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

disallowance of interest expenditure on amount advanced to subsidiary company and held that - "Commercial expediency in advancing loan does not arise only on account of there being transactions directly between holding company and subsidiary company. The two companies may even be in a different line of business. It would make no difference. It would still be commercially expedient

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

disallowance of Rs. 10,88,438/-. The grounds\nraised by the assessee are accordingly allowed.\n15. In the result, the appeal filed by the assessee is allowed.\"\nc) The Hon'ble Pune ITAT in the case of Kumar Housing Corporation (P)\nLtd vs. ITO (2024) 167 Taxmann.com 259 (Pune - Trib.) also held as\nunder:\n\"20. Since the assessee

DCIT, C-1(1) , CHANDIGARH vs. M/S FIDELITY INFORMATION SERVICES INDIA PVT. LTD., CHANDIGARH

In the result, the cross-objection filed by the assessee is dismissed

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

disallowed the foreign travel expenses which clearly form part of the operating expenses and the cost base and on which the assessee has reported the revenues after considering the mark up of 16.60%. Such an action on part of the AO is clearly in breach of letter and spirit of the APA which has been entered into by CBDT

RAM NIWAS,FATEHABAD vs. INCOME TAX OFFICER, INCOME TAX OFFICE, SIRSA ROAD, INDUSTRIAL AREA, FATEHABAD

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

disallowance. 5. On examination of assessment records, the Ld. Pr. CIT noticed that during the relevant year, the assessee had received an interest amounting to Rs. 1,05,10,592/- on enhanced compensation arising from the acquisition of land. The Assessing Officer had treated the said receipt as exempt and did not bring the same to tax. 6. According

SH. BALJINDER SINGH,CHANDIGARH vs. PR.CIT, CHANDIGARH -1, CHANDIGARH

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

disallowance. 5. On examination of assessment records, the Ld. Pr. CIT noticed that during the relevant year, the assessee had received an interest amounting to Rs. 1,05,10,592/- on enhanced compensation arising from the acquisition of land. The Assessing Officer had treated the said receipt as exempt and did not bring the same to tax. 6. According

INDER KAUR,SIRSA vs. PR.CIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

disallowance. 5. On examination of assessment records, the Ld. Pr. CIT noticed that during the relevant year, the assessee had received an interest amounting to Rs. 1,05,10,592/- on enhanced compensation arising from the acquisition of land. The Assessing Officer had treated the said receipt as exempt and did not bring the same to tax. 6. According

PARVEEN KUMAR,229,VILLAGE MANAKPUR-II,TEHSIL JAGADHRI,HARYANA vs. PRABHJOT KAUR,PCIT PANCHKULA, CHANDIGARH

In the result, all the above appeals filed by the respective assessee’s are dismissed

Bench: the Tribunal as pointed out by the Registry. Considering that the issue involved is purely legal in nature, and respectfully following the ratio laid down by the Hon'ble Supreme Court in Collector, Land Acquisition v. Mst. Katiji & Others [(1987) 167 ITR 471 (SC)], which emphasizes that substantial justice should prevail over technical considerations, we condone the delay in filing these appeals.3. We shall take appeal of the assessee in ITA No. 167/Chd/2023 for A.Y 2018-19 as a lead case f

disallowance. 5. On examination of assessment records, the Ld. Pr. CIT noticed that during the relevant year, the assessee had received an interest amounting to Rs. 1,05,10,592/- on enhanced compensation arising from the acquisition of land. The Assessing Officer had treated the said receipt as exempt and did not bring the same to tax. 6. According

RAKESH KUMAR,JAGADHRI vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, PANCHKULA

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

disallowance. 5. On examination of assessment records, the Ld. Pr. CIT noticed that during the relevant year, the assessee had received an interest amounting to Rs. 1,05,10,592/- on enhanced compensation arising from the acquisition of land. The Assessing Officer had treated the said receipt as exempt and did not bring the same to tax. 6. According

KARAN PRATAP SINGH,SIRSA, HARYANA vs. ITO, WARD-1, SIRSA, HARYANA

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

disallowance. 5. On examination of assessment records, the Ld. Pr. CIT noticed that during the relevant year, the assessee had received an interest amounting to Rs. 1,05,10,592/- on enhanced compensation arising from the acquisition of land. The Assessing Officer had treated the said receipt as exempt and did not bring the same to tax. 6. According

SH. RAM LAL,FATEHABAD vs. PR.CIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

disallowance. 5. On examination of assessment records, the Ld. Pr. CIT noticed that during the relevant year, the assessee had received an interest amounting to Rs. 1,05,10,592/- on enhanced compensation arising from the acquisition of land. The Assessing Officer had treated the said receipt as exempt and did not bring the same to tax. 6. According

SH. DEVENDER KUMAR,YAMUNA NAGAR vs. ITO, WARD -1, YAMUNA NAGAR

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

disallowance. 5. On examination of assessment records, the Ld. Pr. CIT noticed that during the relevant year, the assessee had received an interest amounting to Rs. 1,05,10,592/- on enhanced compensation arising from the acquisition of land. The Assessing Officer had treated the said receipt as exempt and did not bring the same to tax. 6. According

ASHOK KUMAR THAKRAL,JAGADHRI vs. PRINCIPAL COMMISSIONER OF INCOME TAX, PANCHKULA , PANCHKULA

In the result, all the above appeals filed by the respective assessee’s are dismissed

Bench: the Tribunal as pointed out by the Registry. Considering that the issue involved is purely legal in nature, and respectfully following the ratio laid down by the Hon'ble Supreme Court in Collector, Land Acquisition v. Mst. Katiji & Others [(1987) 167 ITR 471 (SC)], which emphasizes that substantial justice should prevail over technical considerations, we condone the delay in filing these appeals.3. We shall take appeal of the assessee in ITA No. 167/Chd/2023 for A.Y 2018-19 as a lead case f

disallowance. 5. On examination of assessment records, the Ld. Pr. CIT noticed that during the relevant year, the assessee had received an interest amounting to Rs. 1,05,10,592/- on enhanced compensation arising from the acquisition of land. The Assessing Officer had treated the said receipt as exempt and did not bring the same to tax. 6. According

MANINDER JEET SINGH V.P.O. UDHAMGARH,JAGADHRI,HARYANA vs. PRABHJOT KAUR,PCIT, PANCHKULA

In the result, all the above appeals filed by the respective assessee’s are dismissed

disallowance. 5. On examination of assessment records, the Ld. Pr. CIT noticed that during the relevant year, the assessee had received an interest amounting to Rs. 1,05,10,592/- on enhanced compensation arising from the acquisition of land. The Assessing Officer had treated the said receipt as exempt and did not bring the same to tax. 6. According

MADHU GREWAL,CHANDIGARH vs. PRINCIPAL COMMISSIONER OF INCOME TAX, CHANDIGARH-1, CHANDIGARH

In the result, all the above appeals filed by the respective assessee’s are dismissed

Bench: the Tribunal as pointed out by the Registry. Considering that the issue involved is purely legal in nature, and respectfully following the ratio laid down by the Hon'ble Supreme Court in Collector, Land Acquisition v. Mst. Katiji & Others [(1987) 167 ITR 471 (SC)], which emphasizes that substantial justice should prevail over technical considerations, we condone the delay in filing these appeals.3. We shall take appeal of the assessee in ITA No. 167/Chd/2023 for A.Y 2018-19 as a lead case f

disallowance. 5. On examination of assessment records, the Ld. Pr. CIT noticed that during the relevant year, the assessee had received an interest amounting to Rs. 1,05,10,592/- on enhanced compensation arising from the acquisition of land. The Assessing Officer had treated the said receipt as exempt and did not bring the same to tax. 6. According

MUNISH KUMAR LEGAL HEIR LATE SH GURDEEP SINGH,VILL MANAKPUR, YAMUNANAGAR vs. ITO, WARD 5, YAMUNANAGAR

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

disallowance. 5. On examination of assessment records, the Ld. Pr. CIT noticed that during the relevant year, the assessee had received an interest amounting to Rs. 1,05,10,592/- on enhanced compensation arising from the acquisition of land. The Assessing Officer had treated the said receipt as exempt and did not bring the same to tax. 6. According

ANIL TUTEJA,FATEHABAD vs. PR. COMMISSIONER OF INCOME TAX, ROHTAK, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

disallowance. 5. On examination of assessment records, the Ld. Pr. CIT noticed that during the relevant year, the assessee had received an interest amounting to Rs. 1,05,10,592/- on enhanced compensation arising from the acquisition of land. The Assessing Officer had treated the said receipt as exempt and did not bring the same to tax. 6. According

KARTAR SINGH, FATEHABAD vs. PR. COMMISSIONER OF INCOME TAX, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

disallowance. 5. On examination of assessment records, the Ld. Pr. CIT noticed that during the relevant year, the assessee had received an interest amounting to Rs. 1,05,10,592/- on enhanced compensation arising from the acquisition of land. The Assessing Officer had treated the said receipt as exempt and did not bring the same to tax. 6. According

SH. GURDEEP SINGH MAHAL,SIRSA vs. PR.CIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

disallowance. 5. On examination of assessment records, the Ld. Pr. CIT noticed that during the relevant year, the assessee had received an interest amounting to Rs. 1,05,10,592/- on enhanced compensation arising from the acquisition of land. The Assessing Officer had treated the said receipt as exempt and did not bring the same to tax. 6. According

SH. AMARJEET SINGH,SIRSA vs. PR.CIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

disallowance. 5. On examination of assessment records, the Ld. Pr. CIT noticed that during the relevant year, the assessee had received an interest amounting to Rs. 1,05,10,592/- on enhanced compensation arising from the acquisition of land. The Assessing Officer had treated the said receipt as exempt and did not bring the same to tax. 6. According