DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, LUDHIANA, LUDHIANA vs. MALBROS INTERNATIONAL PVT LTD, TEHSIL ZIRA, FARIDKOT -151203, LUDHIANA

The appeal of the assessee stand allowed whereas the revenue’s appeal stand dismissed accordingly

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.48/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2022-23) M/S Malbros International Pvt. Ltd. Dcit बनाम/ Village Mansoorwal Central Circle-2 Tehsil Zira Head Office Ludhiana Vs. Old Cantt Road, Faridkot – 151203 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aadcm-7203-R (अपीलाथ"/Appellant) (""थ" / Respondent) : & 2. आयकर अपील सं. / Ita No.463/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2022-23) Dcit M/S Malbros International Pvt. Ltd. बनाम/ Central Circle-2 Village Mansoorwal Ludhiana Tehsil Zira Head Office Vs. Old Cantt Road, Faridkot – 151203 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aadcm-7203-R (अपीलाथ"/Appellant) (""थ" / Respondent) : & 3. आयकर अपील सं. / Ita No.49/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2022-23) M/S Om Sons Marketing Pvt. Ltd. Dcit बनाम/ Quila Chowk, Old Cantt Road, Centre Circle-2 Vs. Faridkot, Punjab-151203 Ludhiana "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaaco-8962-E (अपीलाथ"/Appellant) : (""थ" / Respondent) & 4. आयकर अपील सं. / Ita No.193/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2022-23)

251(2) is illegal and deserves to be quashed. 4. a) That the Ld. CIT(A) has erred in confirming the addition of Rs.9,40,75,924/- u/s 69C on account of certain 'Tally data', which is not reliable and is unauthentic. b). That the Ld. CIT(A) has failed to appreciate that the authenticity of such data as recovered

MALBROS INTERNATIONAL PVT LTD, VILLAGE MANSOORWAL, TEHSIL ZIRA HEAD OFFICE, OLD CANTT ROAD, FARIDKOT,FARIDKOT vs. DCIT, CENTRAL CIRCLE-2, , LUDHIANA

The appeal of the assessee stand allowed whereas the revenue’s appeal stand dismissed accordingly

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.48/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2022-23) M/S Malbros International Pvt. Ltd. Dcit बनाम/ Village Mansoorwal Central Circle-2 Tehsil Zira Head Office Ludhiana Vs. Old Cantt Road, Faridkot – 151203 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aadcm-7203-R (अपीलाथ"/Appellant) (""थ" / Respondent) : & 2. आयकर अपील सं. / Ita No.463/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2022-23) Dcit M/S Malbros International Pvt. Ltd. बनाम/ Central Circle-2 Village Mansoorwal Ludhiana Tehsil Zira Head Office Vs. Old Cantt Road, Faridkot – 151203 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aadcm-7203-R (अपीलाथ"/Appellant) (""थ" / Respondent) : & 3. आयकर अपील सं. / Ita No.49/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2022-23) M/S Om Sons Marketing Pvt. Ltd. Dcit बनाम/ Quila Chowk, Old Cantt Road, Centre Circle-2 Vs. Faridkot, Punjab-151203 Ludhiana "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaaco-8962-E (अपीलाथ"/Appellant) : (""थ" / Respondent) & 4. आयकर अपील सं. / Ita No.193/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2022-23)

251(2) is illegal and deserves to be quashed. 4. a) That the Ld. CIT(A) has erred in confirming the addition of Rs.9,40,75,924/- u/s 69C on account of certain 'Tally data', which is not reliable and is unauthentic. b). That the Ld. CIT(A) has failed to appreciate that the authenticity of such data as recovered

OM SONS MARKETING PRIVATE LIMITED,FARIDKOT vs. DCIT, CENTRE CIRCLE-2, , LUDHIANA

The appeal of the assessee stand allowed whereas the revenue’s appeal stand dismissed accordingly

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.48/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2022-23) M/S Malbros International Pvt. Ltd. Dcit बनाम/ Village Mansoorwal Central Circle-2 Tehsil Zira Head Office Ludhiana Vs. Old Cantt Road, Faridkot – 151203 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aadcm-7203-R (अपीलाथ"/Appellant) (""थ" / Respondent) : & 2. आयकर अपील सं. / Ita No.463/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2022-23) Dcit M/S Malbros International Pvt. Ltd. बनाम/ Central Circle-2 Village Mansoorwal Ludhiana Tehsil Zira Head Office Vs. Old Cantt Road, Faridkot – 151203 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aadcm-7203-R (अपीलाथ"/Appellant) (""थ" / Respondent) : & 3. आयकर अपील सं. / Ita No.49/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2022-23) M/S Om Sons Marketing Pvt. Ltd. Dcit बनाम/ Quila Chowk, Old Cantt Road, Centre Circle-2 Vs. Faridkot, Punjab-151203 Ludhiana "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaaco-8962-E (अपीलाथ"/Appellant) : (""थ" / Respondent) & 4. आयकर अपील सं. / Ita No.193/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2022-23)

251(2) is illegal and deserves to be quashed. 4. a) That the Ld. CIT(A) has erred in confirming the addition of Rs.9,40,75,924/- u/s 69C on account of certain 'Tally data', which is not reliable and is unauthentic. b). That the Ld. CIT(A) has failed to appreciate that the authenticity of such data as recovered

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)

2. Mod Furniture, assessee has shown cash payment of Rs.18,000/- on 21.06.2006, Rs. 13,172/- on 24.06.2006, Rs. 16,032/- on 1.07.2006 and Rs. 6,610/- on 2.07.2006. On the other hand in regular books of account provided, during assessment proceedings, these cash payments are reflected on 15.03.2007, 14.03.2007, 2.02.2007 and on 6.02.2007 respectively. It means cash was paid

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)

2. Mod Furniture, assessee has shown cash payment of Rs.18,000/- on 21.06.2006, Rs. 13,172/- on 24.06.2006, Rs. 16,032/- on 1.07.2006 and Rs. 6,610/- on 2.07.2006. On the other hand in regular books of account provided, during assessment proceedings, these cash payments are reflected on 15.03.2007, 14.03.2007, 2.02.2007 and on 6.02.2007 respectively. It means cash was paid

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

disallowed by the AO have in fact been found to be actively engaged in rendering their respective services as is proved from the fact that during the course of survey on the assessee and the post survey enquiries, ail these parties have given their statements vis- a- vi s the salary being drawn by them from the Society

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

disallowed by the AO have in fact been found to be actively engaged in rendering their respective services as is proved from the fact that during the course of survey on the assessee and the post survey enquiries, ail these parties have given their statements vis- a- vi s the salary being drawn by them from the Society

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

disallowed by the AO have in fact been found to be actively engaged in rendering their respective services as is proved from the fact that during the course of survey on the assessee and the post survey enquiries, ail these parties have given their statements vis- a- vi s the salary being drawn by them from the Society

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

disallowed by the AO have in fact been found to be actively engaged in rendering their respective services as is proved from the fact that during the course of survey on the assessee and the post survey enquiries, ail these parties have given their statements vis- a- vi s the salary being drawn by them from the Society

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

disallowed by the AO have in fact been found to be actively engaged in rendering their respective services as is proved from the fact that during the course of survey on the assessee and the post survey enquiries, ail these parties have given their statements vis- a- vi s the salary being drawn by them from the Society

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

disallowed by the AO have in fact been found to be actively engaged in rendering their respective services as is proved from the fact that during the course of survey on the assessee and the post survey enquiries, ail these parties have given their statements vis- a- vi s the salary being drawn by them from the Society

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

disallowed by the AO have in fact been found to be actively engaged in rendering their respective services as is proved from the fact that during the course of survey on the assessee and the post survey enquiries, ail these parties have given their statements vis- a- vi s the salary being drawn by them from the Society

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

disallowed by the AO have in fact been found to be actively engaged in rendering their respective services as is proved from the fact that during the course of survey on the assessee and the post survey enquiries, ail these parties have given their statements vis- a- vi s the salary being drawn by them from the Society

SCOTT EDIL ADVANCE RESEARCH LABORATORIES AND EDUCATION LIMITED,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

251(1) regarding alleged understatement of investment in\nproperty at 28/6, Industrial Area, Phase-2, Chandigarh.\nIssue 5 : Directions by CIT(A) to AO to initiate 147/148 proceedings taking shelter of\ns.150(1)(2) for AY 2010-11 and 2012-13.\nIssue 6: Shortage of stock found during search held as undisclosed sale.\nIssue 7: Commission/profit earned at estimated rate

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-I, CHANDIGARH , CHANDIGARH vs. MS SCOTT EDIL ADVANCE RESEARCH LABORATOTRIES AND EDUCATION LTD., , CHANDIGARH

251(1) regarding alleged understatement of investment in\nproperty at 28/6, Industrial Area, Phase-2, Chandigarh.\nIssue 5 : Directions by CIT(A) to AO to initiate 147/148 proceedings taking shelter of\ns.150(1)(2) for AY 2010-11 and 2012-13.\nIssue 6: Shortage of stock found during search held as undisclosed sale.\nIssue 7: Commission/profit earned at estimated rate

SHRI BALRAM KRISHAN,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH, CHANDIGARH

251(1) regarding alleged understatement of investment in\nproperty at 28/6, Industrial Area, Phase-2, Chandigarh.\nIssue 5 : Directions by CIT(A) to AO to initiate 147/148 proceedings taking shelter of\ns.150(1)(2) for AY 2010-11 and 2012-13.\nIssue 6: Shortage of stock found during search held as undisclosed sale.\nIssue 7: Commission/profit earned at estimated rate

SCOTT EDIL ADVANCE RESEARCH LABORATORIES AND EDUCATION LIMITED,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

251(1) regarding alleged understatement of investment in\nproperty at 28/6, Industrial Area, Phase-2, Chandigarh.\nIssue 5 : Directions by CIT(A) to AO to initiate 147/148 proceedings taking shelter of\ns.150(1)(2) for AY 2010-11 and 2012-13.\nIssue 6: Shortage of stock found during search held as undisclosed sale.\nIssue 7: Commission/profit earned at estimated rate

SCOTT EDIL ADVANCE RESEARCH LABORATORIES AND EDUCATION LIMITED,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

251(1) regarding alleged understatement of investment in\nproperty at 28/6, Industrial Area, Phase-2, Chandigarh.\nIssue 5 : Directions by CIT(A) to AO to initiate 147/148 proceedings taking shelter of\ns.150(1)(2) for AY 2010-11 and 2012-13.\nIssue 6: Shortage of stock found during search held as undisclosed sale.\nIssue 7: Commission/profit earned at estimated rate