DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), CHANDIGARH vs. ESSIX BIOSCIENCES LIMITED, MANIMAJRA

In the result, the appeal is dismissed and the

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

2. "That the Ld. OT(A) is not justified in not upholding disallowance of Rs. 1,87,44,249/-u/s I4A of the Income Tax Act on the ground that disallowance cannot be made where there is no exempt income without appreciating the fact that applicability 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)

249) ITR 307 vii) Asprin Wall & Co. Ltd. Vs. CIT 2001 (251) ITR 323 viii) CIT Vs. Shri Mahesh Chnder Sharma 308 ITR 222 (2009) P&H ix) Computer Graphics case of Apex Court x) Gramphone Co. (India) ltd. Vs. Collector of Customs (2000) 1 SCC 549 xi) UOI Vs. DCM (1963) AIR 1963 SC 791 xii) Dy. Commissioner

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)

249) ITR 307 vii) Asprin Wall & Co. Ltd. Vs. CIT 2001 (251) ITR 323 viii) CIT Vs. Shri Mahesh Chnder Sharma 308 ITR 222 (2009) P&H ix) Computer Graphics case of Apex Court x) Gramphone Co. (India) ltd. Vs. Collector of Customs (2000) 1 SCC 549 xi) UOI Vs. DCM (1963) AIR 1963 SC 791 xii) Dy. Commissioner

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

disallowance was called for Your goodself would also appreciate that, though, initially in the Assessment order, the Assessing Officer has mentioned that a reasonable salary has to be considered to the related persons, but then while passing the order, he has added the entire salary, which is against the facts and circumstances of the case, though, both Sh. Sanjay Sardana

M/S MANAV MANGAL SOCIETY,CHANDIGARH vs. DCIT, C-1, (E), CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

disallowance was called for Your goodself would also appreciate that, though, initially in the Assessment order, the Assessing Officer has mentioned that a reasonable salary has to be considered to the related persons, but then while passing the order, he has added the entire salary, which is against the facts and circumstances of the case, though, both Sh. Sanjay Sardana

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

disallowance was called for Your goodself would also appreciate that, though, initially in the Assessment order, the Assessing Officer has mentioned that a reasonable salary has to be considered to the related persons, but then while passing the order, he has added the entire salary, which is against the facts and circumstances of the case, though, both Sh. Sanjay Sardana

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

disallowance was called for Your goodself would also appreciate that, though, initially in the Assessment order, the Assessing Officer has mentioned that a reasonable salary has to be considered to the related persons, but then while passing the order, he has added the entire salary, which is against the facts and circumstances of the case, though, both Sh. Sanjay Sardana

M/S MANAV MANGAL SOCIETY,CHANDIGARH vs. DCIT, C-1, (E), CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

disallowance was called for Your goodself would also appreciate that, though, initially in the Assessment order, the Assessing Officer has mentioned that a reasonable salary has to be considered to the related persons, but then while passing the order, he has added the entire salary, which is against the facts and circumstances of the case, though, both Sh. Sanjay Sardana

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

disallowance was called for Your goodself would also appreciate that, though, initially in the Assessment order, the Assessing Officer has mentioned that a reasonable salary has to be considered to the related persons, but then while passing the order, he has added the entire salary, which is against the facts and circumstances of the case, though, both Sh. Sanjay Sardana

DCIT,CIRCLE-1(EXEMPTION), CHANDIGARH vs. M/S MANAV MANGAL SCHOOL( MANAV MANGAL SOCIETY), CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

disallowance was called for Your goodself would also appreciate that, though, initially in the Assessment order, the Assessing Officer has mentioned that a reasonable salary has to be considered to the related persons, but then while passing the order, he has added the entire salary, which is against the facts and circumstances of the case, though, both Sh. Sanjay Sardana

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

disallowance was called for Your goodself would also appreciate that, though, initially in the Assessment order, the Assessing Officer has mentioned that a reasonable salary has to be considered to the related persons, but then while passing the order, he has added the entire salary, which is against the facts and circumstances of the case, though, both Sh. Sanjay Sardana

SHRI SATISH SOIN,LUDHIANA vs. ACIT, CC-II, LUDHIANA

In the result, appeal of the assessee is allowed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 303/Chd/2019 "नधा"रण वष" / Assessment Year : 2012-13 Shri Satish Soin, बनाम The Acit, House No.31, Garden Enclave, Central Circle-2, Vs South City-Ii, Ludhiana. Ludhiana. "थायी लेखा सं./Pan /Tan No: Advps6254N अपीलाथ"/Appellant ""यथ"/Respondent "नधा"रती क" ओर से/Assessee By : Shri Ashwani Kumar & Ms. Muskan Garg, Cas राज"व क" ओर से/ Revenue By : Smt. Kusum Bansal, Cit Dr तार"ख/Date Of Hearing : 26.05.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 23.07.2025 Hybrid Hearing आदेश/Order Per Rajpal Yadav, Vp

249 of Income Tax Act, which provides powers to the ld. Commissioner to condone the delay in filing the appeal before the Commissioner. Similarly, it has been used in section 5 of Indian Limitation Act, 1963. Whenever interpretation and construction of this expression has fallen for consideration before Hon’ble High Court as well as before the Hon’ble Supreme

M/S SWARAJ ENGINES LTD.,MOHALI vs. DCIT, C-6(1), MOHALI

In the result, the appeal of the assessee stands allowed

249/- (Accounts Officer) 10% Salary of Mr. M.S.Grewal 2,23,856/- (Company Secretary) Sub Total 6,01,105/- Add: 46.30% (% age of 2,78,311/- Administrative expenses to the salary) for Admn. Exp. Gross Total 8,79,416/- This disallowance has been depicted in clause 17(1) of the Tax Audit report and was also disallowed in the computation

THE KOTLA BHARI MILK PRODUCERS SOCIETY LTD.,KHANNA vs. ITO, KHANNA, KHANNA

In the result, appeal of the Assessee is dismissed

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

249(3) to condone the delay, citing the Supreme Court's ruling in Collector Land Acquisition vs. Mst. Katiji & Ors, which advocates a liberal approach to advance substantial justice. The Ld. AR further argued that the society, being a small cooperative engaged in milk supply, was entitled to a full deduction under Section 80P(2

M/S DIN DAYAL PURSOTAM LAL,SIRSA vs. PR.CIT, ROHTAK

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

2 to Section 263(1) of the Act, the assessment order was treated as erroneous and ITA 146,147 & 148/CHD/2021 A.Y. 2011-12, 2015-16 & 2016-17 32 prejudicial to the interests of the Revenue . The Tribunal quashed the revisional order and restored the order of the AO, following the Co-ordinate Bench decision in “Rajal Enterprises

M/S DIN DAYAL PURSOTAM LAL,SIRSA vs. PR.CIT, ROHTAK

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

2 to Section 263(1) of the Act, the assessment order was treated as erroneous and ITA 146,147 & 148/CHD/2021 A.Y. 2011-12, 2015-16 & 2016-17 32 prejudicial to the interests of the Revenue . The Tribunal quashed the revisional order and restored the order of the AO, following the Co-ordinate Bench decision in “Rajal Enterprises

M/S DIN DAYAL PURSOTAM LAL,SIRSA vs. PR.CIT, ROHTAK

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

2 to Section 263(1) of the Act, the assessment order was treated as erroneous and ITA 146,147 & 148/CHD/2021 A.Y. 2011-12, 2015-16 & 2016-17 32 prejudicial to the interests of the Revenue . The Tribunal quashed the revisional order and restored the order of the AO, following the Co-ordinate Bench decision in “Rajal Enterprises

A.B. SUGARS LIMITED,PUNJAB vs. PRINCIPAL COMMISSIONER OF INCOME TAX -1, CHANDIGARH, CHANDIGARH

In the result, the appeal of the assessee is allowed

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

249/- for deduction under section 80-IA(4)(iv) of the Act. The said adjustments have been rightly done by the assessee in consonance with the tax laws and there cannot be any two views in this regard and the AO has rightly allowed the same. As far as quantum of tax depreciation of Rs 43,16,890/- is concerned

A.B. SUGARS LIMITED,PUNJAB vs. PRINCIPAL COMMISSIONER OF INCOME TAX-1, CHANDIGARH

In the result, the appeal of the assessee is allowed

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

249/- for deduction under section 80-IA(4)(iv) of the Act. The said adjustments have been rightly done by the assessee in consonance with the tax laws and there cannot be any two views in this regard and the AO has rightly allowed the same. As far as quantum of tax depreciation of Rs 43,16,890/- is concerned