ASSTT.COMMISSIONER OF INCOME TAX, LUDHIANA vs. M/S MRS.BECTORS FOOD SPECILTIES LTD, LUDHIANA

Bench: Smt. Diva Singh & Dr. B.R.R. Kumar

Section-80 IB-assessee is at liberty to do Affirmed in( 2009) 183 Taxman 38 (P&H) manufacturing for itself or for others, which makes no difference for purpose of deduction u/s 80-IB. Allowable on job work. In view of above submissions we have correctly claimed deduction U/S 801C on the profits earned on job work." The assessee

ASSTT.COMMISSIONER OF INCOME TAX, LUDHIANA vs. M/S MRS.BECTORS FOOD SPECILTIES LTD, LUDHIANA

Bench: Smt. Diva Singh & Dr. B.R.R. Kumar

Section-80 IB-assessee is at liberty to do Affirmed in( 2009) 183 Taxman 38 (P&H) manufacturing for itself or for others, which makes no difference for purpose of deduction u/s 80-IB. Allowable on job work. In view of above submissions we have correctly claimed deduction U/S 801C on the profits earned on job work." The assessee

ASSTT.COMMISSIONER OF INCOME TAX, LUDHIANA vs. M/S MRS.BECTORS FOOD SPECILTIES LTD, LUDHIANA

Bench: Smt. Diva Singh & Dr. B.R.R. Kumar

Section-80 IB-assessee is at liberty to do Affirmed in( 2009) 183 Taxman 38 (P&H) manufacturing for itself or for others, which makes no difference for purpose of deduction u/s 80-IB. Allowable on job work. In view of above submissions we have correctly claimed deduction U/S 801C on the profits earned on job work." The assessee

ASSTT.COMMISSIONER OF INCOME TAX, LUDHIANA vs. M/S MRS.BECTORS FOOD SPECILTIES LTD, LUDHIANA

Bench: Smt. Diva Singh & Dr. B.R.R. Kumar

Section-80 IB-assessee is at liberty to do Affirmed in( 2009) 183 Taxman 38 (P&H) manufacturing for itself or for others, which makes no difference for purpose of deduction u/s 80-IB. Allowable on job work. In view of above submissions we have correctly claimed deduction U/S 801C on the profits earned on job work." The assessee

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)

section 147 r.w.s 144/144B of the Act. 13. That the assessee company being aggrieved by the aforesaid assessment order prefers first appeal before Ld. CIT(A) who by the order bearing No. ITBA/NFAC/S/250/2023-24/1059109232(1) dt. 27/12/2023 has allowed the appeal and has in para 6.6 and 7 has held as under: 6.6. In view of the same and respectfully following

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)

section 147 r.w.s 144/144B of the Act. 13. That the assessee company being aggrieved by the aforesaid assessment order prefers first appeal before Ld. CIT(A) who by the order bearing No. ITBA/NFAC/S/250/2023-24/1059109232(1) dt. 27/12/2023 has allowed the appeal and has in para 6.6 and 7 has held as under: 6.6. In view of the same and respectfully following

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)

section 147 r.w.s 144/144B of the Act. 13. That the assessee company being aggrieved by the aforesaid assessment order prefers first appeal before Ld. CIT(A) who by the order bearing No. ITBA/NFAC/S/250/2023-24/1059109232(1) dt. 27/12/2023 has allowed the appeal and has in para 6.6 and 7 has held as under: 6.6. In view of the same and respectfully following

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)

section 147 r.w.s 144/144B of the Act. 13. That the assessee company being aggrieved by the aforesaid assessment order prefers first appeal before Ld. CIT(A) who by the order bearing No. ITBA/NFAC/S/250/2023-24/1059109232(1) dt. 27/12/2023 has allowed the appeal and has in para 6.6 and 7 has held as under: 6.6. In view of the same and respectfully following

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)

section 147 r.w.s 144/144B of the Act. 13. That the assessee company being aggrieved by the aforesaid assessment order prefers first appeal before Ld. CIT(A) who by the order bearing No. ITBA/NFAC/S/250/2023-24/1059109232(1) dt. 27/12/2023 has allowed the appeal and has in para 6.6 and 7 has held as under: 6.6. In view of the same and respectfully following

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)

section 147 r.w.s 144/144B of the Act. 13. That the assessee company being aggrieved by the aforesaid assessment order prefers first appeal before Ld. CIT(A) who by the order bearing No. ITBA/NFAC/S/250/2023-24/1059109232(1) dt. 27/12/2023 has allowed the appeal and has in para 6.6 and 7 has held as under: 6.6. In view of the same and respectfully following

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)

section 147 r.w.s 144/144B of the Act. 13. That the assessee company being aggrieved by the aforesaid assessment order prefers first appeal before Ld. CIT(A) who by the order bearing No. ITBA/NFAC/S/250/2023-24/1059109232(1) dt. 27/12/2023 has allowed the appeal and has in para 6.6 and 7 has held as under: 6.6. In view of the same and respectfully following

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)

section 147 r.w.s 144/144B of the Act. 13. That the assessee company being aggrieved by the aforesaid assessment order prefers first appeal before Ld. CIT(A) who by the order bearing No. ITBA/NFAC/S/250/2023-24/1059109232(1) dt. 27/12/2023 has allowed the appeal and has in para 6.6 and 7 has held as under: 6.6. In view of the same and respectfully following

DCIT, PARWANOO vs. M/S HYCRON ELECTRONICS, SOLAN

Appeal of the Revenue is dismissed and appeal of the assessee is allowed

Bench: Smt. Diva Singh & Dr. B.R.R. Kumar

disallowed, would not prove it to be a fit case of levy of penalty for filing inaccurate particulars of income. The issue of claim of deduction was debatable and bonafide. However, there was conflict for determination of provision of law. Merely making a claim of 100% deduction against 25% as per opinion of the Assessing Officer under section 801C

HYCRON ELECTRONICS vs. DY.COMMISSIONER OF INCOME TAX,

Appeal of the Revenue is dismissed and appeal of the assessee is allowed

Bench: Smt. Diva Singh & Dr. B.R.R. Kumar

disallowed, would not prove it to be a fit case of levy of penalty for filing inaccurate particulars of income. The issue of claim of deduction was debatable and bonafide. However, there was conflict for determination of provision of law. Merely making a claim of 100% deduction against 25% as per opinion of the Assessing Officer under section 801C

DCIT, CC-I, CHANDIGARH , CHANDIGARH vs. VALCO INDUSTRIES LTD., , CHANDIGARH

In the result, the appeal of the Revenue is dismissed

Bench: The Hon'Ble Punjab & Haryana High Court? Ii) Whether On The Facts & Circumstances Of The Case & In Law, Ld. Cit(A) Is Right Holding Such Consequential Order As Void An Initio Ignoring The Facts That Order Passed By Ld. Pcit (Central), Gurugram U/S 263 Has Not Attained Its Finality? Iii) Whether On The Facts & In Circumstances Of The Case & In Law, The Ld. Cit(A) Was Right In Holding That Consequential Order Passed U/S 147 R.W.S. 263 Of The Act As Void As Initio Without Giving Any Liberty To The Revenue To Revive The Proceedings Consequent To Any Directions Or Order

801C of the IT. Act, 1961 are disallowed and added to the returned income of the assessee. I am satisfied that the assessee company has furnished inaccurate particulars of income hence penalty proceedings u/s 271(l)(c) of the I.T. Act, 1961 is being initiated. Subject to above income of the assessee is computed as under:- Last Assessed Income

DAXEN AGRITECH INDIA PVT. LTD.,BADDI vs. ACIT, CIRCLE, PARWANOO

In the result, all the above appeals of the Assessee are dismissed

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

801C may not be disallowed by observing the facts that assessee has not proved manufacturing activity. In reply Dt. Assessee furnished detailed reply annexed at Annexure 2 h) It is clear from the reply to the show cause that nothing new was stated by the assessee but repeated the same story. In view of the above facts, circumstances, evidences

DAXEN AGRITECH INDIA PVT. LTD.,BADDI vs. ACIT, CIRCLE, PARWANOO

In the result, all the above appeals of the Assessee are dismissed

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

801C may not be disallowed by observing the facts that assessee has not proved manufacturing activity. In reply Dt. Assessee furnished detailed reply annexed at Annexure 2 h) It is clear from the reply to the show cause that nothing new was stated by the assessee but repeated the same story. In view of the above facts, circumstances, evidences

DAXEN AGRITECH INDIA PVT. LTD.,BADDI vs. ACIT, CIRCLE, PARWANOO

In the result, all the above appeals of the Assessee are dismissed

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

801C may not be disallowed by observing the facts that assessee has not proved manufacturing activity. In reply Dt. Assessee furnished detailed reply annexed at Annexure 2 h) It is clear from the reply to the show cause that nothing new was stated by the assessee but repeated the same story. In view of the above facts, circumstances, evidences