KARNAIL SINGH,UK vs. JCIT (OSD) INTL. TAXATION, CIRCLE, CHANDIGARH

In the result, all the appeals of the assessee stands allowed

section 271(l)(c) of the Act initiating penalty proceedings against the appellant is vague, illegal and bad in law. 2. That, in view of the facts and circumstances of the case and in law, no valid satisfaction has been recorded by the Assessing Officer while completing the assessment proceedings, hence the order passed u/s 274 r.w.s271

KARNAIL SINGH,UK vs. JCIT (OSD) INTL. TAXATION, CIRCLE, CHANDIGARH

In the result, all the appeals of the assessee stands allowed

section 271(l)(c) of the Act initiating penalty proceedings against the appellant is vague, illegal and bad in law. 2. That, in view of the facts and circumstances of the case and in law, no valid satisfaction has been recorded by the Assessing Officer while completing the assessment proceedings, hence the order passed u/s 274 r.w.s271

KARNAIL SINGH,UK vs. JCIT (OSD) INTL. TAXATION, CIRCLE, CHANDIGARH

In the result, all the appeals of the assessee stands allowed

section 271(l)(c) of the Act initiating penalty proceedings against the appellant is vague, illegal and bad in law. 2. That, in view of the facts and circumstances of the case and in law, no valid satisfaction has been recorded by the Assessing Officer while completing the assessment proceedings, hence the order passed u/s 274 r.w.s271

KARNAIL SINGH,UK vs. JCIT (OSD) INTL. TAXATION, CIRCLE, CHANDIGARH

In the result, all the appeals of the assessee stands allowed

section 271(l)(c) of the Act initiating penalty proceedings against the appellant is vague, illegal and bad in law. 2. That, in view of the facts and circumstances of the case and in law, no valid satisfaction has been recorded by the Assessing Officer while completing the assessment proceedings, hence the order passed u/s 274 r.w.s271

KARNAIL SINGH,UK vs. JCIT (OSD) INTL. TAXATION, CIRCLE, CHANDIGARH

In the result, all the appeals of the assessee stands allowed

section 271(l)(c) of the Act initiating penalty proceedings against the appellant is vague, illegal and bad in law. 2. That, in view of the facts and circumstances of the case and in law, no valid satisfaction has been recorded by the Assessing Officer while completing the assessment proceedings, hence the order passed u/s 274 r.w.s271

KARNAIL SINGH,UK vs. JCIT (OSD) INTL. TAXATION, CIRCLE, CHANDIGARH

In the result, all the appeals of the assessee stands allowed

section 271(l)(c) of the Act initiating penalty proceedings against the appellant is vague, illegal and bad in law. 2. That, in view of the facts and circumstances of the case and in law, no valid satisfaction has been recorded by the Assessing Officer while completing the assessment proceedings, hence the order passed u/s 274 r.w.s271

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

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

disallowance of provision made towards standard assets amounting to Rs. 2,21,28,000/- and separately, the penalty proceedings were initiated under section 271(1)(c) of the Act for concealment of income by furnishing inaccurate particulars of income by issuing a notice dt. 05/03/2014 under section 274

THE HP STATE CO-OPERATIVE MARKETING & CONSUMERS FEDERATION LIMITED,SHIMLA vs. DCIT, CIRCLE, SHIMLA

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

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

disallowance of Rs. 22,93,002/- was made under section 14A r.w. Rule 8D of the Act and thereafter the penalty proceedings were separately initiated for misreporting of income by issue of show cause under section 274

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

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(1)(c) of the Act for\nconcealment of income by furnishing inaccurate particulars of income by\nissuing a notice dt. 05/03/2014 under section 274

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)

disallowed entire purchases of Rs.4.17 Crores under Section 69C. The CIT(A) applied GP rate of 3.67% on bogus purchases, whereas the Tribunal enhanced the disallowance to 12.5% of bogus purchases. 5.6.7. The AO has, in the impugned order discussed as to how the assessee has not maintained Stock register, along with other reasons, based upon this finding

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)

disallowed entire purchases of Rs.4.17 Crores under Section 69C. The CIT(A) applied GP rate of 3.67% on bogus purchases, whereas the Tribunal enhanced the disallowance to 12.5% of bogus purchases. 5.6.7. The AO has, in the impugned order discussed as to how the assessee has not maintained Stock register, along with other reasons, based upon this finding

AL RASHEED CHARITABLE SOCIETY,HARYANA vs. JCIT, EXEMPTIONS, CHANDIGARH

Appeal of the Assessee is allowed for statistical purposes

section\n143(1) of the Act. The case of the assessee was selected through CASS for\ncomplete scrutiny. After the issue of statutory notices, the AO examined\nthe details. The AO has completed the assessment u/s.143(3) of the Act\nvide an order dated:21.12.2018 assessing the assessee as an AOP at the\nassessed total income of the assessee

HIMALAYAN BUDDHIST CULTURAL ASSOCIATION,KULLU vs. ACIT,CIRCLE/DCIT CPC,BENGLURU, MANDI

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

Bench: Due Date Of Filling Of Income Tax Return Was On Bonafide Grounds, The Cit(A) Has Erred In Not Condoning The Delay.

disallowing the benefit under section 11(2) of the Act to the assessee. He requested to restore the issue back to the file of the A.O. to allow the claim after verification. The reliance was placed on the following case laws : • M/s Infrastructure Development Fund Vs. The DCIT, Exemptions in ITA No. 220/Chd/2020 for the A.Y. 2016-17 vide order

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)

274 of paperbook volume 2). The Respondent has settled the same under VSV Scheme as no tax impact involved. 2 2007-08 1,02,69,448 Service Foreign travelling The Hon'ble Tribunal agreement dated expenditure disallowed remanded the issue April 15, 2002 alleging that the back to the DRP, Delhi entered with Respondent is not to pass a speaking

DCIT-CC-III, LUDHIANA vs. M/S SEL TEXTILE LTD, LUDHIANA

In the result, the appeal is allowed

274, GT Road, VS Ludhiana. Dhandari Khurd, Ludhiana. "थायी लेखा सं./PAN /TAN No: AANCS0401M अपीलाथ"/Appellant ""यथ"/Respondent राज"व क" ओर से/ Revenue by : Shri Ashok Khanna, Addl. CIT िनधा"रती क" ओर से/Assessee by : Shri Ashwani Kumar, CA & Shri Bhavesh Jindal, CA तारीख/Date of Hearing : 16.11.2021 उदघोषणा क" तारीख/Date of Pronouncement : 04.01.2022 VIRTUAL HEARING

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

disallowance in computing the total income of the assessee for the purpose of section 271(1)(c) would be deemed to be representing the income in respect of which inaccurate particulars have been furnished. 11. In the light of the above, if we examine the facts then it would reveal that first addition is on account of difference in opinion

S.P. SINGLA CONSTRUCTION PRIVATE LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CHANDIGARH

In the result, the appeal is allowed

Bench: SHRI MAHAVIR SINGH (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

disallowed as per the provisions of the Income Tax Act, 1961.” Analysis of information by the AO: 3. Vide letter dated 01.03.2019 and email ID at manojkumar@sbsingla.com andspscpkl@gmail.com, assessee Company was requested to provide following information to this office on or before 06.03.2019: I. Please furnish copies of nil, audit financial statements with all annexures