PUNJAB SMALL INDUSTRIES AND EXPORT CORPORATION LTD.,CHANDIGARH vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 2(1), CHANDIGARH, CHANDIGARH

In the result, appeal of the Assessee is partly allowed

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

36,31,460. The return was scrutinized, and the assessment was completed on 24/12/2018, under Section 143(3) by the Deputy Commissioner of Income Tax, Chandigarh. The Assessing Officer (AO) made two additions: (i) Rs. 82,78,750 under Section 43B: Disallowed Rs. 37,50,000 (bonus) and Rs. 45,28,750 (ex-gratia) as they were paid on October

DCIT,CIRCLE-1(EXEMPTION), CHANDIGARH vs. M/S MANAV MANGAL SCHOOL( MANAV MANGAL SOCIETY), CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

disallowed by the AO have in fact been found to be actively engaged in rendering their respective services as is proved from the fact that during the course of survey on the assessee and the post survey enquiries, ail these parties have given their statements vis- a- vi s the salary being drawn by them from the Society

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

disallowed by the AO have in fact been found to be actively engaged in rendering their respective services as is proved from the fact that during the course of survey on the assessee and the post survey enquiries, ail these parties have given their statements vis- a- vi s the salary being drawn by them from the Society

M/S MANAV MANGAL SOCIETY,CHANDIGARH vs. DCIT, C-1, (E), CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

disallowed by the AO have in fact been found to be actively engaged in rendering their respective services as is proved from the fact that during the course of survey on the assessee and the post survey enquiries, ail these parties have given their statements vis- a- vi s the salary being drawn by them from the Society

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

disallowed by the AO have in fact been found to be actively engaged in rendering their respective services as is proved from the fact that during the course of survey on the assessee and the post survey enquiries, ail these parties have given their statements vis- a- vi s the salary being drawn by them from the Society

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

disallowed by the AO have in fact been found to be actively engaged in rendering their respective services as is proved from the fact that during the course of survey on the assessee and the post survey enquiries, ail these parties have given their statements vis- a- vi s the salary being drawn by them from the Society

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

disallowed by the AO have in fact been found to be actively engaged in rendering their respective services as is proved from the fact that during the course of survey on the assessee and the post survey enquiries, ail these parties have given their statements vis- a- vi s the salary being drawn by them from the Society

M/S MANAV MANGAL SOCIETY,CHANDIGARH vs. DCIT, C-1, (E), CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

disallowed by the AO have in fact been found to be actively engaged in rendering their respective services as is proved from the fact that during the course of survey on the assessee and the post survey enquiries, ail these parties have given their statements vis- a- vi s the salary being drawn by them from the Society

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

disallowed by the AO have in fact been found to be actively engaged in rendering their respective services as is proved from the fact that during the course of survey on the assessee and the post survey enquiries, ail these parties have given their statements vis- a- vi s the salary being drawn by them from the Society

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

36. xiv). In our case, neither the person, whose signatures are there is an employee or a family member, which we have challenged at the first instance and, therefore, the service of notice is bad in law. Similarly, in the other judgment, it has conclusively held that the department had to prove that there was proper service of notice

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

36. xiv). In our case, neither the person, whose signatures are there is an employee or a family member, which we have challenged at the first instance and, therefore, the service of notice is bad in law. Similarly, in the other judgment, it has conclusively held that the department had to prove that there was proper service of notice

DEPUTY COMMISSIONER OF INCOME TAX, CHANDIGARH vs. ESSIX BIOSCIENCES LIMITED, CHANDIGARH

In the result, the appeal filed by the Department is

Bench: SHRI A.D.JAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)

36 and Grounds of appeal filed by the revenue. Then the assessee cross checked from the office and office staff who had received the documents intimated that the documents were received by him but he forgot to hand over the same to the concerned person; then those documents were immediately handed over by him to the Accounts-cum-Tax Department

THE ASSISTANT EXCISE & TAXATION COMMISSIONER ,NAHAN vs. ADDL. CIT, RANGE, SHIMLA

In the result, all four appeals filed by the assessee are allowed

Bench: Smt. Diva Singh & Shri Vikram Singh Yadavआयकरअपीलसं./Ita No.903 /Chd/2019 "नधा"रण वष" / Assessment Year :2007-08 The Assistant Excise & बनाम The Additional Cit, Taxation Commissioner, Tds Range, Nahan Shimla "थायीलेखासं./Pan/Tan No: Ptla12468B अपीलाथ"/Appellant ""यथ"/Respondent

XVII-B then such person shall be liable to pay, by way of penalty, a sum equal to the amount of tax which such person failed to deduct. In ITA Nos. 903 to 905-Chd-2019 - Assistant Excise & Taxation Commissioner Nahan & Othrs 10 these cases we are concerned with s. 271C(l)(a). Thus s. 271C(l)(a) makes

THE ASSISTANT EXCISE & TAXATION COMMISSIONER ,SHIMLA vs. ADDL. CIT, RANGE, SHIMLA

In the result, all four appeals filed by the assessee are allowed

Bench: Smt. Diva Singh & Shri Vikram Singh Yadavआयकरअपीलसं./Ita No.903 /Chd/2019 "नधा"रण वष" / Assessment Year :2007-08 The Assistant Excise & बनाम The Additional Cit, Taxation Commissioner, Tds Range, Nahan Shimla "थायीलेखासं./Pan/Tan No: Ptla12468B अपीलाथ"/Appellant ""यथ"/Respondent

XVII-B then such person shall be liable to pay, by way of penalty, a sum equal to the amount of tax which such person failed to deduct. In ITA Nos. 903 to 905-Chd-2019 - Assistant Excise & Taxation Commissioner Nahan & Othrs 10 these cases we are concerned with s. 271C(l)(a). Thus s. 271C(l)(a) makes

THE ASSISTANT EXCISE & TAXATION COMMISSIONER ,SHIMLA vs. ADDL. CIT, RANGE, SHIMLA

In the result, all four appeals filed by the assessee are allowed

Bench: Smt. Diva Singh & Shri Vikram Singh Yadavआयकरअपीलसं./Ita No.903 /Chd/2019 "नधा"रण वष" / Assessment Year :2007-08 The Assistant Excise & बनाम The Additional Cit, Taxation Commissioner, Tds Range, Nahan Shimla "थायीलेखासं./Pan/Tan No: Ptla12468B अपीलाथ"/Appellant ""यथ"/Respondent

XVII-B then such person shall be liable to pay, by way of penalty, a sum equal to the amount of tax which such person failed to deduct. In ITA Nos. 903 to 905-Chd-2019 - Assistant Excise & Taxation Commissioner Nahan & Othrs 10 these cases we are concerned with s. 271C(l)(a). Thus s. 271C(l)(a) makes

THE ASSISTANT EXCISE & TAXATION COMMISSIONER ,NAHAN vs. ADDL. CIT, RANGE, SHIMLA

In the result, all four appeals filed by the assessee are allowed

Bench: Smt. Diva Singh & Shri Vikram Singh Yadavआयकरअपीलसं./Ita No.903 /Chd/2019 "नधा"रण वष" / Assessment Year :2007-08 The Assistant Excise & बनाम The Additional Cit, Taxation Commissioner, Tds Range, Nahan Shimla "थायीलेखासं./Pan/Tan No: Ptla12468B अपीलाथ"/Appellant ""यथ"/Respondent

XVII-B then such person shall be liable to pay, by way of penalty, a sum equal to the amount of tax which such person failed to deduct. In ITA Nos. 903 to 905-Chd-2019 - Assistant Excise & Taxation Commissioner Nahan & Othrs 10 these cases we are concerned with s. 271C(l)(a). Thus s. 271C(l)(a) makes