THE JAGADHRI CO-OPERATIVE MARKETING CUM PROCESSING SOCIETY LTD.,JAGADHRI vs. THE PR.CIT, PANCHKULA

In the result, the appeal of the assessee is allowed

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

disallowance of the deduction claimed which on appeal has been allowed by the Tribunal and thereafter, the question of law which was proposed by the Revenue for the opinion of the Hon’ble High Court was “whether on the facts and circumstances of the case, the Tribunal is right in law in allowing deduction under section 80P(2)(d

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

disallowance of deduction amounting to Rs. 16,21,458/- under section 80P(2)(d) of the Act, 2. None appeared on behalf of the assessee nor has any adjournment application been filed. Considering the issue involved in the matter, it was decided to proceed based on the written submissions dt. 31/07/2025 filed by the assessee’s Counsel, Shri Sanjeev Mishra

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

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. 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

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

4 accepting the donations. Hence, it is not hit by Section 13(1)(c) as well as 13(1)(d) of the Act. The Tribunal has directed the AO to grant benefit of Section 11 and 12 of the Act. In other words, if 85% of the income derived by the assessee Trust is being applied towards its objective

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

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

section 36(1) (iii) of the Act on the ground that the assessee company has given loan/advance to M/s Hero Exports (P) Limited and M/s Munjal Hospitality (P) Limited allegedly out of borrowed funds and that too for non-business purposes. The reasons for making the impugned addition have been given in detail in para 7 of the assessment order

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)

4 the 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

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)

4 the 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

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)

4 the 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

CHANDIGARH EDUCATIONAL TRUST,MOHALI vs. PR.CIT-CENTRAL,GURGAON, AT CHANDIGARH

d) of the Act, tax shall be charged on the relevant income or part of relevant income, at the maximum marginal rate, the Ld. Pr. CIT observed that the judgments relied by the assessee related to the period when the provisions of section 12AA(4) of the Act was not in the statute which was inserted w.e.f 01/10/2014

CHANDIGARH EDUCATIONAL SOCIETY,MOHALI vs. PR.CIT(CENTRAL)-GURGAON, AT CHANDIGARH

d) of the Act, tax shall be charged on the relevant income or part of relevant income, at the maximum marginal rate, the Ld. Pr. CIT observed that the judgments relied by the assessee related to the period when the provisions of section 12AA(4) of the Act was not in the statute which was inserted w.e.f 01/10/2014

SHRI GURU RAM DASS EDUCATIONAL SOCIETY,MOHALI vs. PR.CIT(CENTRAL) GURGAON, AT CHANDIGARH

d) of the Act, tax shall be charged on the relevant income or part of relevant income, at the maximum marginal rate, the Ld. Pr. CIT observed that the judgments relied by the assessee related to the period when the provisions of section 12AA(4) of the Act was not in the statute which was inserted w.e.f 01/10/2014

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)

4). The Ld. counsel for the assessee stated that review of the order was only on account of change of opinion and could not be exercised under section 263 of the Act. In support of its contention that the issue had been examined by the AO during assessment proceedings the Ld. counsel for the assessee drew our attention

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

Disallowance of 80IC on subsidy claimed in ITR.\nIssue 18 : Jewellery found at House no 2273, Sector 21C, Chandigarh & Locker no\n64, Bank of India, Sector 35, Chandigarh during the search

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

In the result, appeal of the Department is dismissed

4). The Ld. counsel for the assessee stated that review of the order was only on account of change of opinion and could not be exercised under section 263 of the Act. In support of its contention that the issue had been examined by the AO during assessment proceedings the Ld. counsel for the assessee drew our attention

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)

D. Reply submitted to the TPO and AO during the Assessment: a) Transfer Pricing Officer (TPO) Replies 1. Notice dated 21.06.2021- Reply dated 05.07.2021 and 10.07.2021 along with Annexures. (Page no. 1-236) ii. Notice dated 30.06.2021- Reply dated 08.07.2021(Page no. 237-244) iii. Notice dated 10.07.2021- Reply dated 13.07.2021 along with Annexures. (Page no. 245-299) Iv. Notice