DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, LUDHIANA, LUDHIANA vs. M/S JAMNA DASS NIKKAMAL JAIN SARAF PVT. LTD., LUDHIANA

In the result, the appeal filed by Revenue is dismissed and the appeal filed by the Assessee is allowed

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

section 69A, hence, penalty proceedings u/s 271AAC are to be initiated, which are being initiated separately. (Addition: Rs. 36,75,23,049-/) 22. Feeling aggrieved with the finding of the Assessing Officer the Assessee preferred the appeal before the Ld. CIT(A) and the Ld. CIT(A) has granted 22 the relief to the assessee. The finding

SHRI SATISH SOIN,LUDHIANA vs. ACIT, CC-II, LUDHIANA

In the result, appeal of the assessee is allowed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 303/Chd/2019 "नधा"रण वष" / Assessment Year : 2012-13 Shri Satish Soin, बनाम The Acit, House No.31, Garden Enclave, Central Circle-2, Vs South City-Ii, Ludhiana. Ludhiana. "थायी लेखा सं./Pan /Tan No: Advps6254N अपीलाथ"/Appellant ""यथ"/Respondent "नधा"रती क" ओर से/Assessee By : Shri Ashwani Kumar & Ms. Muskan Garg, Cas राज"व क" ओर से/ Revenue By : Smt. Kusum Bansal, Cit Dr तार"ख/Date Of Hearing : 26.05.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 23.07.2025 Hybrid Hearing आदेश/Order Per Rajpal Yadav, Vp

70,120/-. A notice under Section 143(2) was issued and served upon the assessee. Thereafter ld. AO has passed an assessment order under Section 153A read with Section 143(3) of the Income Tax Act on 31.03.2015. Since no incriminating material was found during the course of search, therefore, no addition was made by the AO except Rs.25

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)

3) of the Act, whereby the total income of the assessee company was assessed at Rs. 57,03,70,400/- after making addition on account of alleged under valuation of closing work in progress. 6. That the aforesaid addition made by the AO was deleted by the CIT(A) and the order of Ld. CIT(A) was thereafter affirmed

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)

70. In the interest of justice and to meet the ends of fairness, we deem it appropriate to restrict the disallowance to 5% of the cash component of salary and wages, instead of 25% of the total expenditure as made by the Assessing Officer. 71. Accordingly, the disallowance made by the Assessing Officer at Rs. 11,48,800/- is reduced

SHRI ABHISHEK SOIN,LUDHIANA vs. DCIT, CC-II, LUDHIANA

The appeals are partly allowed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 321 & 322/Chd/2019 "नधा"रण वष" / Assessment Year: 2010-11, 2011-12 Shri Abhishek Soin, The Dcit, C/O Sigma Cartons Pvt. Ltd., Vs Central Circle-Ii, Unit-Ii, Industrial Area-C, Ludhiana. Sua Road, Ludhiana. "थायी लेखा सं./Pan No: Anbps9446A अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Aditya Kumar, Ca Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 03.06.2025 Date Of Pronouncement : 29.07.2025 Hybrid Hearing O R D E R

70,120/-. A notice under Section 143(2) was issued and served upon the assessee. Thereafter ld. AO has passed an assessment order under Section 153A read with Section 143(3) of the Income Tax Act on 31.03.2015. Since no incriminating material was found during the course of search, therefore, no addition was made by the AO except Rs.25

SHRI ABHISHEK SOIN,LUDHIANA vs. DCIT, CC-II, LUDHIANA

The appeals are partly allowed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 321 & 322/Chd/2019 "नधा"रण वष" / Assessment Year: 2010-11, 2011-12 Shri Abhishek Soin, The Dcit, C/O Sigma Cartons Pvt. Ltd., Vs Central Circle-Ii, Unit-Ii, Industrial Area-C, Ludhiana. Sua Road, Ludhiana. "थायी लेखा सं./Pan No: Anbps9446A अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Aditya Kumar, Ca Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 03.06.2025 Date Of Pronouncement : 29.07.2025 Hybrid Hearing O R D E R

70,120/-. A notice under Section 143(2) was issued and served upon the assessee. Thereafter ld. AO has passed an assessment order under Section 153A read with Section 143(3) of the Income Tax Act on 31.03.2015. Since no incriminating material was found during the course of search, therefore, no addition was made by the AO except Rs.25

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

In the result appeal of the assessee is allowed

70 of the Act against income of Rs. 105,19,500/-, therefore, the income declared by the assessee of Rs. 39,73,107/- in the return of income filed in section 139(1) of the Act may kindly be accepted as such. Should your goodself require any further evidence to verify the claim made by the assessee either in respect

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

section 13(3) of IT Act. In this regard it is submitted that Sh G S Sardana is the chairman of the Manav Mangal Schools. Sh. Sanjay Sardana and Sandeep Sardana are two Directors of the Manav Mangal Schools having three schools (Manav Mangal High School, Sector 21, Chandigarh, Manav Mangal School Sector 11 Panchkula and Manav Mangal Smart School

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

section 13(3) of IT Act. In this regard it is submitted that Sh G S Sardana is the chairman of the Manav Mangal Schools. Sh. Sanjay Sardana and Sandeep Sardana are two Directors of the Manav Mangal Schools having three schools (Manav Mangal High School, Sector 21, Chandigarh, Manav Mangal School Sector 11 Panchkula and Manav Mangal Smart School

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

section 13(3) of IT Act. In this regard it is submitted that Sh G S Sardana is the chairman of the Manav Mangal Schools. Sh. Sanjay Sardana and Sandeep Sardana are two Directors of the Manav Mangal Schools having three schools (Manav Mangal High School, Sector 21, Chandigarh, Manav Mangal School Sector 11 Panchkula and Manav Mangal Smart School

DCIT,CIRCLE-1(EXEMPTION), CHANDIGARH vs. M/S MANAV MANGAL SCHOOL( MANAV MANGAL SOCIETY), CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

section 13(3) of IT Act. In this regard it is submitted that Sh G S Sardana is the chairman of the Manav Mangal Schools. Sh. Sanjay Sardana and Sandeep Sardana are two Directors of the Manav Mangal Schools having three schools (Manav Mangal High School, Sector 21, Chandigarh, Manav Mangal School Sector 11 Panchkula and Manav Mangal Smart School

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

section 13(3) of IT Act. In this regard it is submitted that Sh G S Sardana is the chairman of the Manav Mangal Schools. Sh. Sanjay Sardana and Sandeep Sardana are two Directors of the Manav Mangal Schools having three schools (Manav Mangal High School, Sector 21, Chandigarh, Manav Mangal School Sector 11 Panchkula and Manav Mangal Smart School

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

section 13(3) of IT Act. In this regard it is submitted that Sh G S Sardana is the chairman of the Manav Mangal Schools. Sh. Sanjay Sardana and Sandeep Sardana are two Directors of the Manav Mangal Schools having three schools (Manav Mangal High School, Sector 21, Chandigarh, Manav Mangal School Sector 11 Panchkula and Manav Mangal Smart School

M/S MANAV MANGAL SOCIETY,CHANDIGARH vs. DCIT, C-1, (E), CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

section 13(3) of IT Act. In this regard it is submitted that Sh G S Sardana is the chairman of the Manav Mangal Schools. Sh. Sanjay Sardana and Sandeep Sardana are two Directors of the Manav Mangal Schools having three schools (Manav Mangal High School, Sector 21, Chandigarh, Manav Mangal School Sector 11 Panchkula and Manav Mangal Smart School

M/S MANAV MANGAL SOCIETY,CHANDIGARH vs. DCIT, C-1, (E), CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

section 13(3) of IT Act. In this regard it is submitted that Sh G S Sardana is the chairman of the Manav Mangal Schools. Sh. Sanjay Sardana and Sandeep Sardana are two Directors of the Manav Mangal Schools having three schools (Manav Mangal High School, Sector 21, Chandigarh, Manav Mangal School Sector 11 Panchkula and Manav Mangal Smart School

S.P. SINGLA CONSTRUCTION PRIVATE LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CHANDIGARH

In the result, the appeal is allowed

Bench: SHRI MAHAVIR SINGH (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

disallowed the total expenses claimed by assessee on account of these bogus Sub Contractor firms at Rs.36,10,58,438/-. Accordingly, assessee's income was assessed. Aggrieved, assessee preferred appeal before CIT(A). 5. Before CIT(A), assessee raised the issue of re-opening vide Ground No. 2 and 3 as under : “2. That the assessment order dated 17.12.2019 passed

M/S DIN DAYAL PURSOTAM LAL,SIRSA vs. PR.CIT, ROHTAK

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

70 were pertaining to earlier years and they were brought forward as pending balances. Now, it is well settled that sums pertaining to earlier years, brought forward as pending balance cannot be taxed under the provisions of Section 68 of the Act. It has been so held, inter-alia in the following decisions

M/S DIN DAYAL PURSOTAM LAL,SIRSA vs. PR.CIT, ROHTAK

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

70 were pertaining to earlier years and they were brought forward as pending balances. Now, it is well settled that sums pertaining to earlier years, brought forward as pending balance cannot be taxed under the provisions of Section 68 of the Act. It has been so held, inter-alia in the following decisions

M/S DIN DAYAL PURSOTAM LAL,SIRSA vs. PR.CIT, ROHTAK

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

70 were pertaining to earlier years and they were brought forward as pending balances. Now, it is well settled that sums pertaining to earlier years, brought forward as pending balance cannot be taxed under the provisions of Section 68 of the Act. It has been so held, inter-alia in the following decisions