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)

disallowance under Section 36(l)(iii) of t h e Income Tax Act, 1961 is squarely covered in view of decision of the Hon'ble Supreme Court in the case of Commissioner of Income Tax Vs. Reliance Industries Limited, reported as [2019] 410 ITR 466 (SC) wherein the issue has been held to be a pure question of fact

M/S HERO CYCLES LTD.,LUDHIANA vs. ACIT, C-V, LUDHIANA

In the result, appeal of the Department is dismissed and the\nappeal of the assessee is allowed

section 36(1)(iii) of\nthe Act by following the earlier order of the ITAT in ITA Nos.\n758/Chd/2014 forthe A.Y. 2010-11 dt. 03/04/2017. The relevant findings\ngiven by the Ld. CIT (A) in para 7.2 of the impugned order read as\nunder:\n7.2 I have considered the observations of the Assessing Officer as made by him\nin para

RAMJEE CONCRETES PVT.LTD.,MOHALI vs. ITO-WARD-6(3), CHANDIGARH

The appeals are disposed of in the aforesaid terms

Bench: Shri N.K. Saini & Shri Sudhanshu Srivastavaआयकर अपील सं./ Ita No. 205/Chd/2021 "नधा"रण वष" / Assessment Year : 2019-20 Ramjee Concretes Private Limited, The Ito, बनाम #1238.Sector 91, Ward 6(3), Mohali, Punjab Chandigarh "थायी लेखा सं./Pan No: Aafcr9457E अपीलाथ"/Appellant ""यथ"/Respondent

disallowable expenditure under Section 40(a)(ii) of the IT Act. Ms. Linhares was unable to state whether the Revenue has appealed this decision. Mr. Ramani, learned Senior Advocate submitted that his research did not suggest that any appeal was instituted by the Revenue against this decision, which is directly on the point and favours the Assessee. 31. Mr. Ramani

IND SWIFT LABORATORIES LTD.,CHANDIGARH vs. DCIT, CIRCLE 1(1), CHANDIGARH

In the result, the appeal is allowed, as indicated

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

disallowed the claim to the extent of Rs.16,39,010/-. Commissioner set aside the order of the AO, holding that the interest paid by the assessee, of which, deduction was claimed, on the facts of the case, was for business purposes and, therefore, the entire interest paid by the assessee should have been allowed as business expenditure. 37.2. The Honorable

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)

254 dt. 05/03/2018 was issued and served upon the assessee on 06/03/2018. 2.5 A notice under section 142(1) dt. 19/11/2018 alongwith detailed questionnaire was issued and served upon the assessee on 20.11.2018. 2.6 We reproduce below Para 7 and 13 of order of this Tribunal (supra) “ 7. We have considered the rival contentions and have also gone through

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)

254 dt. 05/03/2018 was issued and served upon the assessee on 06/03/2018. 2.5 A notice under section 142(1) dt. 19/11/2018 alongwith detailed questionnaire was issued and served upon the assessee on 20.11.2018. 2.6 We reproduce below Para 7 and 13 of order of this Tribunal (supra) “ 7. We have considered the rival contentions and have also gone through

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)

254 dt. 05/03/2018 was issued and served upon the assessee on 06/03/2018. 2.5 A notice under section 142(1) dt. 19/11/2018 alongwith detailed questionnaire was issued and served upon the assessee on 20.11.2018. 2.6 We reproduce below Para 7 and 13 of order of this Tribunal (supra) “ 7. We have considered the rival contentions and have also gone through

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)

254 dt. 05/03/2018 was issued and served upon the assessee on 06/03/2018. 2.5 A notice under section 142(1) dt. 19/11/2018 alongwith detailed questionnaire was issued and served upon the assessee on 20.11.2018. 2.6 We reproduce below Para 7 and 13 of order of this Tribunal (supra) “ 7. We have considered the rival contentions and have also gone through

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)

254 dt. 05/03/2018 was issued and served upon the assessee on 06/03/2018. 2.5 A notice under section 142(1) dt. 19/11/2018 alongwith detailed questionnaire was issued and served upon the assessee on 20.11.2018. 2.6 We reproduce below Para 7 and 13 of order of this Tribunal (supra) “ 7. We have considered the rival contentions and have also gone through

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)

254 dt. 05/03/2018 was issued and served upon the assessee on 06/03/2018. 2.5 A notice under section 142(1) dt. 19/11/2018 alongwith detailed questionnaire was issued and served upon the assessee on 20.11.2018. 2.6 We reproduce below Para 7 and 13 of order of this Tribunal (supra) “ 7. We have considered the rival contentions and have also gone through

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)

254 dt. 05/03/2018 was issued and served upon the assessee on 06/03/2018. 2.5 A notice under section 142(1) dt. 19/11/2018 alongwith detailed questionnaire was issued and served upon the assessee on 20.11.2018. 2.6 We reproduce below Para 7 and 13 of order of this Tribunal (supra) “ 7. We have considered the rival contentions and have also gone through

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)

254 dt. 05/03/2018 was issued and served upon the assessee on 06/03/2018. 2.5 A notice under section 142(1) dt. 19/11/2018 alongwith detailed questionnaire was issued and served upon the assessee on 20.11.2018. 2.6 We reproduce below Para 7 and 13 of order of this Tribunal (supra) “ 7. We have considered the rival contentions and have also gone through

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)

disallowed the foreign travel expenses which clearly form part of the operating expenses and the cost base and on which the assessee has reported the revenues after considering the mark up of 16.60%. Such an action on part of the AO is clearly in breach of letter and spirit of the APA which has been entered into by CBDT

ACIT, C-4(1), CHANDIGARH vs. M/S GLAXOSMITHKLINE CONSUMER HEALTHCARE LTD., GURGAON

The appeal stands dismissed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No.1355/Chandi/2018 (िनधा"रण वष" / Assessment Year: 1997-98) Dcit-1(1)(1) M/S Hindustan Unilever Ltd. R.N.579A, 5Th Floor (Legal Successor Of M/S Glaxosmithkline बनाम/ Aaykar Bhawan Consumer Healthcare Ltd.) Vs. Mumbai – 400020 Unilever House, B.D. Swant Marg, Chakala Andheri (East), Mumbai – 400 099 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaach-1004-N (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Rohit Jain (Advocate) & Ms. Somya Jain, Ca – Ld. Ars ""थ"कीओरसे/Respondent By : Shri Rohit Sharma (Cit) A/W Sh. Vivek Vardhan (Addl. Cit) – Ld. Drs सुनवाईकीतारीख/Date Of Hearing : 27-06-2025 घोषणाकीतारीख /Date Of Pronouncement : 18-08-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Revenue For Assessment Year (Ay) 1997-98 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals)-2, Chandigarh Dated 02-08-2018 In The Matter Of An Assessment Framed By Ld. Assessing Officer (Ao) U/S 143(3) R.W.S. 254 Of The Act On 31-03-2017. The Revenue Has Filed Revised Form No.36 On 10-09-2024 Which Is On Record. The Grounds Of Appeal Read As Under: -

254 of the Act on 31-03-2017. In regular assessment framed u/s 143(3), Ld. AO made disallowance of Rs.11.94 Crores u/s 43B. The matter was set aside by Tribunal vide ITA No.475/Chd/2002 dated 05-04-2016. In consequential assessment, Ld. AO restricted the addition to the extent of Rs.6.19 Crores and revised the demand against the assessee

M/S STYLAM INDUSTRIES LTD.,CHANDIGARH vs. DCIT, C-1(1), CHANDIGARH

In the result, the Department’s appeal in for assessment year

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

disallowance was called for. For A.Y. 2014-15 also, the addition was deleted, though this time by the CIT(A), following the Tribunal Order (supra)for A.Y. 2012-13. The facts remain the same for A.Y. 2013-14 as well. The AO is, accordingly, directed to ascertain the position of availability of the funds of the assessee exceeding the advances

M/S STYLAM INDUSTRIES LTD.,CHANDIGARH vs. DCIT, C-1(1), CHANDIGARH

In the result, the Department’s appeal in for assessment year

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

disallowance was called for. For A.Y. 2014-15 also, the addition was deleted, though this time by the CIT(A), following the Tribunal Order (supra)for A.Y. 2012-13. The facts remain the same for A.Y. 2013-14 as well. The AO is, accordingly, directed to ascertain the position of availability of the funds of the assessee exceeding the advances

DCIT, C-1(1), CHANDIGARH vs. M/S STYLAM INDUSTRIES LTD., CHANDIGARH

In the result, the Department’s appeal in for assessment year

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

disallowance was called for. For A.Y. 2014-15 also, the addition was deleted, though this time by the CIT(A), following the Tribunal Order (supra)for A.Y. 2012-13. The facts remain the same for A.Y. 2013-14 as well. The AO is, accordingly, directed to ascertain the position of availability of the funds of the assessee exceeding the advances

DCIT, C-1(1), CHANDIGARH vs. M/S STYLAM INDUSTRIES LTD., CHANDIGARH

In the result, the Department’s appeal in for assessment year

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

disallowance was called for. For A.Y. 2014-15 also, the addition was deleted, though this time by the CIT(A), following the Tribunal Order (supra)for A.Y. 2012-13. The facts remain the same for A.Y. 2013-14 as well. The AO is, accordingly, directed to ascertain the position of availability of the funds of the assessee exceeding the advances

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)

disallowed without giving specific finding. 14. That the assessee craves leave to add, amend, alter any ground or grounds of appeal before the appeal is finally heard or disposed off.” 6. With the consent of the parties, the case of the assessee in ITA No.633/Chd/2023 was taken as the lead case wherein the brief facts of the case are that