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 DIN DAYAL PURSOTAM LAL,SIRSA vs. PR.CIT, ROHTAK

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

3) of the Act is unsustainable. As in the cited case, here also, there is no evidence worth its name to incriminate the assessee and this conclusion has been arrived at only on premises and conjectures, rendering it unsustainable in the eye of law. ITA 146,147 & 148/CHD/2021 A.Y. 2011-12, 2015-16 & 2016-17 38 12. Then

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

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

3) of the Act is unsustainable. As in the cited case, here also, there is no evidence worth its name to incriminate the assessee and this conclusion has been arrived at only on premises and conjectures, rendering it unsustainable in the eye of law. ITA 146,147 & 148/CHD/2021 A.Y. 2011-12, 2015-16 & 2016-17 38 12. Then

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

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

3) of the Act is unsustainable. As in the cited case, here also, there is no evidence worth its name to incriminate the assessee and this conclusion has been arrived at only on premises and conjectures, rendering it unsustainable in the eye of law. ITA 146,147 & 148/CHD/2021 A.Y. 2011-12, 2015-16 & 2016-17 38 12. Then

J.K. EDUCATIONAL SOCIETY,JAMMU & KASHMIR vs. DCIT (EXEMPTION)-CIRCLE-1,, CHANDIGARH

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

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

section 164 of the IT Act, 1961 and the exemption u/s 11 cannot be denied and the whole of the excess income over expenditure of the trust cannot be added back and assessed as the income during the year under consideration. In this connection, attention was invited to assessment order in connection with AY 2014-15 where the so- called

J. K. EDUCATIONAL SOCIETY,JAMMU vs. DCIT, CIRCLE-1, CHANDIGARH

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

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

section 164 of the IT Act, 1961 and the exemption u/s 11 cannot be denied and the whole of the excess income over expenditure of the trust cannot be added back and assessed as the income during the year under consideration. In this connection, attention was invited to assessment order in connection with AY 2014-15 where the so- called

J.K.EDUCATIONAL SOCIETY,JAMMU vs. INCOME TAX OFFICER (EXEMPTION), CHANDIGARH

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

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

section 164 of the IT Act, 1961 and the exemption u/s 11 cannot be denied and the whole of the excess income over expenditure of the trust cannot be added back and assessed as the income during the year under consideration. In this connection, attention was invited to assessment order in connection with AY 2014-15 where the so- called

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)

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 14 A or Rule 8D does not depend on earning of income. 3

SJVN LIMITED,SHIMLA HIMACHAL PRADESH vs. ACIT , SHIMLA

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

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

disallowance of the same was made in the assessment order by the AO NaFAC. However, in the computation-of-income attached with the assessment order the deduction u/s 80IA was remained to be allowed inadvertently. Therefore, the contention of the assessee is accepted and mistake apparent from the records is being rectified as under. 6. On the issue raised

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)

disallowed the deduction without detailed scrutiny or hearing. 4. Against the order of the Ld. AO the assessee went in appeal before the Ld. CIT(A). 5. The Ld. CIT(A) dismissed the assessee’s appeal as time-barred due to the 3350-day delay in filing, as per the order issued under Section 250 of the 3 Income

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

THE CHAPLAH CO-OPERATIVE AGRICULTURAL SERVICE SOCIETY LTD,VPO CHOULI vs. LD. DCIT , CPC, CPC, BENGALURU

In the result, appeal of the Assessee is allowed

Bench: The Tribunal Against The Order Dt 25.04.2023 Of Ld. Commissioner Of Income Tax(Appeals), National Faceless Appeal Centre (Nfac), Delhi.

3 of section 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

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

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

AJAR AMAR STEELS 1725 10G, 3-A, FOCAL POINT LUDHIANA 141010,PUNJAB vs. THE PCIT (CENTRAL) LUDHIANA, PUNJAB

In the result, appeal of the assessee is allowed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 950/Chd/2024 "नधा"रण वष" / Assessment Year: 2017-18 Ajar Amar Steels, Vs The Pcit (Central), 1725 10G, 3-A, Focal Point, Ludhiana. Ludhiana. "थायी लेखा सं./Pan No: Aaefa8866A अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Sudhir Sehgal, Advocate Revenue By : Shri Vivek Vardhan, Addl. Cit Sr.Dr Date Of Hearing : 29.07.2025 Date Of Pronouncement : 29.09.2025 Physical Hearing O R D E R Per Raj Pal Yadav, Vp

disallowance of salary payment to Shri Sorav Jain, hence nothing left for the AO for adjudication. He has to executed the order of ld. CIT and only compute the income. When this aspect was faced by the assessee in ITA 399/CHD/2024 challenging the order of CIT (Appeals) against assessment order passed in pursuance of 263 order, then assessee withdrew that

THE DOL COOPERATIVE AGRICULTURAL SERVICE SOCIETY LIMITED,VPO AGHWANI vs. ITO DHARAM SHALA, DHARAMSHALA

In the result, the appeal of the Assessee stands allowed for statistical purposes

Bench: Shri A.D. Jain & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 163/Chd/2024 "नधा"रण वष" / Assessment Year : 2018-19 The Dol Cooperative Vs. The Ito, बनाम Dharamshala Agricultural Service Society Limited, Vpo Aghwani, Tehsil Jawalamukhi, Kangra Hp "थायी लेखा सं./Pan No: Aadat6246M अपीलाथ"/ Appellant ""यथ"/ Repsondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : Shri Sudhir Sehgal, Advocate राज"व क" ओर से/ Revenue By : Shri Vivek Vardhan, Jcit, Sr. Dr सुनवाई क" तार"ख/Date Of Hearing : 13.08.2024 उदघोषणा क" तार"ख/Date Of Pronouncement : 16.10.2024 आदेश/Order Per Krinwant Sahay, A.M.:

disallowing deduction under chapter Vl-A in respect of section 80P of the Income Tax Act 1961, as assessee is providing banking/credit 163-Chd-2024 – The Dol Cooperative Agricultural Service Society Pvt. Ltd, Distt.Kangra 7 facilities to its members and covered u/s sec 80P(2)(a)(l) without considering the facts of the case which is highly arbitrary, illegal, unwarranted

SHRI BALBIR SINGH VERMA,SHIMLA vs. PR.CIT, SHIMLA

In the result, appeal of the Assessee is allowed

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

3 Therefore, the AO disallowed the entire deduction claimed. An alternative claim made by the assessee under Section 36(1)(iii) was also rejected, as the assessee failed to provide sufficient evidence to prove that the loan was used for business purposes. Further, penalty proceedings under Section 271(1)(c) were initiated for furnishing inaccurate particulars of income. 3.4 Regarding

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

3 of section 249 of Income Tax Act, which provides\npowers to the 1d. Commissioner to condone the delay in filing\nthe appeal before the Commissioner. Similarly, it has been\nused in section 5 of Indian Limitation Act, 1963. Whenever\ninterpretation and construction of this expression has fallen\nfor consideration before Hon'ble High Court as well as before\nthe

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