CEE ENN ESTATES PRIVATE LIMITED BAREWAL SUKHMANI ENCLAVE LUDHIANA,LUDHIANA vs. INCOME TAX OFFICER WARD 1(5) LUDHIANA RISHI NAGAR LUDHIANA, INCOME TAX OFFICER LUDHIANA RISHI NAGAR LUDHINA

In the result, appeal of the Assessee is allowed

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

disallowed, and the resultant interest under sections 234B and 234C was found to be statutorily correct. 7. Against the order

TYNOR ORTHOTICS PRIVATE LIMITED,MOHALI vs. ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE 6(1), MOHALI, MOHALI

In the result, appeal of the Assessee is partly allowed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. MANOJ KUMAR AGGARWAL (Accountant Member)

disallowances of Rs.85,00,000 excess salary and Rs.3,88,300/- software expenses. Penalty proceedings under Section 270A were initiated for under-reporting and misreporting of income, and interest was charged under Sections 234A, 234B

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

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

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, 234B

IILM EDUCATION TRUST,GURGAON vs. DCIT (EXEMPTIONS CIRCLE 2), CHANDIGARH

In the result, the appeal of the assessee is allowed for

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

disallowance of Rs.72,00,000 being rent paid by the appellant to Kulwant Rai Trust alleging the same to be in the nature of accommodation entry. 5.1 That the C1T(A) erred on facts and in law in not appreciating that the merely because the land underneath the leased building is owned by the settlor of the appellant-trust

MOHAMMAD MUSHTAQ,PANCHKULA vs. DCIT, CIRCLE, PANCHKULA

Bench: This Tribunal. The Assessee Is Aggrieved By The Order Bearing No. Itba/Nfac/S/250/2023-

disallowed the agricultural income of the assessee without any basis. The assessee had filed the detail of sale of flowers of Rs. 1,29,28,611.00 during the relevant assessment year and after deduction of expenses had earned agricultural Income of Rs.46,68,628.00. For the last 10 years the assessee is regularly showing his agricultural income from the same

M/S INTERNATIONAL CUSTOMER RELATED MANAGEMENT SERVICES PRIVATE LIMITED,CHANDIGARH vs. D.C.I.T., CIRCLE 6(1), MOHALI

In the result, for statistical purposes, the appeal is

Bench: SHRI A.D.JAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)

disallowing an amount of Rs.40,82,148, being interest on capital raised for business purpose, on the alleged ground that the same was not incurred wholly and exclusively for the purpose of business. 10. That the assessing officer erred on facts and in law in charging interest under section 234B

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)

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

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

NIKHIL BECTOR,SARABHA NAGAR LUDHIANA vs. DCIT, CIRLCE-1, LUDHIANA

In the result, appeal of the assessee is allowed

Bench: The Appeal Is Finally Heard & Disposed Off.

section 69A on account of cash deposited by the assessee out of cash in hand available ignoring the submissions made in respect of the said deposits. 3. That in any case the disallowance made is against the law and facts of the cases. 4. That the learned Assessing Officer has erred in charging interest u/s 234B

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

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)

section 40A(3) of Income Tax Act 1961 .Therefore, this amount of Rs 1,23,299/- is added back to the income of the assessee being unexplained cash credit since the same are not reflected in assessee's regular books of accounts on those relevant dates.. Since the above transaction also violated the provisions of section

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)

section 40A(3) of Income Tax Act 1961 .Therefore, this amount of Rs 1,23,299/- is added back to the income of the assessee being unexplained cash credit since the same are not reflected in assessee's regular books of accounts on those relevant dates.. Since the above transaction also violated the provisions of section