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: -

disallowances made in the regular assessment. The order passed on 31-03-2017 was not an order of regular assessment as envisaged u/s 234D. Accordingly, the interest as charged by Ld. AO was deleted against which the revenue is in further appeal before us. Our findings and Adjudication 4. The short issue that falls for our consideration is to adjudicate

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

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

disallowed. The following decisions are also to the same effect : i) M/s Beauty Tex ITA 508/JP/2016 ii) Shri Heera Lal Chuni Lal Jain V ITO, order dated 01.01.2016, passed in ITA No.4547/Mum/2014 iii) M/s Imperial Imp & Exp V ITO, order dated 18.03.2016, passed in ITA No. 5427/Mum/2015 iv) ITO V Shri Sanjay V Dhruv, order dated

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

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

disallowed. The following decisions are also to the same effect : i) M/s Beauty Tex ITA 508/JP/2016 ii) Shri Heera Lal Chuni Lal Jain V ITO, order dated 01.01.2016, passed in ITA No.4547/Mum/2014 iii) M/s Imperial Imp & Exp V ITO, order dated 18.03.2016, passed in ITA No. 5427/Mum/2015 iv) ITO V Shri Sanjay V Dhruv, order dated

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

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

disallowed. The following decisions are also to the same effect : i) M/s Beauty Tex ITA 508/JP/2016 ii) Shri Heera Lal Chuni Lal Jain V ITO, order dated 01.01.2016, passed in ITA No.4547/Mum/2014 iii) M/s Imperial Imp & Exp V ITO, order dated 18.03.2016, passed in ITA No. 5427/Mum/2015 iv) ITO V Shri Sanjay V Dhruv, order dated

DCIT, CC-I, CHANDIGARH vs. M/S D.D. GLOBAL CAPITAL PVT. LTD., NEW DELHI

The appeal of the Revenue is hereby dismissed

Bench: Smt. Diva Singh & Dr. B.R.R. Kumarassessment Year: 2012-13

disallowance under section 14A as the assessee has invested Rs. 29,96,34,120/- as per the balance sheet. On perusal of the record, we find that the assessee has not earned any exempt income. The Assessing Officer has resorted to the matching principles as enunciated in the case of Taparia Tools Ltd. Vs. JCIT 260

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

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,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

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

NAHAR SPINNING MILLS LTD.,LUDHIANA vs. ACIT, C-7, LUDHIANA

In the result, the appeal filed by the assessee for the assessment year 2014-

Bench: Shri N.K. Saini & Shri R.L. Negiआयकर अपील सं./Ita Nos. 1160/Chd/2019 "नधा"रण वष" / Assessment Year : 2014-15

260/-. 3. The assessee challenged the assessment order before the ld. CIT(A). The ld. CIT(A) restricted the addition on account of disallowance U/s 14A read with Rule 8D of the Rules to the amount claimed as exempt U/s 10(34) of the Act, confirmed the addition

DCIT, C-1 (EXEMPTION), CHANDIGARH vs. M/S IMPROVEMENT TRUST KARTARPUR, KARTARPUR

The appeals of the Revenue are hereby dismissed

Bench: Smt. Diva Singh & Dr. B.R.R. Kumarassessment Year: 2014-15

disallowance of exemption. 74. It cannot possibly be suggested that the Government of Punjab formed the trusts under the Punjab Town Improvement Act, 1922 because it wanted to carry on the business as colonizers or developers under the mask of the category "objects of general public utility". 75. Section 28(2)(iii) of the Punjab Town Improvement Act, 1922 permits

DCIT, C-1 (EXPEMTION), CHANDIGARH vs. M/S IMPROVEMENT TRUST HOSHIARPUR, HOSHIARPUR

The appeals of the Revenue are hereby dismissed

Bench: Smt. Diva Singh & Dr. B.R.R. Kumarassessment Year: 2014-15

disallowance of exemption. 74. It cannot possibly be suggested that the Government of Punjab formed the trusts under the Punjab Town Improvement Act, 1922 because it wanted to carry on the business as colonizers or developers under the mask of the category "objects of general public utility". 75. Section 28(2)(iii) of the Punjab Town Improvement Act, 1922 permits

ASTT. COMMISSIONER OF INCOME TAX, CIRCLE-4, LUDHIANA, AAYAKAR BHAWAN vs. WARYAM STEEL CASTING PRIVATE LIMITED, KANGANWAL ROAD

In the result, appeal of the assessee is allowed and the Cross appeal of the Revenue is dismissed

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

260 (Delhi) (xi) Assessment year 2004-05 - During relevant assessment year, assessee had purchased sand from 'S' on different dates - Assessing Officer issued notice to 'S' under section 133(6) which returned back with remarks 'not known' - Assessing Officer, thus, disallowed

WARYAM STEEL CASTINGS PRIVATE LIMITED,LUDHIANA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-4, LUDHIANA

In the result, appeal of the assessee is allowed and the Cross appeal of the Revenue is dismissed

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

260 (Delhi) (xi) Assessment year 2004-05 - During relevant assessment year, assessee had purchased sand from 'S' on different dates - Assessing Officer issued notice to 'S' under section 133(6) which returned back with remarks 'not known' - Assessing Officer, thus, disallowed