ARYANS EDUCATIONAL AND CHARITABLE TRUST REGD, MOHALI,MOHALI vs. COMMISSIONER OF INCOME TAX, EXEMPTIONS, CHANDIGARH

In the result, appeal is allowed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 1136/Chd/2024 "नधा"रण वष" / Assessment Year: 2025-26 Aryans Educational & The Cit (Exemptions), Charitable Trust, Regd.Mohali Vs Chandigarh, C/O Shri Tej Mohan Singh, Advocate, # 527, Sector 10-D, Chandigarh. "थायी लेखा सं./Pan No: Aabta7550L अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Tej Mohan Singh, Advocate Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 07.08.2025 Date Of Pronouncement : 24.09.2025

4)(a). This means that any adversarial action u/s 12AA(3) of the Act against this assessee is a non-starter, ultra vires the self same Section 12AA(3) itself and void ab initio. In respect of the purported "one or more specified violations" that you have sought to identify as violative of Section

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/-under Section 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 14A or Rule 8D does not depend on earning of income; that the ld. CIT(A) has erred expressed in ignoring the legislative intent in the clarificatory explanation inserted

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

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

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.

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)

4. From the above noted reply and after examination of books of account, it has been emerged that the purchases made from the abovesaid party as recorded in the books of account are not proved for the reason that the abovesaid party is not in existence as discussed in detail in succeeding paras. It appears that the assessee has made

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

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

4. From the above noted reply and after examination of books of account, it has been emerged that the purchases made from the abovesaid party as recorded in the books of account are not proved for the reason that the abovesaid party is not in existence as discussed in detail in succeeding paras. It appears that the assessee has made

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

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

4. From the above noted reply and after examination of books of account, it has been emerged that the purchases made from the abovesaid party as recorded in the books of account are not proved for the reason that the abovesaid party is not in existence as discussed in detail in succeeding paras. It appears that the assessee has made

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 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

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)

249 on money borrowed from others. Out of this, the AO disallowed Rs.1,38,000 as an expense. This amount was calculated at 12% on Rs.11,50,000, which was a loan the assessee gave for office space. The AO said this disallowance was made because the assessee did not provide any proof that giving the loan was necessary

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

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 Hon'ble Supreme

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

4. In view of the above said facts and circumstances and evidences of the comparable cases, our submissions may, please be accepted and oblige. 6. From the above said facts, it is very clear that starting from the school at residential premises by Sh. G.S. Sardana and Smt. Usha Sardana and due to the far sightedness and planning of both

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

4. In view of the above said facts and circumstances and evidences of the comparable cases, our submissions may, please be accepted and oblige. 6. From the above said facts, it is very clear that starting from the school at residential premises by Sh. G.S. Sardana and Smt. Usha Sardana and due to the far sightedness and planning of both

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

4. In view of the above said facts and circumstances and evidences of the comparable cases, our submissions may, please be accepted and oblige. 6. From the above said facts, it is very clear that starting from the school at residential premises by Sh. G.S. Sardana and Smt. Usha Sardana and due to the far sightedness and planning of both

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

4. In view of the above said facts and circumstances and evidences of the comparable cases, our submissions may, please be accepted and oblige. 6. From the above said facts, it is very clear that starting from the school at residential premises by Sh. G.S. Sardana and Smt. Usha Sardana and due to the far sightedness and planning of both

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

4. In view of the above said facts and circumstances and evidences of the comparable cases, our submissions may, please be accepted and oblige. 6. From the above said facts, it is very clear that starting from the school at residential premises by Sh. G.S. Sardana and Smt. Usha Sardana and due to the far sightedness and planning of both