DCIT, CHANDIGARH vs. SH. PARAMJIT SINGH, MOHALI

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

disallowance into the income of the assessee and the assessee has no explanation that why the same be not treated as taxable income of the assessee for that relevant year. The words ‘particulars of income’ though in general will have a wide and broader aspect as to of the relevant particulars such as the source of income, manner of earning

DCIT, CHANDIGARH vs. SMT. JASWANT KAUR, MOHALI

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

disallowance into the income of the assessee and the assessee has no explanation that why the same be not treated as taxable income of the assessee for that relevant year. The words ‘particulars of income’ though in general will have a wide and broader aspect as to of the relevant particulars such as the source of income, manner of earning

DCIT, CHANDIGARH vs. SH. KULWANT SINGH, MOHALI

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

disallowance into the income of the assessee and the assessee has no explanation that why the same be not treated as taxable income of the assessee for that relevant year. The words ‘particulars of income’ though in general will have a wide and broader aspect as to of the relevant particulars such as the source of income, manner of earning

DCIT, CHANDIGARH vs. SMT. MANJIT KAUR, CHANDIGARH

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

disallowance into the income of the assessee and the assessee has no explanation that why the same be not treated as taxable income of the assessee for that relevant year. The words ‘particulars of income’ though in general will have a wide and broader aspect as to of the relevant particulars such as the source of income, manner of earning

DCIT, CHANDIGARH vs. SH. KULWANT SINGH, MOHALI

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

disallowance into the income of the assessee and the assessee has no explanation that why the same be not treated as taxable income of the assessee for that relevant year. The words ‘particulars of income’ though in general will have a wide and broader aspect as to of the relevant particulars such as the source of income, manner of earning

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

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

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 588/Chd/2018 निर्धारण वर्ष / Assessment Years : 2012-13 The DCIT C-V, Ludhiana बनाम M/s Hero Cycles Ltd. Hero Nagar, G.T. Road Ludhiana स्थायी लेखा सं./PAN NO: AAACH4073P अपीलार्थी/Appellant प्रत्यर्थी / Respondent आयकर अपील सं. / ITA No. 473/Chd/2018 निर्धारण वर्ष / Assessment Years : 2012-13 M/s Hero Cycles Ltd. Hero Nagar, G.T. Road Ludhiana बनाम The ACIT C-V, Ludhiana स्थायी लेखा सं./PAN NO: AAACH4073P

31,25,91,729/-. Less: Disallowance already made by the assessee: Rs. 22,86,36,462/ Disallowance to be made: Rs. 8,39,55,267/- 41. The A.O. made various disallowance of interest under section 14A and Section 36(1

SHRI GURU RAM DASS EDUCATIONAL SOCIETY,MOHALI vs. PR.CIT(CENTRAL) GURGAON, AT CHANDIGARH

31 of 1998 Oct. 8, 2002 • Parivar Sewa Sanstha Vs. Deputy Director of Income-tax [2005] 1 SOT 71 (Del) • Action for Welfare & Awakening in Rural Environment (AWARE) Vs. Deputy Commissioner of Income-tax [2003] 130 Taxman 82 (AP) • Little Tradition Vs. Deputy Director of Income-tax (Exemption), Trust Circle-IV, New Delhi [2009] 119 ITD 127 (Del) • Director

CHANDIGARH EDUCATIONAL SOCIETY,MOHALI vs. PR.CIT(CENTRAL)-GURGAON, AT CHANDIGARH

31 of 1998 Oct. 8, 2002 • Parivar Sewa Sanstha Vs. Deputy Director of Income-tax [2005] 1 SOT 71 (Del) • Action for Welfare & Awakening in Rural Environment (AWARE) Vs. Deputy Commissioner of Income-tax [2003] 130 Taxman 82 (AP) • Little Tradition Vs. Deputy Director of Income-tax (Exemption), Trust Circle-IV, New Delhi [2009] 119 ITD 127 (Del) • Director

CHANDIGARH EDUCATIONAL TRUST,MOHALI vs. PR.CIT-CENTRAL,GURGAON, AT CHANDIGARH

31 of 1998 Oct. 8, 2002 • Parivar Sewa Sanstha Vs. Deputy Director of Income-tax [2005] 1 SOT 71 (Del) • Action for Welfare & Awakening in Rural Environment (AWARE) Vs. Deputy Commissioner of Income-tax [2003] 130 Taxman 82 (AP) • Little Tradition Vs. Deputy Director of Income-tax (Exemption), Trust Circle-IV, New Delhi [2009] 119 ITD 127 (Del) • Director

ARYANS EDUCATIONAL AND CHARITABLE TRUST REGD, MOHALI,MOHALI vs. COMMISSIONER OF INCOME TAX, EXEMPTIONS, CHANDIGARH

In the result, appeal is allowed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 1136/Chd/2024 "नधा"रण वष" / Assessment Year: 2025-26 Aryans Educational & The Cit (Exemptions), Charitable Trust, Regd.Mohali Vs Chandigarh, C/O Shri Tej Mohan Singh, Advocate, # 527, Sector 10-D, Chandigarh. "थायी लेखा सं./Pan No: Aabta7550L अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Tej Mohan Singh, Advocate Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 07.08.2025 Date Of Pronouncement : 24.09.2025

disallowed is of an ambiguous nature owing to the explanation offered alleged to being hazy but is not conclusively held as being for any activity contravening or outside of charity. No proper facts have been determined and placed on record that shows that the 3 preconditions of Explanation 12AB(4) have been met. Due to the hazy grey-area nature

METALMAN AUTO PRIVATE LIMITED,NEW DELHI vs. ACIT, CIRCLE -1,, LUDHIANA

Bench: Shri N.K. Saini & Shri Sudhanshu Srivastavaआयकर अपील सं./ Ita No. 18/Chd/2022 "नधा"रण वष" / Assessment Year : 2019-20 Dcit, Central Circle, Smt. Madhubala बनाम Patiala W/O Sh. Krishan Gopal, Ward No.1, Lehargaga, Punjab "थायी लेखा सं./Pan No: Anjpb7890D अपीलाथ"/Appellant ""यथ"/Respondent

disallowed for once and all if payment is delayed beyond the prescribed time. 1(b) That the Ld.CIT(A) erred in ignoring and failing to take into account the amendment carried out by Finance Act, 2021 by way of inserting Explanation 1 & Explanation 2 below section 36(l)(va) of the Act which has been interpreted

SANDEEP GUPTA,CHANDIGARH vs. DCIT, CIRCLE 3(1),, CHANDIGARH

Bench: Shri N.K. Saini & Shri Sudhanshu Srivastavaआयकर अपील सं./ Ita No. 18/Chd/2022 "नधा"रण वष" / Assessment Year : 2019-20 Dcit, Central Circle, Smt. Madhubala बनाम Patiala W/O Sh. Krishan Gopal, Ward No.1, Lehargaga, Punjab "थायी लेखा सं./Pan No: Anjpb7890D अपीलाथ"/Appellant ""यथ"/Respondent

disallowed for once and all if payment is delayed beyond the prescribed time. 1(b) That the Ld.CIT(A) erred in ignoring and failing to take into account the amendment carried out by Finance Act, 2021 by way of inserting Explanation 1 & Explanation 2 below section 36(l)(va) of the Act which has been interpreted

TEGSONS INDIA,LUDHIANA vs. ITO, WARD 1(3), LUDHIANA

Bench: Shri N.K. Saini & Shri Sudhanshu Srivastavaआयकर अपील सं./ Ita No. 18/Chd/2022 "नधा"रण वष" / Assessment Year : 2019-20 Dcit, Central Circle, Smt. Madhubala बनाम Patiala W/O Sh. Krishan Gopal, Ward No.1, Lehargaga, Punjab "थायी लेखा सं./Pan No: Anjpb7890D अपीलाथ"/Appellant ""यथ"/Respondent

disallowed for once and all if payment is delayed beyond the prescribed time. 1(b) That the Ld.CIT(A) erred in ignoring and failing to take into account the amendment carried out by Finance Act, 2021 by way of inserting Explanation 1 & Explanation 2 below section 36(l)(va) of the Act which has been interpreted

PARMINDER SINGH,LUDHIANA vs. ITO, LUDHIANA

Bench: Shri N.K. Saini & Shri Sudhanshu Srivastavaआयकर अपील सं./ Ita No. 18/Chd/2022 "नधा"रण वष" / Assessment Year : 2019-20 Dcit, Central Circle, Smt. Madhubala बनाम Patiala W/O Sh. Krishan Gopal, Ward No.1, Lehargaga, Punjab "थायी लेखा सं./Pan No: Anjpb7890D अपीलाथ"/Appellant ""यथ"/Respondent

disallowed for once and all if payment is delayed beyond the prescribed time. 1(b) That the Ld.CIT(A) erred in ignoring and failing to take into account the amendment carried out by Finance Act, 2021 by way of inserting Explanation 1 & Explanation 2 below section 36(l)(va) of the Act which has been interpreted

ITO, WARD 6(1), LUDHIANA vs. SH. SITA RAM SINGLA, LUDHIANA

Bench: Shri N.K. Saini & Shri Sudhanshu Srivastavaआयकर अपील सं./ Ita No. 18/Chd/2022 "नधा"रण वष" / Assessment Year : 2019-20 Dcit, Central Circle, Smt. Madhubala बनाम Patiala W/O Sh. Krishan Gopal, Ward No.1, Lehargaga, Punjab "थायी लेखा सं./Pan No: Anjpb7890D अपीलाथ"/Appellant ""यथ"/Respondent

disallowed for once and all if payment is delayed beyond the prescribed time. 1(b) That the Ld.CIT(A) erred in ignoring and failing to take into account the amendment carried out by Finance Act, 2021 by way of inserting Explanation 1 & Explanation 2 below section 36(l)(va) of the Act which has been interpreted

SH. VIJAY KUMAR SINGH,BADDI vs. ITO , BADDI

Bench: Shri N.K. Saini & Shri Sudhanshu Srivastavaआयकर अपील सं./ Ita No. 18/Chd/2022 "नधा"रण वष" / Assessment Year : 2019-20 Dcit, Central Circle, Smt. Madhubala बनाम Patiala W/O Sh. Krishan Gopal, Ward No.1, Lehargaga, Punjab "थायी लेखा सं./Pan No: Anjpb7890D अपीलाथ"/Appellant ""यथ"/Respondent

disallowed for once and all if payment is delayed beyond the prescribed time. 1(b) That the Ld.CIT(A) erred in ignoring and failing to take into account the amendment carried out by Finance Act, 2021 by way of inserting Explanation 1 & Explanation 2 below section 36(l)(va) of the Act which has been interpreted

SH. VIJAY KUMAR SINGH,BADDI vs. ITO , BADDI

Bench: Shri N.K. Saini & Shri Sudhanshu Srivastavaआयकर अपील सं./ Ita No. 18/Chd/2022 "नधा"रण वष" / Assessment Year : 2019-20 Dcit, Central Circle, Smt. Madhubala बनाम Patiala W/O Sh. Krishan Gopal, Ward No.1, Lehargaga, Punjab "थायी लेखा सं./Pan No: Anjpb7890D अपीलाथ"/Appellant ""यथ"/Respondent

disallowed for once and all if payment is delayed beyond the prescribed time. 1(b) That the Ld.CIT(A) erred in ignoring and failing to take into account the amendment carried out by Finance Act, 2021 by way of inserting Explanation 1 & Explanation 2 below section 36(l)(va) of the Act which has been interpreted

VIDYADHAR TIWARI,BADDI vs. ITO, , BADDI

Bench: Shri N.K. Saini & Shri Sudhanshu Srivastavaआयकर अपील सं./ Ita No. 18/Chd/2022 "नधा"रण वष" / Assessment Year : 2019-20 Dcit, Central Circle, Smt. Madhubala बनाम Patiala W/O Sh. Krishan Gopal, Ward No.1, Lehargaga, Punjab "थायी लेखा सं./Pan No: Anjpb7890D अपीलाथ"/Appellant ""यथ"/Respondent

disallowed for once and all if payment is delayed beyond the prescribed time. 1(b) That the Ld.CIT(A) erred in ignoring and failing to take into account the amendment carried out by Finance Act, 2021 by way of inserting Explanation 1 & Explanation 2 below section 36(l)(va) of the Act which has been interpreted