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

73,62,564\nInvestment yielded exempt income and outstanding:\n-As on 31.03.2012\n-As on 31.03.2011\nRs. 1,32,09,28,068\nRs. 2,34,36,86,413\nAverage of investments yielded exempt income\n=(1, 32,09,28,068+2,34,36,86,413)/2\nRs. 1,83,23,07,240\nDisallowance

ARYANS EDUCATIONAL AND CHARITABLE TRUST REGD, MOHALI,MOHALI vs. COMMISSIONER OF INCOME TAX, EXEMPTIONS, CHANDIGARH

In the result, appeal is allowed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 1136/Chd/2024 "नधा"रण वष" / Assessment Year: 2025-26 Aryans Educational & The Cit (Exemptions), Charitable Trust, Regd.Mohali Vs Chandigarh, C/O Shri Tej Mohan Singh, Advocate, # 527, Sector 10-D, Chandigarh. "थायी लेखा सं./Pan No: Aabta7550L अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Tej Mohan Singh, Advocate Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 07.08.2025 Date Of Pronouncement : 24.09.2025

disallowance of the entire amount of Rs. 1,73,73,648/- by applying the provisions of section 115BBC and section

DCIT, CIRCLE, YAMUNANAGAR vs. M/S SYMBIOSIS PHARMACEUTICALS PVT. LTD., YAMUNANAGAR

In the result, appeal is dismissed

Bench: The Due Date As Prescribed In Section 139(1) Of The I.T. Act, 1961 Whereas The Assessee Has Filed Its Return Of Income After The Due Date.

73, the Hon'ble ITA 326/CHD/2019 A.Y. 2014-15 23 jurisdictional High Court has observed, inter-alia, as follows : "Order Before proceeding further, we may notice some of the principles of interpretation of the statutes. These are: (1) The question as to whether a statute is mandatory or directory depends upon the intent of the Legislature and not upon

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

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE, PATIALA, PATIALA vs. PUNJAB STATE POWER CORPORATION LIMITED, PATIALA

In the result, both the appeals filed by the Revenue are partly allowed

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

section 36(1)(va) of the Act and therefore there cannot be any disallowance under the said provision. 19.4 It was further submitted that during the said period, the assessee company has made payment to the retired and other employees and only net funds retained by the company was to the tune

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE, PATIALA vs. PUNJAB STATE POWER CORPORATION LIMITED, PATIALA

In the result, both the appeals filed by the Revenue are partly allowed

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

section 36(1)(va) of the Act and therefore there cannot be any disallowance under the said provision. 19.4 It was further submitted that during the said period, the assessee company has made payment to the retired and other employees and only net funds retained by the company was to the tune

M/S ARYANS EDUCATIONAL AND CHARITABLE TRUST,MOHALI vs. DCIT, C-1, (E), CHANDIGARH

In the result, appeal of the assessee is partly allowed

Bench: Shri A.D. Jain & Dr Krinwant Sahayआयकर अपील सं./ Ita No. 821/Chd/2019 "नधा"रण वष" / Assessment Years : 2013-14 M/S Aryans Educational & Vs. The Dcit, Circle-1 Charitable Trust, बनाम (Exemptions), # 2129, Phase-10, Chandigarh Mohali "थायी लेखा सं./Pan No: Aabta7550L

disallowance of the entire amount of Rs. 1,73,73,648/- by applying the provisions of section 115BBC and section

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)

disallowance of Rs.6,49,590/- under Section 36(1)(iii) of the Income Tax Act. The AO observed that the assessee had given loans and advances to various parties, amounting to Rs.92,24,578/- plus Rs.24,98,733/- = Rs.1,17,23,311/-, as follows : Narration Advance Advance against land Rs. 73

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)

disallowance of Rs.6,49,590/- under Section 36(1)(iii) of the Income Tax Act. The AO observed that the assessee had given loans and advances to various parties, amounting to Rs.92,24,578/- plus Rs.24,98,733/- = Rs.1,17,23,311/-, as follows : Narration Advance Advance against land Rs. 73

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)

disallowance of Rs.6,49,590/- under Section 36(1)(iii) of the Income Tax Act. The AO observed that the assessee had given loans and advances to various parties, amounting to Rs.92,24,578/- plus Rs.24,98,733/- = Rs.1,17,23,311/-, as follows : Narration Advance Advance against land Rs. 73

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)

disallowance of Rs.6,49,590/- under Section 36(1)(iii) of the Income Tax Act. The AO observed that the assessee had given loans and advances to various parties, amounting to Rs.92,24,578/- plus Rs.24,98,733/- = Rs.1,17,23,311/-, as follows : Narration Advance Advance against land Rs. 73

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)

disallowed from the gross dividend income received by the assessee. From the reasons recorded by the Assessing Officer, it was clear that the assessment was sought to be reopened merely on suspicion that the assessee might have utilized the borrowed fund for investment and that the assessee might have incurred expenditure for earning the dividend income. There was no material

M/S PAGRO FROZEN FOODS PVT. LTD.,CHANDIGARH vs. ITO, W-2(3), CHANDIGARH

The appeal of the Assessee is dismissed

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

1) in any previous year, owing to there being no profits or gains chargeable for that previous year, or owing to the profits or gains chargeable being less than the allowance, then, subject to the provisions of sub- section (2) of section 72 and sub-section (3) of section 73, the allowance or the part of the allowance to 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)

1,85,53,26/- in the computation of income which is as per Section 14A read with Rule 8D. The calculation of same is given in Annexure 15 to TAR.” 22.6 That the reply of the Assessee has been considered and that the same is untenable. The assessee’s is working of disallowance u/s 14A r.w. Rule

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)

1,85,53,26/- in the computation of income which is as per Section 14A read with Rule 8D. The calculation of same is given in Annexure 15 to TAR.” 22.6 That the reply of the Assessee has been considered and that the same is untenable. The assessee’s is working of disallowance u/s 14A r.w. Rule

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)

1,85,53,26/- in the computation of income which is as per Section 14A read with Rule 8D. The calculation of same is given in Annexure 15 to TAR.” 22.6 That the reply of the Assessee has been considered and that the same is untenable. The assessee’s is working of disallowance u/s 14A r.w. Rule

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)

1,85,53,26/- in the computation of income which is as per Section 14A read with Rule 8D. The calculation of same is given in Annexure 15 to TAR.” 22.6 That the reply of the Assessee has been considered and that the same is untenable. The assessee’s is working of disallowance u/s 14A r.w. Rule

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)

1,85,53,26/- in the computation of income which is as per Section 14A read with Rule 8D. The calculation of same is given in Annexure 15 to TAR.” 22.6 That the reply of the Assessee has been considered and that the same is untenable. The assessee’s is working of disallowance u/s 14A r.w. Rule

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)

1,85,53,26/- in the computation of income which is as per Section 14A read with Rule 8D. The calculation of same is given in Annexure 15 to TAR.” 22.6 That the reply of the Assessee has been considered and that the same is untenable. The assessee’s is working of disallowance u/s 14A r.w. Rule