M/S APEX BUILDERS, LUDHIANA vs. ITO, W-2(1), LUDHIANA

The appeal is partly allowed

Bench: SHRI. LALIET KUMAR (Judicial Member)

191 ITR 667 (SC)], and by several decisions of coordinate Benches of the Tribunal, including Raja & Co., ITA No. 534/Cochin/2011, M/s A. Daga Royal Arts, ITA No. 1065/JP/2016, and Excel Engineers vs. JCIT, ITA No. 1588/Kol/2013. According to the assessee, these decisions support the claim that the impugned disallowance under Section

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, instead of taking into account total\ninvestment, investment attributable to dividend was required to be\nadopted an thereafter disallowance was to be arrived.\n33. The Ld. Counsel of assessee also argued that suo-moto\ndisallowance can also be challenged. Hon'ble SC and many other\ncourts held that the object of the income tax proceedings is to\ndetermine

SH. RAJIV KUMAR,MOHALI vs. ITO , WARD -1,, SANGRUR

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. 8. Now the assessee is in appeal. 9. 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

ABHINAV IMPEX,LUDHIANA vs. ITO , LUDHIANA

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

Bench: The Date Of Filing The Return Of Income Under Income Tax Act, 1961. In So Far As The Income-Tax Act Is Concerned, The Assesse Can Get The Benefit If The Actual Payment Is Made Before The Return Is Filed. The Employee Share For Epf Is Rs. 1,17,494/-And Esi Is Rs. 45,993/-.

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

M/S LONGOWALIA YARNS LIMITED,LUDHIANA vs. DCIT, CENTRAL CIRLE -1, CHANDIGARH

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

Bench: Filing Of The Return.

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 Ld. Sr. DR strongly supported the orders of the authorities below and submitted that since the payment of Rs. 29,22,964/- towards ESI and PF was not made within

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

M/S S.R. INDUSTRIES LIMITED,CHANDIGARH vs. ACIT, CHANDIGARH

In the result, appeal is allowed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwal

disallowed an interest amount under Section 36(1) at Rs.77,191/-. He has examined the WIP, interest position etc. 9. While

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

Section 13(3) and 164(2) of the Income Tax Act. ITA Nos. 797 & 798/CHD/2024 A.Y.2014-15 & 2015-16 10 10.1 While impugning the disallowances, ld. counsel for the assessee took us through the Paper Book. He submitted that details of honorarium paid to different individuals in all these years is being placed on page 191

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

Section 13(3) and 164(2) of the Income Tax Act. ITA Nos. 797 & 798/CHD/2024 A.Y.2014-15 & 2015-16 10 10.1 While impugning the disallowances, ld. counsel for the assessee took us through the Paper Book. He submitted that details of honorarium paid to different individuals in all these years is being placed on page 191

SH. AMAN SETH,LUDHIANA vs. ITO, W-1(1), LUDHIANA

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

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

191 held that for disallowance u/s 36(l)(iii) of the Income Tax Act, 1961 the total fund (i.e owned fund and borrowed funds) is considered for working out the disallowance of interest. The Hon'ble High Court of Punjab and Haryana in the above said case held that “ Where mixed funds are diverted towards interest free advances, the disallowance

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

ACIT, CIRCLE 1(1), CHANDIGARH vs. M/S SML ISUZU LTD., CHANDIGARH

In the result, the impugned order is sustained and appeal of the Revenue is partly allowed for statistical purposes

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

Disallowance of payment of bonus / Ex gratia made  14. During the year under consideration, the assessee company claimed deduction of amount aggregating to Rs.2,42,59,981, being payment of bonus / ex-gratia made after 31st March 2018 but before the due date of filing the return of income under section

ACIT, CIRCLE 1(1), CHANDIGARH vs. M/S SML ISUZU LTD., CHANDIGARH

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

disallowed from the gross dividend income received by the assessee. From the reasons recorded by the Assessing Officer, it was clear that the assessment was sought to be reopened merely on suspicion that the assessee might have utilized the borrowed fund for investment and that the assessee might have incurred expenditure for earning the dividend income. There was no material

WINSOME TEXTILE INDUSTRIES LIMITED,CHANDIGARH vs. ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-4(1), CHANDIGARH, CHANDIGARH

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

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

191 ITR 662, for initiation of action under section 147(a) (as the provision stood at the relevant time) fulfilment of the two requisite conditions in that regard is essential. At that stage, the final outcome of the proceeding is not relevant. In other words, at the initiation stage, what is required is "reason to believe", but not the established

THE JYOTI CO-OPERATIVE NON AGRICULTURAL THRIFT & CREDIT SOCIETY LTD.,SIRMOUR vs. ITO, WARD, NAHAN

In the result, the assessee is not eligible for deduction on interest on deposits placed with scheduled commercial banks under section 80(P)(2)(a)(i) of the Act and the appeal of the assessee is di...

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member)

191/-. Thereafter, the assessee carried the matter in appeal before the Ld. CIT(A) who has confirmed the action of the AO and on further appeal by the assessee, the Coordinate Bench (vide its order dt. 11/03/2019 in ITA No. 1296 & 1297/Chd/2018 pertaining to Assessment Year 2012- 13 & 2013-14) has set aside the matter to the file

THE JYOTI CO-OPERATIVE NON AGRICULTURAL THRIFT & CREDIT SOCIETY LTD.,SIRMOUR vs. ITO, WARD, NAHAN

In the result, the assessee is not eligible for deduction on interest on deposits placed with scheduled commercial banks under section 80(P)(2)(a)(i) of the Act and the appeal of the assessee is di...

191/-. Thereafter, the assessee carried the matter in appeal before the Ld. CIT(A) who has confirmed the action of the AO and on further appeal by the assessee, the Coordinate Bench (vide its order dt. 11/03/2019 in ITA No. 1296 & 1297/Chd/2018 pertaining to Assessment Year 2012- 13 & 2013-14) has set aside the matter to the file

THE JYOTI CO-OPERATIVE NON AGRICULTURAL THRIFT & CREDIT SOCIETY LTD.,SIRMOUR vs. ITO, WARD, NAHAN

In the result, the assessee is not eligible for deduction on interest on deposits placed with scheduled commercial banks under section 80(P)(2)(a)(i) of the Act and the appeal of the assessee is di...

Bench: SHRI. VIKRAM SINGH YADAV, AM आयकर अपील सं . / ITA No.160, 161 & 162/ Chd/2023 निर्धारण वर्ष / Assessment Year : 2017-18, 2012-13 & 2013-14 The Jyoti Co-operative Non Agricultural Thrift & Credit Society Ltd. Sirmour, Solan, HP-173025 स्थायी लेखा सं. / PAN NO: AAABT1453G अपीलार्थी/Appellant बनाम The ITO H.P Ward-Nahan, Sirmour प्रत्यर्थी/Respondent निर्धारिती की ओर से/Assessee by : Shri Vishal Mohan, Sr. Advocate with Shri Parveen Sharma, Advocate राजस्व की ओर से / Revenue by : Dr. Ranjeet K

191/-. Thereafter, the assessee carried the matter in appeal before the Ld. CIT(A) who has confirmed the action of the AO and on further appeal by the assessee, the Coordinate Bench (vide its order dt. 11/03/2019 in ITA No. 1296 & 1297/Chd/2018 pertaining to Assessment Year 2012- 13 & 2013-14) has set aside the matter to the file

M/S NIRBHAI TEXTILES PVT. LTD.,LUDHIANA vs. ACIT, C-2, LUDHIANA

The appeal of the assessee stands allowed

Bench: Shri N.K. Saini & Shri Sudhanshu Srivastavaआयकरअपीलसं./Ita No.1401/Chd/2018 "नधा"रणवष" / Assessment Year :2014-15

191 DTR 345 in which the same principle has been upheld and the order of the Tribunal deleting the addition made u/s 56(2)(viib) was upheld. 3.5 The Ld. AR also relied upon the order of the Chandigarh Bench of the ITAT in the case of ‘Dada Ganpati Gold Products Pvt. Ltd.’ reported in (2021) 92 (Trib

S.P. SINGLA CONSTRUCTION PRIVATE LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CHANDIGARH

In the result, the appeal is allowed

Bench: SHRI MAHAVIR SINGH (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

disallowed as per the provisions of the Income Tax Act, 1961.” Analysis of information by the AO: 3. Vide letter dated 01.03.2019 and email ID at manojkumar@sbsingla.com andspscpkl@gmail.com, assessee Company was requested to provide following information to this office on or before 06.03.2019: I. Please furnish copies of nil, audit financial statements with all annexures