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

The appeal is partly allowed

Bench: SHRI. LALIET KUMAR (Judicial Member)

disallowance under section 40(a)(ia) was not warranted, relying on Merilyn Shipping and Vector Shipping rulings. 6.2 Regarding the cash payments of Rs. 16,33,037/-, the LD. AR contended these were made to transporters under business compulsion, and such payments are exempt under Rule 6DD, with the threshold limit being Rs. 35

DY. COMMISSIONER OF INCOME TAX, CIRCLE-4, LUDHIANA, AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

35: 1. The Ld. AO has wrongly assessed the total income at Rs. 1657269990/- against the returned income of Rs. 1536565490/- thereby making an addition of Rs. 120704500/-u/s 14A. 2. The Ld. AO has wrongly disallowed a sum of Rs. 120704500/- under section

DY. COMMISSIONER OF INCOME TAX, CIRCLE-4, , AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

35: 1. The Ld. AO has wrongly assessed the total income at Rs. 1657269990/- against the returned income of Rs. 1536565490/- thereby making an addition of Rs. 120704500/-u/s 14A. 2. The Ld. AO has wrongly disallowed a sum of Rs. 120704500/- under section

DY. COMMISSIONER OF INCOME TAX, CIRCLE-4, LUDHIANA, - vs. ROCKMAN INDUSTRIES LTD, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

35: 1. The Ld. AO has wrongly assessed the total income at Rs. 1657269990/- against the returned income of Rs. 1536565490/- thereby making an addition of Rs. 120704500/-u/s 14A. 2. The Ld. AO has wrongly disallowed a sum of Rs. 120704500/- under section

ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-4, AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

35: 1. The Ld. AO has wrongly assessed the total income at Rs. 1657269990/- against the returned income of Rs. 1536565490/- thereby making an addition of Rs. 120704500/-u/s 14A. 2. The Ld. AO has wrongly disallowed a sum of Rs. 120704500/- under section

DY. COMMISSIONER OF INCOME TAX, CIRCLE-4,, AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

35: 1. The Ld. AO has wrongly assessed the total income at Rs. 1657269990/- against the returned income of Rs. 1536565490/- thereby making an addition of Rs. 120704500/-u/s 14A. 2. The Ld. AO has wrongly disallowed a sum of Rs. 120704500/- under section

DCIT CIRCLE-4, LUDHIANA, LUDHIANA vs. ROCKMAN INDUSTRIES LTD, LUDHIANA

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

35: 1. The Ld. AO has wrongly assessed the total income at Rs. 1657269990/- against the returned income of Rs. 1536565490/- thereby making an addition of Rs. 120704500/-u/s 14A. 2. The Ld. AO has wrongly disallowed a sum of Rs. 120704500/- under section

DY. COMMISSIONER OF INCOME TAX, CIRCLE-4, AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

35: 1. The Ld. AO has wrongly assessed the total income at Rs. 1657269990/- against the returned income of Rs. 1536565490/- thereby making an addition of Rs. 120704500/-u/s 14A. 2. The Ld. AO has wrongly disallowed a sum of Rs. 120704500/- under section

DY. COMMISSIONER OF INCOME TAX, AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, FOCAL POINT

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

35: 1. The Ld. AO has wrongly assessed the total income at Rs. 1657269990/- against the returned income of Rs. 1536565490/- thereby making an addition of Rs. 120704500/-u/s 14A. 2. The Ld. AO has wrongly disallowed a sum of Rs. 120704500/- under section

AMBER ENTERPRISES INDIA LIMITED, RAJPURA,PUNJAB vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, PATIALA, PUNJAB

In the result, the appeal of the assessee is allowed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. MANOJ KUMAR AGGARWAL (Accountant Member)

disallowance of deduction u/s 35(2AB). in 4. That the PCIT has failed to appreciate that the AO concerned had made requisite inquiries u/s 133(6) during the course of assessment proceedings from DSIR and had also received reply in that context and since the concerned department had replied to the AO concerned, no fault can be attributed

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

disallowance of Rs. 14,15,10,213/- made by the A.O. by\ninvoking the provisions of Section 14A of the Income Tax Act, 1961.\n(hereinafter referred to as Act).\n5. Facts of the case in brief are that the assessee filed its return of\nincome on 20/03/2014 declaring an income of Rs. 140,32,08,590/- which\nwas processed

ASSISTANT COMMISSIONER OF INCOME TAX, PANCHKULA CIRCLE, PANCHKULA, PANCHKULA vs. HARYANA STATE COOPERATIVE SUPPLY AND MARKETING FEDERATION LIMITED, PANCHKULA

In the result, the present appeal of the Revenue is allowed for statistical purposes

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

disallowance in that case was because the goods stored belonged to the assessee, while in the present case, third-party storage was involved. 8.1 The next issue arising for consideration pertains to the allowability of deduction under section 80P(2)(d) of the Income Tax Act, 1961 in respect of dividend and interest income earned by the assessee from

ASSISTANT COMMISSIONER OF INCOME TAX, PANCHKULA CIRCLE, PANCHKULA, PANCHKULA vs. HARYANA STATE COOPERATIVE SUPPLY AND MARKETING FEDERATION LTD, PANCHKULA

In the result, the present appeal of the Revenue is allowed for statistical purposes

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

disallowance in that case was because the goods stored belonged to the assessee, while in the present case, third-party storage was involved. 8.1 The next issue arising for consideration pertains to the allowability of deduction under section 80P(2)(d) of the Income Tax Act, 1961 in respect of dividend and interest income earned by the assessee from

ASSISTANT COMMISSIONER OF INCOME TAX, PANCHKULA CIRCLE, PANCHKULA, PANCHKULA vs. HARYANA STATE COOPERATIVE SUPPLY AND MARKETING FEDERATION LTD, PANCHKULA

In the result, the present appeal of the Revenue is allowed for statistical purposes

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

disallowance in that case was because the goods stored belonged to the assessee, while in the present case, third-party storage was involved. 8.1 The next issue arising for consideration pertains to the allowability of deduction under section 80P(2)(d) of the Income Tax Act, 1961 in respect of dividend and interest income earned by the assessee from

DCIT-CC-III, LUDHIANA vs. M/S LAXMI ENERGY & FOODS LTD.,, CHANDIGARH

In the result, the appeal of the Revenue is dismissed

Bench: Shri A.D. Jain & Dr Krinwant Sahayआयकर अपील सं./ Ita No. 33/Chd/2021 "नधा"रण वष" / Assessment Year: 2011-12 The Dcit, Vs. M/S Laxmi Energy & Foods बनाम Ltd., Central Circle-Iii, Sco 18-19, Sector 9-D, Ludhiana Ludhiana "थायी लेखा सं./Pan No: Aaacl3147J अपीलाथ"/ Appellant ""यथ"/ Repsondent ( Hybrid Mode ) "नधा"रती क" ओर से/Assessee By : Sh. Sudhir Sehgal, Advocate राज"व क" ओर से/ Revenue By : Shri Rohit Sharma, Cit Dr सुनवाई क" तार"ख/Date Of Hearing : 06.06.2024 उदघोषणा क" तार"ख/Date Of Pronouncement : 10.07.2024 आदेश/Order Per Dr. Krinwant Sahay, A.M.:

section 14A is triggered for disallowance of expenditure incurred which is relatable to tax exempt income even though no tax exempt income under the Act has been earned during a particular year?" 4. The Appellant craves leave to add or amend the grounds of appeal on or before is heard and disposed off. 2. Appeal on Ground

DCIT, CIRCLE, PANCHKULA vs. M/S HARYANA VIDYUT PRASARAN NIGAM LTD., PANCHKULA

In the result, appeal is dismissed

Bench: Shri Krinwant Sahay & Shri Paresh M. Joshi

disallowance made under section 14A r/w rule 8D of the Income tax Rules. 1.1 The appellant corporation held following investments as on 31.03.2017; SR. NO. PARTICULARS AMOUNT (RS.) 1 Investment in UHBVNL 5,46,98,55,000 2 Investment in DHBVNL 4,37,27,35

ACIT, CIRCLE, PANCHKULA vs. M/S HARYANA STATE INDUSTRIAL & INFRASTRUCTURE DEV. CORP. LTD., PANCHKULA

In the result, appeal of the Revenue is dismissed

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

disallowance under Section 36(l)(iii) of t h e Income Tax Act, 1961 is squarely covered in view of decision of the Hon'ble Supreme Court in the case of Commissioner of Income Tax Vs. Reliance Industries Limited, reported as [2019] 410 ITR 466 (SC) wherein the issue has been held to be a pure question of fact

KHANNA INFRABUILD PRIVATE LIMITED 2000-1A, SUKHDEV NAGAR FEROZEPUR ROAD, LUDHIANA,LUDHIANA vs. THE DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2 LUDHIANA, LUDHIANA

In the result, the ground of appeal is allowed

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

disallowed. 22. Being aggrieved, the assessee carried the matter in appeal before the Ld. CIT(A) and it was submitted that the assessee had claimed deduction u/s 35AD for the first time in the Assessment Year 2017-18 since the hotel started functioning in early 2017 and the said deduction has been claimed as per the provisions of Section 35