SAHIBZADA TIMBER AND PLY PRIVATE LIMITED ,MOHALI vs. DCIT, ACIT CENTRAL CIRCLE-2, CHANDIGARH, CHANDIGARH

In the result, the appeal of the assessee is dismissed

Bench: SHRI. VIKRAM SINGH YADAV, AM आयकर अपील सं./ ITA No. 699/Chd/2024 निर्धारण वर्ष / Assessment Year : 2019-20 M/s Sahibzada Timber & Ply Private Limited B41-42, Phase-3, Indl. Aera, SAS Nagar Mohali, Punjab बनाम The DCIT Central Circle-2 Chandigarh स्थायी लेखा सं./PAN NO: AAQCS2239G अपीलार्थी/Appellant प्रत्यर्थी/Respondent निर्धारिती की ओर से/Assessee by : Shri Mohit Dhiman, C.A राजस्व की ओर से/ Revenue by : Dr. Ranjeet Kaur, Sr. DR Shri Dharam Vir, Addl. CIT, Sr.DR सुनवाई की तारीख/Date of He

disallowed loss on sale of capital asset amounting to Rs. 25,75,000/- without bringing on record any material to prove that the Appellant had violated the provisions of section 50C of the Income Tax Act, which provides for the fair market value to be adopted in case of transfer(sale) of immovable property, being land or building or both

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), CHANDIGARH vs. ESSIX BIOSCIENCES LIMITED, MANIMAJRA

In the result, the appeal is dismissed and the

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

disallowance under Section 14A to Rs. 48,48,000/- despite the fact that assessee has earned the exempt income of Rs. 7,12,442/- during

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

In the result, we upheld the

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

48,177/- which is not allowable under section 36 of the Act. Further the assessee has not deducted TDS under section 194A of the Act. Hence, the provision so made was also held disallowable

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 made by the assessee suo-moto under\nrule 8D(2)(iii), the same is to be restricted to Rs. 91,61,536/- as against Rs.\n2,94,48,717/- and the assessee is entitled to a relief of Rs. 2,02,87,181/—.\niii) The appellant is thus entitled to a total relief

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)

disallowance under Section 14A to Rs. 48,48,000/- despite the fact that assessee has earned the exempt income of Rs. 7,12,442/- during

AMAN THUKRAL,LUDHIANA vs. INCOME TAX OFFICER WARD 2(1), LUDHIANA , LUDHIANA

Accordingly, Additional Ground No. 1 is allowed for statistical

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

section 69C are not applicable in the case of appellant. 5. That the Ld. CIT(A), NFAC, Delhi has failed to appreciate that the Ld. AO has wrongly disallowed a sum of Rs. 28,48

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

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)

48,92,749/- - 1,29,51,059 = 1,19,41,690/- 2. Misc. Expenses = 2,46,72,893 – 1,13,73,255 = 1,32,99,638/- = 2,52,41,328 Total 2.15 The Ld. AO in para 5.5 of the assessment order dt. 30/12/2018 has finally held as under basis aforesaid:- “Therefore in pursuance of the directions

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)

48,92,749/- - 1,29,51,059 = 1,19,41,690/- 2. Misc. Expenses = 2,46,72,893 – 1,13,73,255 = 1,32,99,638/- = 2,52,41,328 Total 2.15 The Ld. AO in para 5.5 of the assessment order dt. 30/12/2018 has finally held as under basis aforesaid:- “Therefore in pursuance of the directions

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)

48,92,749/- - 1,29,51,059 = 1,19,41,690/- 2. Misc. Expenses = 2,46,72,893 – 1,13,73,255 = 1,32,99,638/- = 2,52,41,328 Total 2.15 The Ld. AO in para 5.5 of the assessment order dt. 30/12/2018 has finally held as under basis aforesaid:- “Therefore in pursuance of the directions

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)

48,92,749/- - 1,29,51,059 = 1,19,41,690/- 2. Misc. Expenses = 2,46,72,893 – 1,13,73,255 = 1,32,99,638/- = 2,52,41,328 Total 2.15 The Ld. AO in para 5.5 of the assessment order dt. 30/12/2018 has finally held as under basis aforesaid:- “Therefore in pursuance of the directions

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)

48,92,749/- - 1,29,51,059 = 1,19,41,690/- 2. Misc. Expenses = 2,46,72,893 – 1,13,73,255 = 1,32,99,638/- = 2,52,41,328 Total 2.15 The Ld. AO in para 5.5 of the assessment order dt. 30/12/2018 has finally held as under basis aforesaid:- “Therefore in pursuance of the directions

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)

48,92,749/- - 1,29,51,059 = 1,19,41,690/- 2. Misc. Expenses = 2,46,72,893 – 1,13,73,255 = 1,32,99,638/- = 2,52,41,328 Total 2.15 The Ld. AO in para 5.5 of the assessment order dt. 30/12/2018 has finally held as under basis aforesaid:- “Therefore in pursuance of the directions

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)

48,92,749/- - 1,29,51,059 = 1,19,41,690/- 2. Misc. Expenses = 2,46,72,893 – 1,13,73,255 = 1,32,99,638/- = 2,52,41,328 Total 2.15 The Ld. AO in para 5.5 of the assessment order dt. 30/12/2018 has finally held as under basis aforesaid:- “Therefore in pursuance of the directions

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)

48,92,749/- - 1,29,51,059 = 1,19,41,690/- 2. Misc. Expenses = 2,46,72,893 – 1,13,73,255 = 1,32,99,638/- = 2,52,41,328 Total 2.15 The Ld. AO in para 5.5 of the assessment order dt. 30/12/2018 has finally held as under basis aforesaid:- “Therefore in pursuance of the directions

SH. RAJINDER SINGH BEDI,CHANDIGARH vs. DCIT (INTL. TAXATION), CHANDIGARH

In the result, appeal of the assessee is allowed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 538/Chd/2022 "नधा"रण वष" / Assessment Year: 2018-19 Shri Rajinder Singh Bedi, The Dcit, (Int.Taxation ), 1368, Sector 40-B, Vs Chandigarh. Chandigarh. "थायी लेखा सं./Pan No: Afwpb3355A अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Sudhir Sehgal, Advocate Revenue By : Smt. Kusum Bansal, Cit, Dr Date Of Hearing : 09.04.2025 Date Of Pronouncement : 04.06.2025 Hybrid Hearing O R D E R

section 144C(2)(b) of the Income Tax 1961 on 28.10.2021 before Dispute Resolution Panel-1, Delhi, against the draft order no. ITBA/AST/F/144C/2021-22/1036004460(1) dated 29.09.2021 for AY 2018-19. The draft order u/s 144C of the Income Tax Act 1961 was forwarded to the assessee on 29.09.2021, in relation to the assessment order proposed to be passed

M/S STYLAM INDUSTRIES LTD.,CHANDIGARH vs. DCIT, C-1(1), CHANDIGARH

In the result, the Department’s appeal in for assessment year

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

48,160/- made u/s 40(a)(ia) on account of non-deduction of TDS ignoring the detailed finding of the assessing officer that as per section 5 and section 9 of the Act the income is deemed to accrue or arise in India even if the services by the commission agents have been rendered abroad. Further since the right

DCIT, C-1(1), CHANDIGARH vs. M/S STYLAM INDUSTRIES LTD., CHANDIGARH

In the result, the Department’s appeal in for assessment year

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

48,160/- made u/s 40(a)(ia) on account of non-deduction of TDS ignoring the detailed finding of the assessing officer that as per section 5 and section 9 of the Act the income is deemed to accrue or arise in India even if the services by the commission agents have been rendered abroad. Further since the right