M/S SJVN LTD. ( FORMERLY SATLUJ JAL VIDYUT NIGAM LIMITED),SHIMLA vs. DCIT, CIRCLE, SHIMLA

disallowance under Explanation 2 to Section 37(1) comes into play, but, as for latter, there is no such disabling provision as long as the expenses, even in discharge of corporate social responsibility on voluntary basis, can be said to be "wholly and exclusively for the purposes of business". There is no dispute that the expenses in question

M/S SJVN LTD. ( FORMERLY SATLUJ JAL VIDYUT NIGAM LIMITED),SHIMLA vs. DCIT, CIRCLE, SHIMLA

disallowance under Explanation 2 to Section 37(1) comes into play, but, as for latter, there is no such disabling provision as long as the expenses, even in discharge of corporate social responsibility on voluntary basis, can be said to be "wholly and exclusively for the purposes of business". There is no dispute that the expenses in question

ACIT, CIRCLE, SHIMLA vs. M/S SATLUJ JAL VIDYUT NIGAM LIMITED, SHIMLA

disallowance under Explanation 2 to Section 37(1) comes into play, but, as for latter, there is no such disabling provision as long as the expenses, even in discharge of corporate social responsibility on voluntary basis, can be said to be "wholly and exclusively for the purposes of business". There is no dispute that the expenses in question

PREM SINGH,CHAMBA vs. ACIT CIRCLE PALAMPUR, PALAMPUR

In the result, the appeal for AY 2017-18 stands partly allowed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No. 946/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2015-16) & 2. आयकर अपील सं. / Ita No. 947/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2017-18) Shri Prem Singh Dcit Circle, Palampur बनाम/ The Palace. Chamba Himachal Pradesh - 176061 Vs. Himachal Pradesh – 176310 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aampr-8876-P (अपीलाथ"/Appellant) : (""थ" / Respondent) Assessee By : Shri Ajay Jain (Ca) – Ld. Ar Revenue By : Shri Bharat Bhushan Garg (Cit) (Virtual) - Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 13-11-2025 घोषणाकीतारीख /Date Of Pronouncement : 13-01-2026 आदेश / O R D E R Manoj Kumar Aggarwal () 1. The Assessee Is In Further Appeals Before Us For Assessment Years (Ay) 2015-16 & 2017-18 Which Arises Out Of Separate Orders Of Learned First Appellate Authority. First, We Take Up Appeal For Assessment Year (Ay) 2015-16 Which Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), Nfac [Cit(A)] Dated 22-07-2025 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S 143(3) Of The Act On 29-12-2017. The Assessee Is Aggrieved By Computation Of Capital

section 54 since the assessee did not attend and comply with the show case notice issued by the AO on 26/12 for 28/12. 6. On the facts and in the circumstances of the case and in law the assessing officer was incorrect and unjustified in rejecting the claim of the assessee for exemption of long term capital gain without providing

M/S GANESH DASS HUF,SIRSA vs. PCIT, 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)

244A of the Act. (33-34) vii) Proposal sent by ITO, Sirsa to initiate proceedings u/s 263 of the Act. (Page 465-466 of JPB) viii) 16.01.2023 Unsigned notice issued for hearing u/s 263 of the Act from the office of Principal of Commissioner of Income Tax, Rohtak. (35-36) ix) 25.01.2023 Reply filed by appellant in response to notice

SH. ARVAIL SINGH,SIRSA vs. PCIT, 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)

244A of the Act. (33-34) vii) Proposal sent by ITO, Sirsa to initiate proceedings u/s 263 of the Act. (Page 465-466 of JPB) viii) 16.01.2023 Unsigned notice issued for hearing u/s 263 of the Act from the office of Principal of Commissioner of Income Tax, Rohtak. (35-36) ix) 25.01.2023 Reply filed by appellant in response to notice

SH. RANDHIR SINGH,SIRSA vs. PCIT ROHTAK, 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)

244A of the Act. (33-34) vii) Proposal sent by ITO, Sirsa to initiate proceedings u/s 263 of the Act. (Page 465-466 of JPB) viii) 16.01.2023 Unsigned notice issued for hearing u/s 263 of the Act from the office of Principal of Commissioner of Income Tax, Rohtak. (35-36) ix) 25.01.2023 Reply filed by appellant in response to notice

DHUNI CHAND HUF,SIRSA vs. PCIT, 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)

244A of the Act. (33-34) vii) Proposal sent by ITO, Sirsa to initiate proceedings u/s 263 of the Act. (Page 465-466 of JPB) viii) 16.01.2023 Unsigned notice issued for hearing u/s 263 of the Act from the office of Principal of Commissioner of Income Tax, Rohtak. (35-36) ix) 25.01.2023 Reply filed by appellant in response to notice

SH. PARAMJEET SINGH,SIRSA vs. PCIT, 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)

244A of the Act. (33-34) vii) Proposal sent by ITO, Sirsa to initiate proceedings u/s 263 of the Act. (Page 465-466 of JPB) viii) 16.01.2023 Unsigned notice issued for hearing u/s 263 of the Act from the office of Principal of Commissioner of Income Tax, Rohtak. (35-36) ix) 25.01.2023 Reply filed by appellant in response to notice

SH. KASHMIR SINGH SANDHA,SIRSA vs. PCIT, 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)

244A of the Act. (33-34) vii) Proposal sent by ITO, Sirsa to initiate proceedings u/s 263 of the Act. (Page 465-466 of JPB) viii) 16.01.2023 Unsigned notice issued for hearing u/s 263 of the Act from the office of Principal of Commissioner of Income Tax, Rohtak. (35-36) ix) 25.01.2023 Reply filed by appellant in response to notice

SURJEET SINGH,SIRSA vs. PCIT, ROHTAK, 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)

244A of the Act. (33-34) vii) Proposal sent by ITO, Sirsa to initiate proceedings u/s 263 of the Act. (Page 465-466 of JPB) viii) 16.01.2023 Unsigned notice issued for hearing u/s 263 of the Act from the office of Principal of Commissioner of Income Tax, Rohtak. (35-36) ix) 25.01.2023 Reply filed by appellant in response to notice