SHOBHA SHARMA,SIRSA vs. ITO-WARD-3, SIRSA

In the result, appeal of the assessee is allowed

disallowance of claim of deduction by Rs. 29,87,000/- u/s 54F of the Act. 2.1 That finding and conclusion that "assessee had not furnished a return of income for the instant assessment year under section 139(1) of the Act and even under section 139(4

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

section 13 (l)(c) (ii) of the benefit of exemption should be denied only to the extent of the benefit provided. 15. We hold that the amount of Rs. 11,33,022/- kept by the Chairman of the assessee Trust Shri Anshu Kataria in his own bank account is to be disallowed. Accordingly, from the confirmed addition of Rs. 4

THE BALDUHAK CO-OPERATIVE AGRICULTURE SERVICE SOCIETY LTD.,HAMIRPUR vs. ITO, WARD, HAMIRPUR

Bench: Us Are That The Assessee Is A Cooperative

disallowance claimed by the assessee society under section 80P(2)(d) of the Act amounting to Rs. 20,51,316/-. 4

THE MANDEBAR PRIMARY AGRICULTURE CO-OPERATIVE SOCIETY LIMITED,YAMUNANAGAR vs. ITO, WARD -5, YAMUNA NAGAR

Bench: Us Are That The Assessee Is A Primary Agricultural Cooperative Society Engaged In Providing Credit Facilities To Its Members For Agricultural Operations & Procurement Of Fertilizers For The Purpose Of Supplying It To Its Members. 3.1 During The Year Under Consideration, It Filed Its Return Of Income Claiming Deduction Under Section 80P Amounting To Rs. 40,87,123/- & Which Includes Deduction Amounting To Rs. 29,44,171/- In Respect Of Interest Income On Deposits Placed With Yamunanagar District Central Cooperative Bank.

section 80P(2)(d) of the Act. 3.3 Here, it is relevant to examine the reasoning adopted by the AO while disallowing the said claim. Referring to the Hon’ble Supreme Court decision in case of Totagars Co-operative sale society Ltd. 322 ITR 283, the AO held that the assessee has earned interest income on surplus funds deposited with

ASSTT.COMMISSIONER OF INCOME TAX, LUDHIANA vs. M/S MRS.BECTORS FOOD SPECILTIES LTD, LUDHIANA

Bench: Smt. Diva Singh & Dr. B.R.R. Kumar

disallowance of Section 80IB on NOIDA Unit (SSI):- A.Y. 2007-08: Ground No. 4 of the Revenue’s appeal A.Y. 2008-09: Ground

ASSTT.COMMISSIONER OF INCOME TAX, LUDHIANA vs. M/S MRS.BECTORS FOOD SPECILTIES LTD, LUDHIANA

Bench: Smt. Diva Singh & Dr. B.R.R. Kumar

disallowance of Section 80IB on NOIDA Unit (SSI):- A.Y. 2007-08: Ground No. 4 of the Revenue’s appeal A.Y. 2008-09: Ground

ASSTT.COMMISSIONER OF INCOME TAX, LUDHIANA vs. M/S MRS.BECTORS FOOD SPECILTIES LTD, LUDHIANA

Bench: Smt. Diva Singh & Dr. B.R.R. Kumar

disallowance of Section 80IB on NOIDA Unit (SSI):- A.Y. 2007-08: Ground No. 4 of the Revenue’s appeal A.Y. 2008-09: Ground

ASSTT.COMMISSIONER OF INCOME TAX, LUDHIANA vs. M/S MRS.BECTORS FOOD SPECILTIES LTD, LUDHIANA

Bench: Smt. Diva Singh & Dr. B.R.R. Kumar

disallowance of Section 80IB on NOIDA Unit (SSI):- A.Y. 2007-08: Ground No. 4 of the Revenue’s appeal A.Y. 2008-09: Ground

ACIT, LUDHIANA vs. M/S MRS. BECTORS FOOD SPECIALTIES PVT. LTD., LUDHIANA

Bench: Smt. Diva Singh & Dr. B.R.R. Kumar

disallowance of Section 80IB on NOIDA Unit (SSI):- A.Y. 2007-08: Ground No. 4 of the Revenue’s appeal A.Y. 2008-09: Ground

ASSTT.COMMISSIONER OF INCOME TAX, LUDHIANA vs. M/S MRS.BECTORS FOOD SPECILTIES LTD, LUDHIANA

Bench: Smt. Diva Singh & Dr. B.R.R. Kumar

disallowance of Section 80IB on NOIDA Unit (SSI):- A.Y. 2007-08: Ground No. 4 of the Revenue’s appeal A.Y. 2008-09: Ground

SHRI BALRAM KRISHAN,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH, CHANDIGARH

Section 132 of the Act in Scott Edil Group of cases on 15.11.2017. Since the facts involved in all these captioned appeals are identical and there are common issues, hence the same were heard together and the same are being disposed of by this common order. 2. The grounds/issues raised in all the appeals are summarized as under

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), CHANDIGARH, CHANDIGARH vs. UNIPRO TECHNO INFRASTRUCTURE PVT LTD, CHANDIGARH

In the result, the order of the ld CIT(A) is confirmed and the grounds of appeal taken by the Revenue are dismissed

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

section 80IA has been accordingly disallowed. 4. Being aggrieved, the assessee carried the matter in appeal before the Ld. CIT(A) who has allowed

A.B. SUGARS LIMITED,PUNJAB 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)

Section 80IA and compliance of the assessee in harmony with the decisions of the Hon'ble Madras High Court in the cases mentioned in clause 4(b) (supra) the deduction u/s 80IA(4)(iv) claimed by the assessee to determine if any excess deduction has been claimed and to disallow

A.B. SUGARS LIMITED,PUNJAB vs. PRINCIPAL COMMISSIONER OF INCOME TAX -1, CHANDIGARH, CHANDIGARH

In the result, the appeal of the assessee is allowed

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

Section 80IA and compliance of the assessee in harmony with the decisions of the Hon'ble Madras High Court in the cases mentioned in clause 4(b) (supra) the deduction u/s 80IA(4)(iv) claimed by the assessee to determine if any excess deduction has been claimed and to disallow

DCIT, C-1(1), CHANDIGARH vs. UNIPRO TECHNO INFRASTRUCTURE PRIVATE LIMITED, CHANDIGARH

In the result, appeal of the Department is dismissed

disallowance cannot be made where there is no exempt income without appreciating the fact that applicability of section 14A or Rule 8D does not depend on earning of income as held by Supreme Court in the case of CIT vs. Rajender Prasad Moody (1978), 115 ITR 519. 4

SMT. AARTI SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-

section 132(4) of the Act after confronting various documents of incriminating In the cases of Shri Sanjay Singhal and Others Vs. DCIT, Chandigarh (9 Appeals) 49 nature and the statement recorded of various persons. Thus, the admission by the assessee in itself is a vital piece of evidence that the group of the assessee has generated huge bogus long

SH. ANIKET SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-

section 132(4) of the Act after confronting various documents of incriminating In the cases of Shri Sanjay Singhal and Others Vs. DCIT, Chandigarh (9 Appeals) 49 nature and the statement recorded of various persons. Thus, the admission by the assessee in itself is a vital piece of evidence that the group of the assessee has generated huge bogus long

SMT. AARTI SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-

section 132(4) of the Act after confronting various documents of incriminating In the cases of Shri Sanjay Singhal and Others Vs. DCIT, Chandigarh (9 Appeals) 49 nature and the statement recorded of various persons. Thus, the admission by the assessee in itself is a vital piece of evidence that the group of the assessee has generated huge bogus long