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

36,86,413)/2 Rs. 1,83,23,07,240 Disallowance @ 0.5% Rs. 91,61,536/- as against Rs. 2,94,48,717/- suo- moto disallowed made by assessee. The appellant is entitled to the following relief:- i) Suo-moto disallowance made under rule 8D(2)(ii) Rs. 1,02,82,974 ii) Suo-moto disallowance made under rule

THE MULLANPUR GARIBDAS CO-OP MULTIPURPOSE SOCIETY,MOHALI vs. PR. CIT-II, CHANDIGARH

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

disallowed deduction under section 80P on the interest income earned from the FDs maintained in the banks. It was stated that however, the assessee was not eligible for deduction under section 80P on this interest income. It was stated that the issue had not been examined by the AO, nor the assessee had offered any detail regarding claiming deduction

THE MULLANPUR GARIBDAS CO-OP MULTIPURPOSE SOCIETY,MULLANPUR vs. PR. CIT-II, CHANDIGARH

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

disallowed deduction under section 80P on the interest income earned from the FDs maintained in the banks. It was stated that however, the assessee was not eligible for deduction under section 80P on this interest income. It was stated that the issue had not been examined by the AO, nor the assessee had offered any detail regarding claiming deduction

THE MULLANPUR GARIBDAS CO-OP MULTIPURPOSE SOCIETY,MOHALI vs. DCIT, C-6(1), MOHALI

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

disallowed deduction under section 80P on the interest income earned from the FDs maintained in the banks. It was stated that however, the assessee was not eligible for deduction under section 80P on this interest income. It was stated that the issue had not been examined by the AO, nor the assessee had offered any detail regarding claiming deduction

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

36,86,413)/2\nRs. 1,83,23,07,240\nDisallowance @ 0.5% Rs. 91,61,536/- as against Rs. 2,94,48,717/- suo-\nmoto disallowed made by assessee.\nThe appellant is entitled to the following relief:-\ni) Suo-moto disallowance made under rule 8D(2)(ii) Rs. 1,02,82,974\nii) Suo-moto disallowance made under rule

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE, PATIALA, PATIALA vs. PUNJAB STATE POWER CORPORATION LIMITED, PATIALA

In the result, both the appeals filed by the Revenue are partly allowed

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

section 36(1)(va) of the Act and therefore there cannot be any disallowance under the said provision. 19.4 It was further submitted that during the said period, the assessee company has made payment to the retired and other employees and only net funds retained by the company was to the tune

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE, PATIALA vs. PUNJAB STATE POWER CORPORATION LIMITED, PATIALA

In the result, both the appeals filed by the Revenue are partly allowed

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

section 36(1)(va) of the Act and therefore there cannot be any disallowance under the said provision. 19.4 It was further submitted that during the said period, the assessee company has made payment to the retired and other employees and only net funds retained by the company was to the tune

THE AMBALA CO-OP MARKETING CUM PROCESSING SOCIETY LTD,AMBALA vs. ITO WARD-1 AMBALA, AMBALA CANTT

36 New Anaj Mandi Ambala Ambala City, Ambala-Haryana-134003 "ायी लेखा सं./PAN NO: AAAFT8989P अपीलाथ"/Appellant ""यथ"/Respondent िनधा"रती क" ओर से/Assessee by : None राज"व क" ओर से/ Revenue by : Dr. Ranjit Kaur, Addl. CIT, Sr. DR सुनवाई क" तारीख/Date of Hearing : 11/08/2025 उदघोषणा क" तारीख/Date of Pronouncement : 12/08/2025 आदेश/Order PER VIKRAM

M/S BARNALA BUILDERS AND CONSULTANT,ZIRAKPUR vs. DCIT/ACIT (CEN)-1, CHANDIGARH

In the result, the appeal of the assessee is dismissed

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

2,46,952/- invoking the provisions of Section 143(1)(a)(iv) was made for fault of the assessee to pay the employees contribution to PF/ESI before the prescribed due date under the relevant statue. Against the said intimation and the disallowance so made under section 36

THE VED PRAKASH MUKAND LAL EDUCATIONAL SOCIETY,YAMUNANAGAR vs. DCIT, YAMUNANAGAR

In the result, the assessee’s appeals, for both the years, stand dismissed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.824/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 2. आयकर अपील सं. / Ita No.825/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) The Ved Prakash Mukand Lal Dcit Educational Society Circle Yamuna Nagar बनाम/ Vs. (Radaur, Yamuna Nagar) Haryana C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : & 3. आयकर अपील सं. / Ita No.833/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 4. आयकर अपील सं. / Ita No.832/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) Dcit The Ved Prakash Mukand Lal Circle Yamuna Nagar Educational Society बनाम/ Haryana (Radaur, Yamuna Nagar) Vs. C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Tejmohan Singh (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Yamini (Cit) - Ld. Dr (Virtual)

disallowance of carry forward of excess expenditure over its income for the earlier year to be adjusted in the subsequent year. 5. The learned CIT(A) by a common order dated 31.07.2014 has refused to accept the ground challenging the reopening and the issue of carry forward of excess expenditure over the income in the subsequent year. The learned

THE VED PRAKASH MUKAND LAL EDUCATIONAL SOCIETY,YAMUNANAGAR vs. DCIT, YAMUNANAGAR

In the result, the assessee’s appeals, for both the years, stand dismissed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.824/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 2. आयकर अपील सं. / Ita No.825/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) The Ved Prakash Mukand Lal Dcit Educational Society Circle Yamuna Nagar बनाम/ Vs. (Radaur, Yamuna Nagar) Haryana C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : & 3. आयकर अपील सं. / Ita No.833/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 4. आयकर अपील सं. / Ita No.832/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) Dcit The Ved Prakash Mukand Lal Circle Yamuna Nagar Educational Society बनाम/ Haryana (Radaur, Yamuna Nagar) Vs. C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Tejmohan Singh (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Yamini (Cit) - Ld. Dr (Virtual)

disallowance of carry forward of excess expenditure over its income for the earlier year to be adjusted in the subsequent year. 5. The learned CIT(A) by a common order dated 31.07.2014 has refused to accept the ground challenging the reopening and the issue of carry forward of excess expenditure over the income in the subsequent year. The learned

DCIT vs. M/S THE VED PARKASH MUKAND LAL, YAMUNANAGAR

In the result, the assessee’s appeals, for both the years, stand dismissed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.824/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 2. आयकर अपील सं. / Ita No.825/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) The Ved Prakash Mukand Lal Dcit Educational Society Circle Yamuna Nagar बनाम/ Vs. (Radaur, Yamuna Nagar) Haryana C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : & 3. आयकर अपील सं. / Ita No.833/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 4. आयकर अपील सं. / Ita No.832/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) Dcit The Ved Prakash Mukand Lal Circle Yamuna Nagar Educational Society बनाम/ Haryana (Radaur, Yamuna Nagar) Vs. C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Tejmohan Singh (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Yamini (Cit) - Ld. Dr (Virtual)

disallowance of carry forward of excess expenditure over its income for the earlier year to be adjusted in the subsequent year. 5. The learned CIT(A) by a common order dated 31.07.2014 has refused to accept the ground challenging the reopening and the issue of carry forward of excess expenditure over the income in the subsequent year. The learned

DEPUTY COMMISSIONER OF INCOME TAX, YAMUNANAGAR vs. M/S THE VED PARKASH MUKAND LAL, YAMUNANAGAR

In the result, the assessee’s appeals, for both the years, stand dismissed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.824/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 2. आयकर अपील सं. / Ita No.825/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) The Ved Prakash Mukand Lal Dcit Educational Society Circle Yamuna Nagar बनाम/ Vs. (Radaur, Yamuna Nagar) Haryana C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : & 3. आयकर अपील सं. / Ita No.833/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 4. आयकर अपील सं. / Ita No.832/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) Dcit The Ved Prakash Mukand Lal Circle Yamuna Nagar Educational Society बनाम/ Haryana (Radaur, Yamuna Nagar) Vs. C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Tejmohan Singh (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Yamini (Cit) - Ld. Dr (Virtual)

disallowance of carry forward of excess expenditure over its income for the earlier year to be adjusted in the subsequent year. 5. The learned CIT(A) by a common order dated 31.07.2014 has refused to accept the ground challenging the reopening and the issue of carry forward of excess expenditure over the income in the subsequent year. The learned

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)

36,792/- was received from The Haryana State Co-operative Bank, which is also a co-operative society. Thus, the total exempt income aggregating to Rs.7,53,72,632/- was claimed as eligible for deduction under section 80P(2)(d). However, the assessee, on its own computation, restricted the deduction claim to Rs.7,11,15,902/- after voluntarily disallowing

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)

36,792/- was received from The Haryana State Co-operative Bank, which is also a co-operative society. Thus, the total exempt income aggregating to Rs.7,53,72,632/- was claimed as eligible for deduction under section 80P(2)(d). However, the assessee, on its own computation, restricted the deduction claim to Rs.7,11,15,902/- after voluntarily disallowing

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)

36,792/- was received from The Haryana State Co-operative Bank, which is also a co-operative society. Thus, the total exempt income aggregating to Rs.7,53,72,632/- was claimed as eligible for deduction under section 80P(2)(d). However, the assessee, on its own computation, restricted the deduction claim to Rs.7,11,15,902/- after voluntarily disallowing

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)

disallowance under section 36(1)(iii) of interest to the extent of interest not taken. ० Post 'Abhishek Industries' (supra), according to 'Bright Enterprises' (dated 24.7.2015) (supra) [on having considered 'Abhishek Industries' (supra) and having followed 'SA Builders' (supra)], to allow the interest as deduction under section 36(1)(iii), the real test is that it was commercial expediency which

SBS BIOTECH UNIT II,SIRMOUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX-1, CHANDIGARH

In the result, the appeal of the assessee is allowed

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

disallowed and charged to tax and the assessee was given an opportunity to explain as to why the assessment order passed u/s 147 r.w.s. 144B of the Act dated 30.03.2022 by the AO for the A.Y. 2017-18 may not be cancelled and the AO may not be directed to make a fresh assessment. 5. In response to the show

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