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)

1)(iii) of the Act provides that “the amount of the interest paid in respect of capital borrowed for the purposes of the business or profession” has to be allowed as a deduction in computing the income under Section 280 of the Act. It was further noted by the Apex Court that the expression “for the purpose of business

DCIT, C-1 (EXEMPTIONS), CHANDIGARH vs. THE INSTITUTION OF CIVIL ENGINEERS SOCIETY, LUDHIANA

In the result, appeal of the Revenue is dismissed

65\ntaxmann.com 95 (Hyderabad - Trib.) has held that:\n12\n\"Section 13, read with section 11 of the Income-tax Act, 1961 - Charitable or\nreligious trust - Denial of exemption (Sub-section (l)(c)) - Assessment year 2011-\nAssessee-society claimed exemption under section 11 - Assessing Officer\nconcluded that quantum jump in payment of salary to its executive director in\n assessment

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

65,94,302 Total Taxable income 5,23,74,106 ITA Nos. 797 & 798/CHD/2024 A.Y.2014-15 & 2015-16 4 Assessment year 2015-16 Particular Amount (In INR) Returned Income Nil Disallowance of Honorarium (Rs. 30,61,129/-) 1,07,39,814 and travelling and conveyance expense along with cost of vehicles (Rs. 76,78,685/-) Disallowance of Interest on Advances

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

65,94,302 Total Taxable income 5,23,74,106 ITA Nos. 797 & 798/CHD/2024 A.Y.2014-15 & 2015-16 4 Assessment year 2015-16 Particular Amount (In INR) Returned Income Nil Disallowance of Honorarium (Rs. 30,61,129/-) 1,07,39,814 and travelling and conveyance expense along with cost of vehicles (Rs. 76,78,685/-) Disallowance of Interest on Advances

ASHISH SOOD,ZIRAKPUR vs. THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), CHANDIGARH, CHANDIGARH

In the result, appeal of the Assessee is allowed for statistical purposes

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

65,39,120/- wherein total tax paid is shown as Rs. 4,93,295/-. 4. In computation of total income (revised) an amount of Rs. 7,70,863/- is claimed as eligible deductible under section 90/91 of the Income Tax Act, 1961 as amended from time to time. In support of such eligible deductible claim under section 90/91

SH. AMAN SETH,LUDHIANA vs. ITO, W-1(1), LUDHIANA

In the result, appeal filed by the assessee is allowed for statistical purposes

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

section 36 (1)(iii) of the Income Tax Act, 1961 being use for non business purpose.” The said finding of Ld. AO is sustained by CIT(A) too. Now it is not open for Ld. AR to turn around and contend otherwise. In any event even on merits the assertion of Ld. AR is required to be tested in original

WINSOME TEXTILE INDUSTRIES LIMITED,CHANDIGARH vs. ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-4(1), CHANDIGARH, CHANDIGARH

In the result, the appeal of the assessee is partly allowed and the appeal of the Revenue is dismissed

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

65,94,005/-). In addition, the AO also treated the GDR receipt of Rs. 6,45,00,000/-being share capital and Rs. 38,30,88,075/- being security premium totaling to Rs. 44,75,88,075/- as income from undisclosed sources and which was brought to tax by invoking the provisions of Section

ACIT, CIRCLE 1(1), CHANDIGARH vs. M/S SML ISUZU LTD., CHANDIGARH

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

65,85,400/- after making the disallowance of bad debts written off during the year. The order of Ld. AO bears No. ITBA/AST/S/147/2021-22/10359/30321(1) and is dated 27/09/2021. 8. That the assessee challenged the validity of the reassessment proceedings and the disallowance made by the AO in the aforesaid reassessment order dt. 27/09/2021 passed under section

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)

1) concerns income deemed to accrue or arise in India, the provisions of Section 195 are to be read in consonance with these two provisions. The AO holds that since the income of the assessee non-resident is deemed to accrue or arise in India, TDS under Section 195 is mandatory. 9.3 The AO holds that according to Sections

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)

1) concerns income deemed to accrue or arise in India, the provisions of Section 195 are to be read in consonance with these two provisions. The AO holds that since the income of the assessee non-resident is deemed to accrue or arise in India, TDS under Section 195 is mandatory. 9.3 The AO holds that according to Sections

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)

1) concerns income deemed to accrue or arise in India, the provisions of Section 195 are to be read in consonance with these two provisions. The AO holds that since the income of the assessee non-resident is deemed to accrue or arise in India, TDS under Section 195 is mandatory. 9.3 The AO holds that according to Sections

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)

1) concerns income deemed to accrue or arise in India, the provisions of Section 195 are to be read in consonance with these two provisions. The AO holds that since the income of the assessee non-resident is deemed to accrue or arise in India, TDS under Section 195 is mandatory. 9.3 The AO holds that according to Sections

KARNAIL SINGH,UK vs. JCIT (OSD) INTL. TAXATION, CIRCLE, CHANDIGARH

In the result, all the appeals of the assessee stands allowed

disallowed. It was submitted that non acceptance of the taxable amount does not means that the assessee has concealed particulars of his income or furnished inaccurate particulars of his income. It was submitted that during the course of assessment proceedings, all details as directed by the AO were filed reflecting the true nature and character of income and there

KARNAIL SINGH,UK vs. JCIT (OSD) INTL. TAXATION, CIRCLE, CHANDIGARH

In the result, all the appeals of the assessee stands allowed

disallowed. It was submitted that non acceptance of the taxable amount does not means that the assessee has concealed particulars of his income or furnished inaccurate particulars of his income. It was submitted that during the course of assessment proceedings, all details as directed by the AO were filed reflecting the true nature and character of income and there

KARNAIL SINGH,UK vs. JCIT (OSD) INTL. TAXATION, CIRCLE, CHANDIGARH

In the result, all the appeals of the assessee stands allowed

disallowed. It was submitted that non acceptance of the taxable amount does not means that the assessee has concealed particulars of his income or furnished inaccurate particulars of his income. It was submitted that during the course of assessment proceedings, all details as directed by the AO were filed reflecting the true nature and character of income and there

KARNAIL SINGH,UK vs. JCIT (OSD) INTL. TAXATION, CIRCLE, CHANDIGARH

In the result, all the appeals of the assessee stands allowed

disallowed. It was submitted that non acceptance of the taxable amount does not means that the assessee has concealed particulars of his income or furnished inaccurate particulars of his income. It was submitted that during the course of assessment proceedings, all details as directed by the AO were filed reflecting the true nature and character of income and there

KARNAIL SINGH,UK vs. JCIT (OSD) INTL. TAXATION, CIRCLE, CHANDIGARH

In the result, all the appeals of the assessee stands allowed

disallowed. It was submitted that non acceptance of the taxable amount does not means that the assessee has concealed particulars of his income or furnished inaccurate particulars of his income. It was submitted that during the course of assessment proceedings, all details as directed by the AO were filed reflecting the true nature and character of income and there

KARNAIL SINGH,UK vs. JCIT (OSD) INTL. TAXATION, CIRCLE, CHANDIGARH

In the result, all the appeals of the assessee stands allowed

disallowed. It was submitted that non acceptance of the taxable amount does not means that the assessee has concealed particulars of his income or furnished inaccurate particulars of his income. It was submitted that during the course of assessment proceedings, all details as directed by the AO were filed reflecting the true nature and character of income and there

ACIT, CIRCLE 1(1), CHANDIGARH vs. M/S SML ISUZU LTD., CHANDIGARH

In the result, the impugned order is sustained and appeal of the Revenue is partly allowed for statistical purposes

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

Disallowance of payment of bonus / Ex gratia made  14. During the year under consideration, the assessee company claimed deduction of amount aggregating to Rs.2,42,59,981, being payment of bonus / ex-gratia made after 31st March 2018 but before the due date of filing the return of income under section 139(1