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)

disallowed the entire purchase amount of Rs. 4,11,60,437/- as bogus, concluding that the assessee failed to establish the genuineness of these transactions. Consequently, the AO added Rs. 4,75,44,959/- (Rs. 63,84,522/- + Rs. 4,11,60,437/-) to the assessee’s total income, determining it at Rs. 4,73,64,687/- under normal provisions

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)

disallowed the entire purchase amount of Rs. 4,11,60,437/- as bogus, concluding that the assessee failed to establish the genuineness of these transactions. Consequently, the AO added Rs. 4,75,44,959/- (Rs. 63,84,522/- + Rs. 4,11,60,437/-) to the assessee’s total income, determining it at Rs. 4,73,64,687/- under normal provisions

TIRUPATI ENGINEERS AND CONTRUCTIONS,SANGRUR vs. ITO, SANGRUR

In the result, the appeal is allowed for statistical purposes

Bench: the Ld. CIT(A). The Ld. CIT(A) submitted that during appellate proceedings, several notices under Section 250 were issued but the assessee failed to file any written submissions or attend hearings. Considering repeated non-compliance, the CIT(A) held that the assessee was not interested in prosecuting the appeal. Relying on judicial precedents, it was observed that an appeal requires active prosecution and mere filing is insufficient. As the assessee provided no evidence or arguments in sup

disallowed partners’ salary and interest due to absence of a certified copy of the partnership deed. Interest under sections 234A

INCOME TAX OFFICER, WARD-2(1), CHANDIGARH, CHANDIGARH vs. ATMA RAM JEWELLERS, CHANDIGARH

In the result, appeal of the Revenue is dismissed

section 234A, B and C amounting to Rs.24,51,682/- is arbitrary\nunjustified and in the alternative is highly excessive.\n6.1 Charging interest u/s 234A, 234B and 234C is mandatory and\nconsequential in view of Hon'ble Supreme Court decision in the case of Anjum\nM.H. Ghaswala - 252 (2001) ITR 1 (SC). Since ground no 2 to 9 of appeal

SHRI RAJIV GUPTA,SIRSA vs. ITO-WARD-2, SIRSA

Bench: The Bench That The Lead

234A of the Act and interest of Rs. 3,97,221/- u/s 234B of the Act which are not leviable on the facts of the instant case. Prayer : It is therefore, prayed that, it be held that addition made and sustained by the learned Commissioner of Income Tax (Appeals) be deleted and appeal of the appellant be allowed. 4. Addressing

EXOTIC REALTORS AND DEVELOPERS,CHANDIGARH vs. PR.CIT-1, CHANDIGARH

In the result, appeal of the assessee is allowed

Bench: SHRI. KRINWANT SAHAY (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

234A, 234B & 234C of the Income Tax Act, as applicable. The calculation sheet is enclosed as the part of the assessment order. 13.2 Basis above assessment order dt. 24/03/2023 under section 147 r.w.s 144 read with Section 144B of the Income Tax Act, the Ld. AR vehemently contended that assessee has gone through the rigours of the proceedings under section

M/S BEBO TECHNOLOGIES PVT. LTD.,MOHALI vs. DCIT, C-6(1), MOHALI

In the result, the appeal of the assessee is treated as allowed for statistical purposes

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumarassessment Year : 2011-12

234A and 234B of the Act which is not chargeable in the facts of the case. 3. Ground No. 1 & 2 are in relation to the disallowance made u/s 14A of the Income-tax Act, 1961 (in short 'the Act'). The Assessing officer during the assessment proceedings found that the assessee had during the year earned tax exempt income

ASHOK KUMAR & CO. MERCANTILE PVT. LTD.,LUDHIANA vs. ACIT, C-VII, LUDHIANA

In the result, appeal of the assessee is allowed for

Bench: The Due Date Of Filing Of Return I.E. On 29.11.2014. Hence, No Interest U/S 234A Can Be Levied. Iv) That The Appellant Craves To Amend, Alter, Change Any Of The Ground(S) Of Appeal. 3. A Perusal Of The Grounds Of Appeal Shows That The Main Grievance Of The Assessee Is Against The Confirmation Of Disallowance Of Interest Amounting To Rs. 7,01,500/-. The

234A can be levied. iv) That the appellant craves to amend, alter, change any of the ground(s) of appeal. 3. A perusal of the grounds of appeal shows that the main grievance of the assessee is against the confirmation of disallowance of interest amounting to Rs. 7,01,500/-. The ITA-1003/CHD/2018 Page 2 of 3 AO during

KATIANI EDUCATION SOCIETY,KULLU vs. DCIT, MANDI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Sanjay Garg & Ms. Annapurna Gupta

sections 11 to 13 of the Act, however, it was incumbent upon the Assessing officer to examine the nature of the receipts. The Ld. Counsel has submitted that the assessee’s claim is that the said receipts were capital in nature and further that even if the same are to be treated as a Revenue receipts, the assessee would

KATIANI EDUCATION SOCIETY,KULLU vs. DCIT, MANDI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Sanjay Garg & Ms. Annapurna Gupta

sections 11 to 13 of the Act, however, it was incumbent upon the Assessing officer to examine the nature of the receipts. The Ld. Counsel has submitted that the assessee’s claim is that the said receipts were capital in nature and further that even if the same are to be treated as a Revenue receipts, the assessee would

SHOBHA SHARMA,SIRSA vs. ITO-WARD-3, SIRSA

In the result, appeal of the assessee is allowed

section 139(4) and the return was submitted after issuing of notice u/s 148 on 16.10.2018" and therefore appellant is not entitled to claim of deduction u/s 54F of the Act is misconceived and wholly untenable. 2.2 That the learned Commissioner of Income Tax (Appeals) has failed to appreciate that once the investment in residential house was not disputed then

FIDELITY INFORMATION SERVICES INDIA PRIVATE LIMITED,PUNJAB vs. DEPUTY COMMISSIONER OF INCOME TAX, CHANDIGARH

In the result, the appeal of the Revenue is dismissed

Bench: Shri Rajpal Yadavand\Nshri Krinwant Sahay\Nआयकर अपील सं./ Ita No. 998/Chd/2024\Nनिर्धारण वर्ष / Assessment Year: 2020-21\Nfidelity Information Services\Nvs\Nthe Dcit,\Nchandigarh,\Nindia Private Ltd., 2Nd A-45,\Nindustrial Area, Sector 74,\Nphase 8B, Sas Nagar.\Nस्थायी लेखा सं./Pan No: Aagcs0395D\Nअपीलार्थी/Appellant\Nप्रत्यर्थी/Respondent\Nassessee By:\Nshri Vishal Kalra, Advocate & Ms. Sumisha, Ca\Nrevenue By :\Nshri Manav Bansal, Cit Dr\Ndate Of Hearing\N: 06.05.2025\Ndate Of Pronouncement\N: 28.05.2025\Nhybrid Hearing\Norder\Nper Raj Pal Yadav, Vp\Nthe Assessee Is In Appeal Before The Tribunal Against\Nthe Assessment Order Dated 31.07.2024 Passed U/S 143(3)\Nread With Section 144C(13)/144B Of The Income Tax Act In\N Assessment Year 2020-21.\N2. The Assessee Has Taken Four Grounds Alongwith Six Sub-\Ngrounds In Ground No.

Section 144C(13)/144B of the Income Tax Act in\n assessment year 2020-21.\n2. The assessee has taken four grounds alongwith six sub-\ngrounds in Ground No. 2. Ground No.1 is a general ground\nwhich does not call for recording of any finding. Hence\nrejected.\n3. In Ground No.3 assessee has pleaded that ld. AO has\nerred

M/S H.P.STATE FOREST COPRN. LTD.,SHIMLA vs. JCIT, S.R., SHIMLA

In the result, the present appeal of Appellant/Assessee is allowed and impugned order of Ld

Bench: Shri Vikram Singh Yadav& Shri Paresh M. Joshiआयकरअपीलसं./Ita Nos.280& 281/Chd/2000 िनधा"रणवष" / Assessment Years : 1990-91& 1991-92 M/S H.P. State Forest Corp. Ltd. Vs The Jcit, Van Nigam Kasumpti Shimla Shimla "ायीलेखासं./Pan No: Aaach4036L अपीलाथ"/Appellant ""यथ"/Respondent िनधा"रतीक"ओरसे/Assessee By: Shri Y.K. Sud, Ca राज"वक"ओरसे/ Revenue By : Sh.Sarabjeet Singh, Cit-Dr सुनवाईक"तारीख/Date Of Hearing : 28.05.2024 उदघोषणाक"तारीख/Date Of Pronouncement : 06.06.2024 Hybridhearing आदेश/Order Per Paresh M. Joshi, Jm: Both The Above Appeals Have Been Filed By The Assessee. Since The Issues Involved In Both The Above Appeals Are Common & Were Heard Together Therefore They Are Being Disposed Off By This Consolidated Order For The Sake Of Brevity. We Shall Take Appeal Of The Assessee In Ita No. 280/Chd/2000 As A Lead Case.

section 143(2) and 142(1) were issued to the Assessee from time to time and ultimately the Assessment was completed u/s 144 of the IT Act, 1961 on 31/03/1994 at the Returned income of Rs.92,52,000/- for the reasons given in the Assessment Order. The assessment framed by the Assessing Officer was confirmed by CIT(A), Shimla vide

M/S H.P.STATE FOREST COPRN. LTD.,SHIMLA vs. JCIT, S.R., SHIMLA

In the result, the present appeal of Appellant/Assessee is allowed and impugned order of Ld

Bench: Shri Vikram Singh Yadav& Shri Paresh M. Joshiआयकरअपीलसं./Ita Nos.280& 281/Chd/2000 िनधा"रणवष" / Assessment Years : 1990-91& 1991-92 M/S H.P. State Forest Corp. Ltd. Vs The Jcit, Van Nigam Kasumpti Shimla Shimla "ायीलेखासं./Pan No: Aaach4036L अपीलाथ"/Appellant ""यथ"/Respondent िनधा"रतीक"ओरसे/Assessee By: Shri Y.K. Sud, Ca राज"वक"ओरसे/ Revenue By : Sh.Sarabjeet Singh, Cit-Dr सुनवाईक"तारीख/Date Of Hearing : 28.05.2024 उदघोषणाक"तारीख/Date Of Pronouncement : 06.06.2024 Hybridhearing आदेश/Order Per Paresh M. Joshi, Jm: Both The Above Appeals Have Been Filed By The Assessee. Since The Issues Involved In Both The Above Appeals Are Common & Were Heard Together Therefore They Are Being Disposed Off By This Consolidated Order For The Sake Of Brevity. We Shall Take Appeal Of The Assessee In Ita No. 280/Chd/2000 As A Lead Case.

section 143(2) and 142(1) were issued to the Assessee from time to time and ultimately the Assessment was completed u/s 144 of the IT Act, 1961 on 31/03/1994 at the Returned income of Rs.92,52,000/- for the reasons given in the Assessment Order. The assessment framed by the Assessing Officer was confirmed by CIT(A), Shimla vide

M/S HOTEL OAK VALLEY RESIDENCY,CHAMBA vs. ITO, BANIKHET

In the result this appeal of the assessee stands partly allowed

Bench: Shri N.K. Saini & Shri Sanjay Gargआयकरअपीलसं./Ita No. 772/Chd/2012 "नधा"रण वष" / Assessment Year : 2007-08

234A and 234B without appreciating our written submissions made in this regard. 10. That the appellant craves to add, to amend, to delete, to withdraw, to modify any of the grounds of appeal at the time of hearing or during hearing period. 11. That the order passed by CIT(A) is illegal, bad in law and contrary to the/ provisions

M/S OAK VALLEY RESIDENCY,DALHOUSIE vs. ITO, BANIKHET

In the result this appeal of the assessee stands partly allowed

Bench: Shri N.K. Saini & Shri Sanjay Gargआयकरअपीलसं./Ita No. 772/Chd/2012 "नधा"रण वष" / Assessment Year : 2007-08

234A and 234B without appreciating our written submissions made in this regard. 10. That the appellant craves to add, to amend, to delete, to withdraw, to modify any of the grounds of appeal at the time of hearing or during hearing period. 11. That the order passed by CIT(A) is illegal, bad in law and contrary to the/ provisions

M/S OAK VALLEY RESIDENCY,DALHOUISE vs. ITO, DALHOUSIE AT, BANIKHET

In the result this appeal of the assessee stands partly allowed

Bench: Shri N.K. Saini & Shri Sanjay Gargआयकरअपीलसं./Ita No. 772/Chd/2012 "नधा"रण वष" / Assessment Year : 2007-08

234A and 234B without appreciating our written submissions made in this regard. 10. That the appellant craves to add, to amend, to delete, to withdraw, to modify any of the grounds of appeal at the time of hearing or during hearing period. 11. That the order passed by CIT(A) is illegal, bad in law and contrary to the/ provisions