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

31,25,91,729/-.\nLess: Disallowance already made by the assessee: Rs. 22,86,36,462/-\nDisallowance to be made: Rs. 8,39,55,267/-\n41. The A.O. made various disallowance of interest under section 14A\nand Section 36(1

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

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 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

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

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

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

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

RIDE LINK AUTO,LUDHIANA vs. ITO WARD 7 (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

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

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

DCIT, CIRCLE, YAMUNANAGAR vs. M/S SYMBIOSIS PHARMACEUTICALS PVT. LTD., YAMUNANAGAR

In the result, appeal is dismissed

Bench: The Due Date As Prescribed In Section 139(1) Of The I.T. Act, 1961 Whereas The Assessee Has Filed Its Return Of Income After The Due Date.

disallowance of deduction claimed u/s 80IC, for assessment year 2013-14. 8.3 Finding that the facts for the year under consideration on this issue are exactly in pari materia with those having a reason for assessment year 2013-14, the ld. CIT(A) followed the aforesaid Tribunal order dated 04.10.2017, passed in ITA 501/CHD/2017, in the assessee's own case

SANJEEV KUMAR KATHURIA,YAMUNA NAGAR vs. INCOME TAX OFFICER WARD 1 , YAMUNANAGAR

In the result, the appeal of the assessee is allowed

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

disallowance under section 40A(3) of the Act amounting to Rs. 12,09,560/-. 4. Subsequently, the assessment records were called for and examined by the Ld. PCIT, Panchkula and a show cause under section 263 dt. 12/12/2023 was issued by the Ld. PCIT and the contents thereof read as under: “Perusal of assessment record reveals that you had sold

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)

1)(i) and section 35(2AB) of the Act ignoring the suo motu disallowance of Rs.10,51,71,451/- made by the assessee on account of research development expenditure claimed in the profit and loss and the said action of the AO will lead to double addition of the same amount in the hands of the assessee

SH. VIBHAV JAIN,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the ground no

Bench: SHRI. SANJAY GARG (Judicial Member), SHRI. VIKRAM SINGH YADAV (Accountant Member)

disallowance can be made only on the basis of material collected during the search or requisition. In case no incriminating material is found, as held by the Rajasthan High Court in the case of Jai Steel (India) v. Asst. CIT (supra), the earlier assessment would have to be reiterated. In case where pending assessments have abated, the Assessing Officer

SH. BIPAN JAIN,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the ground no

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

disallowance can be made only on the basis of material collected during the search or requisition. In case no incriminating material is found, as held by the Rajasthan High Court in the case of Jai Steel (India) v. Asst. CIT (supra), the earlier assessment would have to be reiterated. In case where pending assessments have abated, the Assessing Officer