THE JYOTI CO-OPERATIVE NON AGRICULTURAL THRIFT & CREDIT SOCIETY LTD.,SIRMOUR vs. ITO, WARD, NAHAN

In the result, the assessee is not eligible for deduction on interest on deposits placed with scheduled commercial banks under section 80(P)(2)(a)(i) of the Act and the appeal of the assessee is di...

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member)

55 taxmann.com 447/230 Taxman 309 (Karnataka) and Guttigedarara Credit Co-operative Society Ltd. v. ITO [2015] 60 taxmann.com 215/234 Taxman 476 (Kar.), which are also relied upon by the appellant in the present case. 9.7 Further, the appellant has relied on the decision of the Hon'ble Ahmedabad ITAT in the case of the ITO, Ward-2 vs, Jafari Momin

THE JYOTI CO-OPERATIVE NON AGRICULTURAL THRIFT & CREDIT SOCIETY LTD.,SIRMOUR vs. ITO, WARD, NAHAN

In the result, the assessee is not eligible for deduction on interest on deposits placed with scheduled commercial banks under section 80(P)(2)(a)(i) of the Act and the appeal of the assessee is di...

Bench: SHRI. VIKRAM SINGH YADAV, AM आयकर अपील सं . / ITA No.160, 161 & 162/ Chd/2023 निर्धारण वर्ष / Assessment Year : 2017-18, 2012-13 & 2013-14 The Jyoti Co-operative Non Agricultural Thrift & Credit Society Ltd. Sirmour, Solan, HP-173025 स्थायी लेखा सं. / PAN NO: AAABT1453G अपीलार्थी/Appellant बनाम The ITO H.P Ward-Nahan, Sirmour प्रत्यर्थी/Respondent निर्धारिती की ओर से/Assessee by : Shri Vishal Mohan, Sr. Advocate with Shri Parveen Sharma, Advocate राजस्व की ओर से / Revenue by : Dr. Ranjeet K

55 taxmann.com 447/230 Taxman 309 (Karnataka) and Guttigedarara Credit Co-operative Society Ltd. v. ITO [2015] 60 taxmann.com 215/234 Taxman 476 (Kar.), which are also relied upon by the appellant in the present case. 9.7 Further, the appellant has relied on the decision of the Hon'ble Ahmedabad ITAT in the case of the ITO, Ward-2 vs, Jafari Momin

THE JYOTI CO-OPERATIVE NON AGRICULTURAL THRIFT & CREDIT SOCIETY LTD.,SIRMOUR vs. ITO, WARD, NAHAN

In the result, the assessee is not eligible for deduction on interest on deposits placed with scheduled commercial banks under section 80(P)(2)(a)(i) of the Act and the appeal of the assessee is di...

55 taxmann.com 447/230 Taxman 309 (Karnataka) and Guttigedarara Credit Co-operative Society Ltd. v. ITO [2015] 60 taxmann.com 215/234 Taxman 476 (Kar.), which are also relied upon by the appellant in the present case. 9.7 Further, the appellant has relied on the decision of the Hon'ble Ahmedabad ITAT in the case of the ITO, Ward-2 vs, Jafari Momin

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

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

Section 36(1) (iii). In para 4 the AO made disallowance of interest\nu/s 14A at Rs. 141510213/-, in para 6 made disallowance of interest u/s\n36(1)(iii) at Rs. 40,22,065/- on account of outstanding debit balances\nfrom M/s Hero Exports Pvt. Ltd. and M/s Hero Motors Ltd. and further in\npara 7 made disallowance

THE INSTITUTION OF CIVIL ENGINEERS SOCIETY,LUDHIANA vs. ACIT, EXEMPTIONS, C-1, CHANDIGARH

In the result, appeal of the assessee is partly allowed for statistical purposes

55,014/- in the year 2014. The assessee had taken benefit u/s 11(2) of the Act in these earlier years when the accumulation was made. This issue was also discussed with the authorised representative of the assessee, Sh. Harinder Pal Singh, Advocate, as noted vide order sheet entry dated 26.11.2018. While the assessee is required to use the accumulated

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)

2 which was that the Ld. DCIT has wrongly disallowed a sum of Rs. 2909091/- under section 14A and added back “Rs. 10,43,765/-“ u/s 14A to the returned income after substracting the suomotto disallowance of Rs. 18,55

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)

2 which was that the Ld. DCIT has wrongly disallowed a sum of Rs. 2909091/- under section 14A and added back “Rs. 10,43,765/-“ u/s 14A to the returned income after substracting the suomotto disallowance of Rs. 18,55

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)

2 which was that the Ld. DCIT has wrongly disallowed a sum of Rs. 2909091/- under section 14A and added back “Rs. 10,43,765/-“ u/s 14A to the returned income after substracting the suomotto disallowance of Rs. 18,55

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)

2 which was that the Ld. DCIT has wrongly disallowed a sum of Rs. 2909091/- under section 14A and added back “Rs. 10,43,765/-“ u/s 14A to the returned income after substracting the suomotto disallowance of Rs. 18,55

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)

2 which was that the Ld. DCIT has wrongly disallowed a sum of Rs. 2909091/- under section 14A and added back “Rs. 10,43,765/-“ u/s 14A to the returned income after substracting the suomotto disallowance of Rs. 18,55

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)

2 which was that the Ld. DCIT has wrongly disallowed a sum of Rs. 2909091/- under section 14A and added back “Rs. 10,43,765/-“ u/s 14A to the returned income after substracting the suomotto disallowance of Rs. 18,55

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)

2 which was that the Ld. DCIT has wrongly disallowed a sum of Rs. 2909091/- under section 14A and added back “Rs. 10,43,765/-“ u/s 14A to the returned income after substracting the suomotto disallowance of Rs. 18,55

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)

2 which was that the Ld. DCIT has wrongly disallowed a sum of Rs. 2909091/- under section 14A and added back “Rs. 10,43,765/-“ u/s 14A to the returned income after substracting the suomotto disallowance of Rs. 18,55

KANDI FRIENDS EDUCATIONAL TRUST,ROPAR vs. DEPUTY COMMISSION OF INCOME TAX, CL. 1, EXEMPTION, CHANDIGARH

In the result, both the appeals are allowed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahay

disallowed to the assessee and benefit of Section 11 would not be available on such an amount. It will be taxable. For example, assessee can purchase an item for Rs.100/- but from a specified person, it has purchased at Rs.120/-, then this excess Rs.20/- will be added to the taxable income of the assessee and benefit of Section 11 will

KANDI FRIENDS EDUCATIONAL TRUST,ROPAR vs. DEPUTY COMMISSIONER OF INCOME TAX, CHANDIGARH

In the result, both the appeals are allowed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahay

disallowed to the assessee and benefit of Section 11 would not be available on such an amount. It will be taxable. For example, assessee can purchase an item for Rs.100/- but from a specified person, it has purchased at Rs.120/-, then this excess Rs.20/- will be added to the taxable income of the assessee and benefit of Section 11 will

MUNISH KUMAR LEGAL HEIR LATE SH GURDEEP SINGH,VILL MANAKPUR, YAMUNANAGAR vs. ITO, WARD 5, YAMUNANAGAR

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

disallowance. 5. On examination of assessment records, the Ld. Pr. CIT noticed that during the relevant year, the assessee had received an interest amounting to Rs. 1,05,10,592/- on enhanced compensation arising from the acquisition of land. The Assessing Officer had treated the said receipt as exempt and did not bring the same to tax. 6. According

RAKESH KUMAR,JAGADHRI vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, PANCHKULA

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

disallowance. 5. On examination of assessment records, the Ld. Pr. CIT noticed that during the relevant year, the assessee had received an interest amounting to Rs. 1,05,10,592/- on enhanced compensation arising from the acquisition of land. The Assessing Officer had treated the said receipt as exempt and did not bring the same to tax. 6. According

PARVEEN KUMAR,229,VILLAGE MANAKPUR-II,TEHSIL JAGADHRI,HARYANA vs. PRABHJOT KAUR,PCIT PANCHKULA, CHANDIGARH

In the result, all the above appeals filed by the respective assessee’s are dismissed

Bench: the Tribunal as pointed out by the Registry. Considering that the issue involved is purely legal in nature, and respectfully following the ratio laid down by the Hon'ble Supreme Court in Collector, Land Acquisition v. Mst. Katiji & Others [(1987) 167 ITR 471 (SC)], which emphasizes that substantial justice should prevail over technical considerations, we condone the delay in filing these appeals.3. We shall take appeal of the assessee in ITA No. 167/Chd/2023 for A.Y 2018-19 as a lead case f

disallowance. 5. On examination of assessment records, the Ld. Pr. CIT noticed that during the relevant year, the assessee had received an interest amounting to Rs. 1,05,10,592/- on enhanced compensation arising from the acquisition of land. The Assessing Officer had treated the said receipt as exempt and did not bring the same to tax. 6. According