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)

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 of the Hon'ble ITAT. the common expenses allocated between the exempt

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)

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 of the Hon'ble ITAT. the common expenses allocated between the exempt

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)

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 of the Hon'ble ITAT. the common expenses allocated between the exempt

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)

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 of the Hon'ble ITAT. the common expenses allocated between the exempt

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)

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 of the Hon'ble ITAT. the common expenses allocated between the exempt

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)

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 of the Hon'ble ITAT. the common expenses allocated between the exempt

M/S KNITWELL INDIA PVT. LTD.,CHANDIGARH vs. DCIT, C-1(1), CHANDIGARH

In the result, appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 1609/Chd/2018 "नधा"रण वष" / Assessment Year. : 2014-15 M/S Knitwell India Pvt. Ltd., The Dcit, Plot No. 278, Industrial Area, Vs Circle 1(1), Phase-Ii, Chandigarh. Chandigarh. "थायी लेखा सं./Pan No: Aacck4673L अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Ms. Shruti Khandelwal, Advocate Revenue By : Shri Vivek Vardhan, Addl. Cit Sr.Dr Date Of Hearing : 24.11.2025 Date Of Pronouncement : 27.01.2026 O R D E R Physical Hearing Per Raj Pal Yadav, Vp

Section 36(1)(iii) of the Income Tax Act. 4. The brief facts of the case are that assessee, at the relevant time was engaged in manufacturing of tractor parts, harvesting combine parts and fork lift parts. It has filed its return of income on 27.09.2014 declaring total taxable income of Rs.4,51,31,690/-. The case of the assessee

SH. DHARAM PAL AGGARWAL,LUDHIANA vs. ACIT, LUDHIANA

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

690/- 5.1 The A.O. asked the assessee to provide the breakup of deduction claimed under section 57 and draw nexus between the interest paid and received for the purpose of allowability of expenses under section 57 of the Act. The assessee submitted that no fresh loans had been raised during the year rather the loans had been squared

THE SURARWAN GAGWAN CO-OPERATIVE AGRICULTURE SERVICE SOCIETY LIMITED ,SURARWAN vs. LD. DCIT, CPC, CPC, BENGALURU

In the result, the appeal of the Assessee is allowed

Bench: Dr Krinwant Sahay & Shri Paresh M. Joshiआयकर अपील सं./ Ita No. 46/Chd/2024 "नधा"रण वष" / Assessment Year : 2017-18 The Surarwan Gagwan Co- Vs. The Ito, Operative Agriculture Service बनाम Ward, Society Limited, Nurpur (Palampur ) Surarwan Indora H.P. "थायी लेखा सं./Pan No: Aaact8925A अपीलाथ"/ Appellant ""यथ"/ Repsondent (Virtual Hearing) "नधा"रती क" ओर से/Assessee By : Sh. Vishan Mohan, Sr. Advocate With Sh Aditya Sood, Adv. राज"व क" ओर से/ Revenue By : Shri Dharam Vir, Jcit, Sr. Dr सुनवाई क" तार"ख/Date Of Hearing : 25.07.2024 उदघोषणा क" तार"ख/Date Of Pronouncement : 29.07.2024

disallowance of deduction claimed u/s 80P of the Income Tax Act, 1961 and that too under section 143(1) of the Income Tax Act, 1961. 2. That the order of the ld. Assessing Officer is bad in law and facts. 3. Brief facts of the case are that the return of income of Rs. 3,49,690

M/S SUSHIL KUMAR GUPTA & COMPANY,AMBALA CITY vs. 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)

690/-. Thereafter, the case of the assessee was selected for limited scrutiny and notice under section 143(2) dt. 28/09/2019 was issued on the issue of verification of genuineness of expenses and unsecured loans. Thereafter, notice under section 142(1) alongwith questionnaire were issued and after taking into consideration the reply submitted by the assessee, the assessment was completed under

NAHAR POLY FILMS LTD.,LUDHIANA vs. ACIT, C-7, LUDHIANA

In the result, both the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri N.K. Saini & Shri R.L Negiआयकर अपील सं./Ita Nos. 1414 & 1415/Chd/2019 "नधा"रणवष" / Assessment Years : 2011-12 & 2012-13 Nahar Poly Films Limited, The Acit, बनाम 376, Industrial Area, Circle 7, Aaykar Bhawan, Ludhiana Rishi Nagar, Ludhiana "थायी लेखा सं./Pan No: Aaacn5708K अपीलाथ"/Appellant ""यथ"/Respondent

section 143(3) of the Act and determined the total income at Rs. 9,80,25,690/- under the normal provisions of the Act inter alia making addition of Rs. 41,58,517/- u/s 14A of the Act read with Rule 8D of the Income Tax Rules

NAHAR POLY FILMS LTD.,LUDHIANA vs. ACIT, C-7, LUDHIANA

In the result, both the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri N.K. Saini & Shri R.L Negiआयकर अपील सं./Ita Nos. 1414 & 1415/Chd/2019 "नधा"रणवष" / Assessment Years : 2011-12 & 2012-13 Nahar Poly Films Limited, The Acit, बनाम 376, Industrial Area, Circle 7, Aaykar Bhawan, Ludhiana Rishi Nagar, Ludhiana "थायी लेखा सं./Pan No: Aaacn5708K अपीलाथ"/Appellant ""यथ"/Respondent

section 143(3) of the Act and determined the total income at Rs. 9,80,25,690/- under the normal provisions of the Act inter alia making addition of Rs. 41,58,517/- u/s 14A of the Act read with Rule 8D of the Income Tax Rules

JAI KARAN SINGH,MOHALI vs. INCOME TAX OFFICER, WARD-6(4), MOHALI , MOHALI

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

Bench: JUSTICE (RETD.) C.V. BHADANG (President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

690/- under the head “income from Salary” and “income from other sources” after claiming deduction under Chapter VIA of the Act. The case of the assessee was thereafter selected for scrutiny under CASS. AS per the AO, basis database and information in possession of the Revenue, the assessee has been maintaining an account in Punjab National Bank

M/S SHUBHAM COTTON MILLS PVT. LTD.,ELLENABAD vs. DCIT, CIRCLE, SIRSA

In the result appeal of the assessee is allowed

690 (SC) • State of Kerala Vs. C. Velukutty 60 ITR 239 (SC) • Kachwala Gems Vs. CIT 288 ITR 10 (SC) 8. In his rival submissions the Ld. DR strongly supported the orders of the authorities below and reiterated the observations made in their respective orders. It was further submitted that the assessee had shown the loss only in the post

M/S FASTWAY TRANSMISSION (P) LTD.,CHANDIGARH vs. DCIT, CC-II, CHANDIGARH

In the result the captioned appeals of the assessee are

Bench: Shri N.K. Saini & Shri Sanjay Gargआयकर अपील सं./ Ita No.547/Chd/2017 "नधा"रण वष" / Assessment Year : 2013-14

disallowance of the deduction claimed u/s 35D of the Act of 1/5 t h of the preliminary expenses amounting to Rs.2.40 crores. 45. The facts of the case are that the assessee had acquired 100% shares in a company ‘Cable Network Limited’ (CBSL) from its parent company which had owned 100% shares in it namely DIGI Western Network

M/S FASTWAY TRANSMISSION (P) LTD.,CHANDIGARH vs. DCIT, CC-II, CHANDIGARH

In the result the captioned appeals of the assessee are

Bench: Shri N.K. Saini & Shri Sanjay Gargआयकर अपील सं./ Ita No.547/Chd/2017 "नधा"रण वष" / Assessment Year : 2013-14

disallowance of the deduction claimed u/s 35D of the Act of 1/5 t h of the preliminary expenses amounting to Rs.2.40 crores. 45. The facts of the case are that the assessee had acquired 100% shares in a company ‘Cable Network Limited’ (CBSL) from its parent company which had owned 100% shares in it namely DIGI Western Network

M/S FASTWAY TRANSMISSION (P) LTD.,CHANDIGARH vs. ACIT, CHANDIGARH

In the result the captioned appeals of the assessee are

Bench: Shri N.K. Saini & Shri Sanjay Gargआयकर अपील सं./ Ita No.547/Chd/2017 "नधा"रण वष" / Assessment Year : 2013-14

disallowance of the deduction claimed u/s 35D of the Act of 1/5 t h of the preliminary expenses amounting to Rs.2.40 crores. 45. The facts of the case are that the assessee had acquired 100% shares in a company ‘Cable Network Limited’ (CBSL) from its parent company which had owned 100% shares in it namely DIGI Western Network

M/S INTERNATIONAL FRESH FARM PRODUCTS (INDIA) LIMITED,CHANDIGARH vs. DCIT, C-1(1), CHANDIGARH

In the result, appeal of the assessee is allowed

disallowing proportionate interest in respect of interest free advance given for business purpose to M/ s Temptation Foods even when the owned interest free funds far exceeded the advance in question. 3. That on law, facts and circumstances of the case, Worthy CIT(A) has erred in confirming the action of Ld. AO of making an addition