Kuntal Kumari\n[AIR 1969 SC 575] and State of West Bengal Vs. The\nAdministrator, Howrah Municipality [AIR 1972 SC\n749]. It must be remembered that in every case of\ndelay there can be some lapse

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 depreciation amounting to Rs. 70,000/- on the building. 5. Notwithstanding, the above said grounds of appeal, the Ld. CIT(Appeals) has wrongly confirmed the order passed u/s 143(3). 6. That the Ld. CIT(A), Ludhiana has erred in confirming the action of the Assessing Officer in invoking the provision of Section 68 of the Income

SHRI BALBIR SINGH VERMA,SHIMLA vs. PR.CIT, SHIMLA

In the result, appeal of the Assessee is allowed

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

133A conducted on 04.03.2015. 3.2 Regarding Interest Claimed under Section 24(b) of the Act, the AO observed that the assessee claimed Rs. 39,15,328/- as interest on borrowed capital for seven properties under Section 24(b). The Ld. AO asked the assessee to provide loan agreements and bank certificates related to loan. However, the assessee did not provided

SH. KRISHAN KUMAR,KHANNA vs. DCIT, CC-1, LUDHIANA

In the result, the appeal of the Assessee is allowed

Bench: Shri A.D. Jain & Shri Vikram Singh Yadav

133A of the Income Tax Act, 1961 on 24.01.2019, the Assessee had offered an additional income of Rs. 1,00,00,000/- as business income and was duly declared in the return of income. The same also stood accounted for in the books of account and was a part of the trading account. While framing assessment, the Assessing Officer treated

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

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

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

M/S SHUBHAM COTTON MILLS PVT. LTD.,ELLENABAD vs. DCIT, CIRCLE, SIRSA

In the result appeal of the assessee is allowed

133A of the Act) is found sustainable hence confirmed. 7. Now the assessee is in appeal. 7.1. The Ld. Counsel for the assessee reiterated the submissions made before the authorities and further submitted that at the time of survey selling price of guwar gum was Rs. 14500/- per quintal which had been reduced to Rs. 11,700/- per quintal within

KAMBOJ TRADING COMPANY,GURUHARSAHAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-3, LUDHIANA

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)

133A (1) of the Income Tax Act, 1961 was conducted on 15/11/2017 at the business premises of the assessee and various documents were impounded during the course of survey. Subsequently, the case was selected under compulsory scrutiny as per the guidelines of CBDT, New Delhi and notice under section 143(2) of the Income Tax Act, 1961 was issued

M/S ASHA TECHNOLOGIES,SIRMOUR vs. ADDL. CIT, SOLAN

In the result, both the above appeals of the Assessee are partly allowed as aforesaid in respect of impugned orders dt

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

133A of the IT Act to find out the true facts of the case when there was no compliance and cooperation on the part of the assessee to prove its primary onus. And on the basis of survey only true facts of the case were ascertained which helped in ascertaining the factual reality. The assessing office collected information

M/S ASHA TECHNOLOGIES,KALA AMB vs. ITO, SIRMOUR

In the result, both the above appeals of the Assessee are partly allowed as aforesaid in respect of impugned orders dt

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

133A of the IT Act to find out the true facts of the case when there was no compliance and cooperation on the part of the assessee to prove its primary onus. And on the basis of survey only true facts of the case were ascertained which helped in ascertaining the factual reality. The assessing office collected information

GEETA SHARMA,SUNAM vs. PRINCIPAL COMMISSIONER OF INCOME TAX , PATIALA

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

disallowance under Section 10(37) of the Act. It was stated that tax has been calculated on income of Rs.3,79,320/- and [agriculture income of Rs.2,50,000/- only] but not on assessed income of Rs.2,98,60,842/-. 15.2 In the aforesaid Show Cause Notice dated 05.02.2024 it was further alleged that“you had e-filed your return

ANISH GARG,PATIALA vs. ITO WARD-4, PATIALA

In the result, the appeal of the assessee is allowed

disallowance of expenses.\n9. That the CIT(A) has wrongly upheld that addition of Rs 50,000/- made by AO on\naccount of household expenses.”\n2.\nBriefly the facts of the case are that the assessee has originally filed his\nreturn of income on 12/09/2012 declaring total income of Rs.2,74,500/-.\nSubsequently, survey action was conducted under section 133A