THE KANGRA CENTRAL COOPERATIVE BANK LIMITED,DHARAMSHALA vs. DEPUTY COMMISSIONER OF INCOME TAX, PALAMPUR

In the result, both the appeals of the assessee are allowed

disallowance of provision\nmade towards standard assets amounting to Rs.2,21,28,000/- and separately,\nthe penalty proceedings were initiated under section 271

AKM RESORTS,MOHALI vs. ACIT CIRCLE 5(1), CHANDIGARH

Appeal of the assessee is allowed

Bench: This Tribunal. The Assessee

section 274 of the Income Tax Act, 1961 was issued to the assessee on 08.12.2018 fixing the case for 04.01.2019. ITA 42/CHD/2024 A.Y. 2016-17 3 2.3 Thereafter, another opportunity of being heard was given to the assessee vide notice dated 02.05.2019 fixing the case for 10.05.2019 sent by post and by e-mail also. However, on the said dates

M/S APEX BUILDERS, LUDHIANA vs. ITO, W-2(1), LUDHIANA

The appeal is partly allowed

Bench: SHRI. LALIET KUMAR (Judicial Member)

disallowed notional interest of Rs.12,000 under section 36(1)(iii). 4.6 As a result of these additions, the AO computed the total assessed income at Rs.33,96,780/- and initiated penalty proceedings under section 271

JINDAL PADDING PRIVATE LIMITED,VILLAGE MANNPURA, TEHSIL NALAG vs. INCOME TAX OFFICER PARWANO, PARWANO

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

271(1) (c) of the Act. The observation of the Hon'ble Delhi High Court is as under:- 'Under the scheme of the Income Tax Act, 1961, the total income of the assessee is first computed under the normal provisions of the Act and tax payable on such total income is computed with the prescribed percentage of the book profits

ASPEE SONS,SOLAN vs. INCOME TAX OFFICER, PARWANOO, PARWANOO

In the result, appeal of the assessee is allowed for statistical purposes

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

disallowances: (i) Rs. 18,33,710/- towards ineligible profits from insurance claims and foreign exchange fluctuation not derived from manufacturing activity, and (ii) Rs. 9,86,497/- for excess deduction on additional depreciation. Penalty proceedings under Section 271

SHRI DINESH SETHI,LUDHIANA vs. ITO, LUDHIANA

The appeals are dismissed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 376/Chd/2014 & "नधा"रण वष" / Assessment Year : 2006-07 Shri Janesh Sethi, Legal Heir Of बनाम The Ito, Late Shri Dinesh Sethi, Ward – 1(1), Vs Prop. M/S R.S. Trading Corp., Ludhiana. C-434, Urban Estate Focal Point, Ludhiana. "थायी लेखा सं./Pan /Tan No: Aaqpk1200Q अपीलाथ"/Appellant ""यथ"/Respondent "नधा"रती क" ओर से/Assessee By : Shri Sudhir Sehgal, Advocate राज"व क" ओर से/ Revenue By : Shri Manav Bansal, Cit Dr तार"ख/Date Of Hearing : 23.06.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 04.8.2025

Section 271(1)(c) makes it clear that that when this deeming fiction comes into play in the above two situations then the related addition or disallowance

SH. DINESH SETHI,LUDHIANA vs. ITO, LUDHIANA

The appeals are dismissed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 376/Chd/2014 & "नधा"रण वष" / Assessment Year : 2006-07 Shri Janesh Sethi, Legal Heir Of बनाम The Ito, Late Shri Dinesh Sethi, Ward – 1(1), Vs Prop. M/S R.S. Trading Corp., Ludhiana. C-434, Urban Estate Focal Point, Ludhiana. "थायी लेखा सं./Pan /Tan No: Aaqpk1200Q अपीलाथ"/Appellant ""यथ"/Respondent "नधा"रती क" ओर से/Assessee By : Shri Sudhir Sehgal, Advocate राज"व क" ओर से/ Revenue By : Shri Manav Bansal, Cit Dr तार"ख/Date Of Hearing : 23.06.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 04.8.2025

Section 271(1)(c) makes it clear that that when this deeming fiction comes into play in the above two situations then the related addition or disallowance

THE SHAHABAD COOP. SUGAR MILLS,SHAHABAD vs. ACIT, CIRCLE, KURUKSHETRA

Bench: Us In Terms Of Section 253 Of The Income Tax Act, 1961. 2. The Assessee Being Aggrieved By The Order Of Ld. Cit(A) Dt. 11/03/2018 Which Is Hereinafter Referred To As The Impugned Order, Before This Tribunal In Form No. 36 Has Interalia Raised The Following Grounds Of Appeal:

Section u/s 271(l)(c) of the I.T. Act are attracted in this case for which penalty proceedings are initiated separately." The submissions made by the appellant have been clearly controverted by the A.O. in arriving at his conclusion. In the circumstances, I consider that the addition has been correctly made and confirm the same. This ground of appeal

M/S HIMACHAL FASHION PVT. LTD.,LUDHIANA vs. ITO, W-6(3), LUDHIANA

In the result, the appeal of the Assessee is allowed

Bench: Shri Krinwant Sahay & Shri Paresh M. Joshiआयकर अपील सं./ Ita No. 8/Chd/2020 िनधा"रण वष" / Assessment Year: 2012-13

disallow the claim of considered u/s 80IC of the Act but it cannot be considered as filing of inaccurate particulars but the Assessing Officer did not accept this argument and levied penalty u/s Section 271

OSHO FORGE LTD.,LUDHIANA vs. DCIT, LUDHIANA

Appeal of the Assessee is allowed and penalty is deleted

Bench: Shri Rajpal Yaday & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 523/Chd/2024 "नधा"रण वष" / Assessment Year : 2007-08 Osho Forge Ltd., Vs. Dcit, बनाम D-42, Phase V, Circle 1, Focal Point, Ludhiana, Ludhiana Punjab 141010 "थायी लेखा सं./Pan No: Aaaco3362I अपीलाथ"/Appellant ""यथ"/Respondent ( Hybrid Hearing ) "नधा"रती क" ओर से/Assessee By : Sh. Sarabjit Garg, Ca राज"व क" ओर से/ Revenue By : Sh. Ved Parkash Kalia, Jcit, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 27.11.2024 उदघोषणा क" तार"ख/Date Of Pronouncement : 02.12.2024

section 271(1)(c) makes it clear that that when this deeming fiction comes into play in the above two situations then the related addition or disallowance

SH. JAGMOHAN SINGH,LUDHIANA vs. DCIT, CC-1, LUDHIANA

In the result, the appeal of the assessee is allowed

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member)

disallowed and an amount of Rs. 38,65,580/- was brought to tax under the head “long term capital gains”. Separately, penalty proceedings under section 271

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)

disallowed the entire deduction claimed. An alternative claim made by the assessee under Section 36(1)(iii) was also rejected, as the assessee failed to provide sufficient evidence to prove that the loan was used for business purposes. Further, penalty proceedings under Section 271

DCIT, C-1 (EXEMPTIONS), CHANDIGARH vs. THE INSTITUTION OF CIVIL ENGINEERS SOCIETY, LUDHIANA

In the result, appeal of the Revenue is dismissed

disallowance should not be\nmade. The Id. CIT(Appeals), accordingly, set aside the order of the Assessing\nOfficer and deleted the additions. The Assessing Officer has not brought any\nmaterial on record as to how he has given his finding that the cars have been\npurchased for the benefit of the Chairman. The Assessing Officer was also not\njustified

THE AYALI KALAN CO-OP AGRICULTURE MULTI,LUDHIANA vs. INCOME TAC OFFICER, LUDHIANA

The appeal of the assessee is allowed

Bench: Shri Rajpal Yadav

disallowed the claim of the assessee and determined the taxable income at Rs.97,60,590/-. 4. The ld. AO has visited the assessee with penalty under Section 271

DAXEN AGRITECH INDIA PVT. LTD.,BADDI vs. ACIT, CIRCLE, PARWANOO

In the result, all the above appeals of the Assessee are dismissed

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

disallowed and added back in the taxable income of the assessee. I have reason to believe that the assessee has furnished inaccurate particulars of its income, therefore penalty proceedings under section 271

DAXEN AGRITECH INDIA PVT. LTD.,BADDI vs. ACIT, CIRCLE, PARWANOO

In the result, all the above appeals of the Assessee are dismissed

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

disallowed and added back in the taxable income of the assessee. I have reason to believe that the assessee has furnished inaccurate particulars of its income, therefore penalty proceedings under section 271

DAXEN AGRITECH INDIA PVT. LTD.,BADDI vs. ACIT, CIRCLE, PARWANOO

In the result, all the above appeals of the Assessee are dismissed

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

disallowed and added back in the taxable income of the assessee. I have reason to believe that the assessee has furnished inaccurate particulars of its income, therefore penalty proceedings under section 271

SH. AMAN SETH,LUDHIANA vs. ITO, W-1(1), LUDHIANA

In the result, appeal filed by the assessee is allowed for statistical purposes

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

section 36(l)(iii)." Further, in the case of CIT Vs Abhishek Industries Ltd. quoted above, the Hon'ble Punjab & Haryana High Court held that: - "Once it is borne out from the records that the assessee had borrowed certain funds on which liability to pay tax is being incurred and on the other hand, certain amounts had been advanced