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 for corresponding purchases, no addition could be made under Section 68 in as much as it is not in dispute that the creditors outstanding related to purchases and the trading results were accepted by the AO. We are, therefore, of the opinion that no substantial question of law arises for consideration in this case. The appeal is accordingly dismissed

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 for corresponding purchases, no addition could be made under Section 68 in as much as it is not in dispute that the creditors outstanding related to purchases and the trading results were accepted by the AO. We are, therefore, of the opinion that no substantial question of law arises for consideration in this case. The appeal is accordingly dismissed

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 for corresponding purchases, no addition could be made under Section 68 in as much as it is not in dispute that the creditors outstanding related to purchases and the trading results were accepted by the AO. We are, therefore, of the opinion that no substantial question of law arises for consideration in this case. The appeal is accordingly dismissed

M/S SABER PAPER BOARD PRIVATE LIMITED,LUDHIANA vs. DCIT, LUDHIANA

In the result, all the appeals of the assessee are allowed for statistical purposes

Bench: Shri N.K. Saini & Shri Sanjay Garg

198/- on account of disallowance of interest under section 14A of the Income Tax Act, 1961. 4. That the learned

M/S SABER PAPER LIMITED,LUDHIANA vs. DCIT, LUDHIANA

In the result, all the appeals of the assessee are allowed for statistical purposes

Bench: Shri N.K. Saini & Shri Sanjay Garg

198/- on account of disallowance of interest under section 14A of the Income Tax Act, 1961. 4. That the learned

ACIT, CIRCLE, PANCHKULA vs. M/S JANAK GLOBAL RESOURCES PVT. LTD., PANCHKULA

In the result, the appeal of the Revenue is dismissed

section 14A of the Act. The contention of the Ld. counsel for assessee was that it was neither submitted to the court that sufficient own interest free funds were available, nor were any arguments made raising the presumption that 7 A.Y. 2014-15 would arise in such case. It was pointed out that even the question before

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

SMT. PRIYA ARORA,CHANDIGARH vs. ACIT, CC-II, CHANDIGARH

In the result, the appeals of the Assessee are disposed off as under:-

Bench: Shri A.D. Jain & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 153 To 155/Chd/2019 "नधा"रण वष" / Assessment Years : 2009-10, 2010-11 & 2011-12 Smt. Priya Arora, Vs. The Acit, बनाम Central Circle-Ii, 1136, Ist Floor, Chandigarh Sector 8-C, Chandigarh "थायी लेखा सं./Pan No: Ackpa6762B अपीलाथ"/ Appellant ""यथ"/ Repsondent ( Physical Hering ) "नधा"रती क" ओर से/Assessee By : Shri Tej Mohan Singh, Advocate राज"व क" ओर से/ Revenue By : Smt. Kusum Bansal, Cit, Dr सुनवाई क" तार"ख/Date Of Hearing : 25.09.2024 उदघोषणा क" तार"ख/Date Of Pronouncement : 09.10.2024 आदेश/Order Per Bench:

198 ITR 297 (SC.) The ld. Counsel argued that this order of the Hon'ble Supreme Court in the case of Sun Engineering Works (supra) is applicable for section 147 / 148 of the Act. It is not to be applied on the return filed in response to section 153A/B/C of the Act. 25. On the contrary, he has relied

SMT. PRIYA ARORA,CHANDIGARH vs. ACIT, CC-II, CHANDIGARH

In the result, the appeals of the Assessee are disposed off as under:-

Bench: Shri A.D. Jain & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 153 To 155/Chd/2019 "नधा"रण वष" / Assessment Years : 2009-10, 2010-11 & 2011-12 Smt. Priya Arora, Vs. The Acit, बनाम Central Circle-Ii, 1136, Ist Floor, Chandigarh Sector 8-C, Chandigarh "थायी लेखा सं./Pan No: Ackpa6762B अपीलाथ"/ Appellant ""यथ"/ Repsondent ( Physical Hering ) "नधा"रती क" ओर से/Assessee By : Shri Tej Mohan Singh, Advocate राज"व क" ओर से/ Revenue By : Smt. Kusum Bansal, Cit, Dr सुनवाई क" तार"ख/Date Of Hearing : 25.09.2024 उदघोषणा क" तार"ख/Date Of Pronouncement : 09.10.2024 आदेश/Order Per Bench:

198 ITR 297 (SC.) The ld. Counsel argued that this order of the Hon'ble Supreme Court in the case of Sun Engineering Works (supra) is applicable for section 147 / 148 of the Act. It is not to be applied on the return filed in response to section 153A/B/C of the Act. 25. On the contrary, he has relied

SMT. PRIYA ARORA,CHANDIGARH vs. ACIT, CC-II, CHANDIGARH

In the result, the appeals of the Assessee are disposed off as under:-

Bench: Shri A.D. Jain & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 153 To 155/Chd/2019 "नधा"रण वष" / Assessment Years : 2009-10, 2010-11 & 2011-12 Smt. Priya Arora, Vs. The Acit, बनाम Central Circle-Ii, 1136, Ist Floor, Chandigarh Sector 8-C, Chandigarh "थायी लेखा सं./Pan No: Ackpa6762B अपीलाथ"/ Appellant ""यथ"/ Repsondent ( Physical Hering ) "नधा"रती क" ओर से/Assessee By : Shri Tej Mohan Singh, Advocate राज"व क" ओर से/ Revenue By : Smt. Kusum Bansal, Cit, Dr सुनवाई क" तार"ख/Date Of Hearing : 25.09.2024 उदघोषणा क" तार"ख/Date Of Pronouncement : 09.10.2024 आदेश/Order Per Bench:

198 ITR 297 (SC.) The ld. Counsel argued that this order of the Hon'ble Supreme Court in the case of Sun Engineering Works (supra) is applicable for section 147 / 148 of the Act. It is not to be applied on the return filed in response to section 153A/B/C of the Act. 25. On the contrary, he has relied

M/S CORE METAL KRAFTS LTD.,CHANDIGARH vs. ACIT, C-5(1), CHANDIGARH

In the result, the appeal of the assessee is allowed

Bench: Us.

section has been the subject to interpretation by higher Judicial Forums repeatedly and the basic proposition laid down with regard to the same, as pointed out by the Ld.Counsel for the assessee, is that if all particulars of income are disclosed the mere disallowance of A.Y. 2013-14 Page 7 of 9 claim or non acceptance of claim

DCIT, C-I, LUDHIANA vs. M/S KAPSONS ASSOCIATES INVESTMENTS (P) LTD., LUDHIANA

In the result, appeal of the Revenue stands dismissed

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

section 14A of the Act read with Rule 8D of the Rules and apportioned the expenditure. The CIT(A) had set aside the disallowance, which view was upturned by the ITAT in the following words: "...Admittedly the assessee had paid total interest of Rs.2.92 crores out of which interest paid on term loan raised for specific purpose totals to Rs.1.70

SHRI SANJAY JAIN,BATHINDA vs. DCIT, CC-1, LUDHIANA

Bench: Shri Sanjay Garg & Ms. Annapurna Guptaआयकर अपील सं./ Ita Nos. 625 & 626/Chd/2019 "नधा"रण वष" / Assessment Years : 2013-14 & 2014-15 The Dcit, Shri Tarun Jain, बनाम Central Circle-1, C/O M/S Royal Lifestyle Jewellers Chandigarh Pvt Limited, Bhatinda "थायी लेखा सं./Pan No: Ahwpj2158H Appeal Against The Order Of Cit(A)-1, Ludhiana Dated 11.3.2018 अपीलाथ"/Appellant ""यथ"/Respondent

section 10(38) of the Income Tax Act are fulfilled. As such, addition confirmed is unjustified. The same be deleted. 5. That the learned CIT(A) has erred on facts and in law by upholding the addition by following the single member judgement of ITAT, Delhi Bench ignoring two member judgements of ITAT. Delhi Bench and judgements of jurisdictional High

SHRI SANJAY JAIN,BATHINDA vs. DCIT, CC-1, LUDHIANA

Bench: Shri Sanjay Garg & Ms. Annapurna Guptaआयकर अपील सं./ Ita Nos. 625 & 626/Chd/2019 "नधा"रण वष" / Assessment Years : 2013-14 & 2014-15 The Dcit, Shri Tarun Jain, बनाम Central Circle-1, C/O M/S Royal Lifestyle Jewellers Chandigarh Pvt Limited, Bhatinda "थायी लेखा सं./Pan No: Ahwpj2158H Appeal Against The Order Of Cit(A)-1, Ludhiana Dated 11.3.2018 अपीलाथ"/Appellant ""यथ"/Respondent

section 10(38) of the Income Tax Act are fulfilled. As such, addition confirmed is unjustified. The same be deleted. 5. That the learned CIT(A) has erred on facts and in law by upholding the addition by following the single member judgement of ITAT, Delhi Bench ignoring two member judgements of ITAT. Delhi Bench and judgements of jurisdictional High

SHRI SANJAY JAIN,BATHINDA vs. DCIT, CC-1, LUDHIANA

Bench: Shri Sanjay Garg & Ms. Annapurna Guptaआयकर अपील सं./ Ita Nos. 625 & 626/Chd/2019 "नधा"रण वष" / Assessment Years : 2013-14 & 2014-15 The Dcit, Shri Tarun Jain, बनाम Central Circle-1, C/O M/S Royal Lifestyle Jewellers Chandigarh Pvt Limited, Bhatinda "थायी लेखा सं./Pan No: Ahwpj2158H Appeal Against The Order Of Cit(A)-1, Ludhiana Dated 11.3.2018 अपीलाथ"/Appellant ""यथ"/Respondent

section 10(38) of the Income Tax Act are fulfilled. As such, addition confirmed is unjustified. The same be deleted. 5. That the learned CIT(A) has erred on facts and in law by upholding the addition by following the single member judgement of ITAT, Delhi Bench ignoring two member judgements of ITAT. Delhi Bench and judgements of jurisdictional High

SANJAY JAIN & SONS,BATHINDA vs. DCIT, CC-1, LUDHIANA

Bench: Shri Sanjay Garg & Ms. Annapurna Guptaआयकर अपील सं./ Ita Nos. 625 & 626/Chd/2019 "नधा"रण वष" / Assessment Years : 2013-14 & 2014-15 The Dcit, Shri Tarun Jain, बनाम Central Circle-1, C/O M/S Royal Lifestyle Jewellers Chandigarh Pvt Limited, Bhatinda "थायी लेखा सं./Pan No: Ahwpj2158H Appeal Against The Order Of Cit(A)-1, Ludhiana Dated 11.3.2018 अपीलाथ"/Appellant ""यथ"/Respondent

section 10(38) of the Income Tax Act are fulfilled. As such, addition confirmed is unjustified. The same be deleted. 5. That the learned CIT(A) has erred on facts and in law by upholding the addition by following the single member judgement of ITAT, Delhi Bench ignoring two member judgements of ITAT. Delhi Bench and judgements of jurisdictional High

TARUN JAIN,BATHINDA vs. DCIT, CC-1, LUDHIANA

Bench: Shri Sanjay Garg & Ms. Annapurna Guptaआयकर अपील सं./ Ita Nos. 625 & 626/Chd/2019 "नधा"रण वष" / Assessment Years : 2013-14 & 2014-15 The Dcit, Shri Tarun Jain, बनाम Central Circle-1, C/O M/S Royal Lifestyle Jewellers Chandigarh Pvt Limited, Bhatinda "थायी लेखा सं./Pan No: Ahwpj2158H Appeal Against The Order Of Cit(A)-1, Ludhiana Dated 11.3.2018 अपीलाथ"/Appellant ""यथ"/Respondent

section 10(38) of the Income Tax Act are fulfilled. As such, addition confirmed is unjustified. The same be deleted. 5. That the learned CIT(A) has erred on facts and in law by upholding the addition by following the single member judgement of ITAT, Delhi Bench ignoring two member judgements of ITAT. Delhi Bench and judgements of jurisdictional High

RAJNI JAIN,BATHINDA vs. DCIT, CC-1, LUDHIANA

Bench: Shri Sanjay Garg & Ms. Annapurna Guptaआयकर अपील सं./ Ita Nos. 625 & 626/Chd/2019 "नधा"रण वष" / Assessment Years : 2013-14 & 2014-15 The Dcit, Shri Tarun Jain, बनाम Central Circle-1, C/O M/S Royal Lifestyle Jewellers Chandigarh Pvt Limited, Bhatinda "थायी लेखा सं./Pan No: Ahwpj2158H Appeal Against The Order Of Cit(A)-1, Ludhiana Dated 11.3.2018 अपीलाथ"/Appellant ""यथ"/Respondent

section 10(38) of the Income Tax Act are fulfilled. As such, addition confirmed is unjustified. The same be deleted. 5. That the learned CIT(A) has erred on facts and in law by upholding the addition by following the single member judgement of ITAT, Delhi Bench ignoring two member judgements of ITAT. Delhi Bench and judgements of jurisdictional High