KHANNA INFRABUILD PRIVATE LIMITED ,LUDHIANA vs. THE DEPUTY COMMISSIONER OF INCOME TAX (CENTRAL CIRCLE)-2, LUDHIANA, LUDHIANA

In the result, the ground of appeal is allowed

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

5) The provisions of this section shall apply to the specified business referred to in sub-section (2) if it commences its operations." 23. It would also be apt, at this stage, to reiterate what the Ministry of Tourism, Government of India, has observed, in the opening lines (APB:253) of its "Guidelines for classification/re- classification of hotels", as under

KHANNA INFRABUILD PRIVATE LIMITED 2000-1A, SUKHDEV NAGAR FEROZEPUR ROAD, LUDHIANA,LUDHIANA vs. THE DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2 LUDHIANA, LUDHIANA

In the result, the ground of appeal is allowed

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

5) The provisions of this section shall apply to the specified business referred to in sub-section (2) if it commences its operations." 23. It would also be apt, at this stage, to reiterate what the Ministry of Tourism, Government of India, has observed, in the opening lines (APB:253) of its "Guidelines for classification/re- classification of hotels", as under

ITO, WARD, PALAMPUR vs. THE KANGRA CENTRAL COOPERATIVE BANK LIMITED, KANGRA

In the result, appeal of the Department is partly allowed for statistical purposes

Bench: Us Is Filed Under Section 253 Of The Income Tax Act, As Amended From Time To Time. The Respondent Is A Cooperative Bank.

253 of the Income Tax Act, as amended from time to time. The Respondent is a Cooperative Bank. 2. The Appellant Income Tax Department has raised following grounds of appeal in the Form No. 36. i) Whether on the facts and in the circumstances of the case and in law, the First Appellate Authority is justified in allowing the Appeal

DY. COMMISSIONER OF INCOME TAX, CIRCLE-4, LUDHIANA, AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

253 of the Income Tax Act, 1961 (hereinafter referred to as Act) before this Tribunal. The Revenue is aggrieved by the order bearing No. ITBA/NFAC/S/250/2023- 24/1056753913(i) dt. 04/10/2023 dt. 04/10/2023 of Ld. CIT(A) which is hereinafter referred to as the “impugned order” . The impugned order is passed in the first appellate proceedings

DCIT CIRCLE-4, LUDHIANA, LUDHIANA vs. ROCKMAN INDUSTRIES LTD, LUDHIANA

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

253 of the Income Tax Act, 1961 (hereinafter referred to as Act) before this Tribunal. The Revenue is aggrieved by the order bearing No. ITBA/NFAC/S/250/2023- 24/1056753913(i) dt. 04/10/2023 dt. 04/10/2023 of Ld. CIT(A) which is hereinafter referred to as the “impugned order” . The impugned order is passed in the first appellate proceedings

DY. COMMISSIONER OF INCOME TAX, CIRCLE-4, , AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

253 of the Income Tax Act, 1961 (hereinafter referred to as Act) before this Tribunal. The Revenue is aggrieved by the order bearing No. ITBA/NFAC/S/250/2023- 24/1056753913(i) dt. 04/10/2023 dt. 04/10/2023 of Ld. CIT(A) which is hereinafter referred to as the “impugned order” . The impugned order is passed in the first appellate proceedings

ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-4, AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

253 of the Income Tax Act, 1961 (hereinafter referred to as Act) before this Tribunal. The Revenue is aggrieved by the order bearing No. ITBA/NFAC/S/250/2023- 24/1056753913(i) dt. 04/10/2023 dt. 04/10/2023 of Ld. CIT(A) which is hereinafter referred to as the “impugned order” . The impugned order is passed in the first appellate proceedings

DY. COMMISSIONER OF INCOME TAX, CIRCLE-4,, AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

253 of the Income Tax Act, 1961 (hereinafter referred to as Act) before this Tribunal. The Revenue is aggrieved by the order bearing No. ITBA/NFAC/S/250/2023- 24/1056753913(i) dt. 04/10/2023 dt. 04/10/2023 of Ld. CIT(A) which is hereinafter referred to as the “impugned order” . The impugned order is passed in the first appellate proceedings

DY. COMMISSIONER OF INCOME TAX, CIRCLE-4, AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

253 of the Income Tax Act, 1961 (hereinafter referred to as Act) before this Tribunal. The Revenue is aggrieved by the order bearing No. ITBA/NFAC/S/250/2023- 24/1056753913(i) dt. 04/10/2023 dt. 04/10/2023 of Ld. CIT(A) which is hereinafter referred to as the “impugned order” . The impugned order is passed in the first appellate proceedings

DY. COMMISSIONER OF INCOME TAX, CIRCLE-4, LUDHIANA, - vs. ROCKMAN INDUSTRIES LTD, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

253 of the Income Tax Act, 1961 (hereinafter referred to as Act) before this Tribunal. The Revenue is aggrieved by the order bearing No. ITBA/NFAC/S/250/2023- 24/1056753913(i) dt. 04/10/2023 dt. 04/10/2023 of Ld. CIT(A) which is hereinafter referred to as the “impugned order” . The impugned order is passed in the first appellate proceedings

DY. COMMISSIONER OF INCOME TAX, AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, FOCAL POINT

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

253 of the Income Tax Act, 1961 (hereinafter referred to as Act) before this Tribunal. The Revenue is aggrieved by the order bearing No. ITBA/NFAC/S/250/2023- 24/1056753913(i) dt. 04/10/2023 dt. 04/10/2023 of Ld. CIT(A) which is hereinafter referred to as the “impugned order” . The impugned order is passed in the first appellate proceedings

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.

253 contemplates that the Tribunal may admit an appeal or permit filing of memorandum of cross- 47-Chd-2024 – The Chaplah Co-operative Agriculture Service Society ltd, Distt. Kangra 3 objections after expiry of relevant period, if it is satisfied that there was a sufficient cause for not presenting it within that period. This expression sufficient cause employed

DCIT, C-1(1) , CHANDIGARH vs. M/S FIDELITY INFORMATION SERVICES INDIA PVT. LTD., CHANDIGARH

In the result, the cross-objection filed by the assessee is dismissed

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

5. 2010-11 2,41,27,534/- New Service DRP allowed the claim of The appeal is pending agreement dated foreign travelling disposal before the May 12, 2007 with expenditure in favour of Hon’ble Chandigarh Fidelity the Respondent by Bench of Tribunal Next Information directing the AO to allow listed for hearing on Services Inc. USA the claim after

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

253 contemplates that the Tribunal may admit an appeal or permit filing of memorandum of cross- objections after expiry of relevant period, if it is satisfied that there was a sufficient cause for not presenting it within that period. This expression sufficient cause employed in the section has also been used identically in sub-section 3 of section

PUNJAB STATE COOP. BANK LTD.,CHANDIGARH vs. ACIT, CL-2(1), CHANDIGARH

In the result the impugned order of Ld

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

253 of the Income Tax Act, 1961 as and by way of second appeal under the Act. The assessee is aggrieved by order No. ITBA/NFAC/250/2022-23/1050740589(1) dt. 14/03/2023 of the Ld. CIT(A) passed under section 250 of the Income Tax Act, which is hereinafter referred to as the “impugned order”. FACTUAL MATRIX 2. The assessee is a cooperative society

ACIT, CIRCLE, PANCHKULA vs. M/S HARYANA STATE INDUSTRIAL & INFRASTRUCTURE DEV. CORP. LTD., PANCHKULA

In the result, appeal of the Revenue is dismissed

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

5 a) Whether on the facts and in the circumstances of the case, the Commissioner of Income Tax (Appeals) is right in law in deleting the disallowance under Section 36(l)(iii) of the Income Tax Act, 1961 on account of interest related to diversion of funds for non business purposes by holding the issue as covered in view

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

253 contemplates that the Tribunal may admit an appeal or permit filing of memorandum of cross- objections after expiry of relevant period, if it is satisfied that there was a sufficient cause for not presenting ITA No.992 & 993/CHD/2024 & CO 46 & 45/CHD/2024 A.Y.2017-18 & 2016-17 3 it within that period. This expression sufficient cause employed in the section has also been

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

253 contemplates that the\nTribunal may admit an appeal or permit filing of memorandum\nof cross- objections after expiry of relevant period, if it is\nsatisfied that there was a sufficient cause for not presenting\nit within that period. This expression sufficient cause\nemployed in the section has also been used identically in sub-\nsection 3 of section

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