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

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

2 of the Revenue’s appeal A.Y. 2011-12: Ground No. 1 of the Revenue’s appeal A.Y. 2012-13: Ground No. 1 of the Revenue’s appeal A.Y. 2013-14: Ground No. 1 of the Revenue’s appeal 7.1 The relevant portion of the Assessment Order pertaining to disallowance on job work is as under: During the assessment proceedings

ACIT, LUDHIANA vs. M/S MRS. BECTORS FOOD SPECIALTIES PVT. LTD., LUDHIANA

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

2 of the Revenue’s appeal A.Y. 2011-12: Ground No. 1 of the Revenue’s appeal A.Y. 2012-13: Ground No. 1 of the Revenue’s appeal A.Y. 2013-14: Ground No. 1 of the Revenue’s appeal 7.1 The relevant portion of the Assessment Order pertaining to disallowance on job work is as under: During the assessment proceedings

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

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

2 of the Revenue’s appeal A.Y. 2011-12: Ground No. 1 of the Revenue’s appeal A.Y. 2012-13: Ground No. 1 of the Revenue’s appeal A.Y. 2013-14: Ground No. 1 of the Revenue’s appeal 7.1 The relevant portion of the Assessment Order pertaining to disallowance on job work is as under: During the assessment proceedings

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

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

2 of the Revenue’s appeal A.Y. 2011-12: Ground No. 1 of the Revenue’s appeal A.Y. 2012-13: Ground No. 1 of the Revenue’s appeal A.Y. 2013-14: Ground No. 1 of the Revenue’s appeal 7.1 The relevant portion of the Assessment Order pertaining to disallowance on job work is as under: During the assessment proceedings

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

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

2 of the Revenue’s appeal A.Y. 2011-12: Ground No. 1 of the Revenue’s appeal A.Y. 2012-13: Ground No. 1 of the Revenue’s appeal A.Y. 2013-14: Ground No. 1 of the Revenue’s appeal 7.1 The relevant portion of the Assessment Order pertaining to disallowance on job work is as under: During the assessment proceedings

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

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

2 of the Revenue’s appeal A.Y. 2011-12: Ground No. 1 of the Revenue’s appeal A.Y. 2012-13: Ground No. 1 of the Revenue’s appeal A.Y. 2013-14: Ground No. 1 of the Revenue’s appeal 7.1 The relevant portion of the Assessment Order pertaining to disallowance on job work is as under: During the assessment proceedings

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)

B) Miscellaneous expenses. The explanation offered by the assessee is logical and plausible. We hold that lower authority before ordering addition of Rs. 2,52,41,328/- (Reducing deduction u/s 80IC) to assessed income of Rs. 26,09,88,806/- ought to have examined this explanation extensively on merits as the explanation given was accompanied with the evidences in support

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)

B) Miscellaneous expenses. The explanation offered by the assessee is logical and plausible. We hold that lower authority before ordering addition of Rs. 2,52,41,328/- (Reducing deduction u/s 80IC) to assessed income of Rs. 26,09,88,806/- ought to have examined this explanation extensively on merits as the explanation given was accompanied with the evidences in support

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)

B) Miscellaneous expenses. The explanation offered by the assessee is logical and plausible. We hold that lower authority before ordering addition of Rs. 2,52,41,328/- (Reducing deduction u/s 80IC) to assessed income of Rs. 26,09,88,806/- ought to have examined this explanation extensively on merits as the explanation given was accompanied with the evidences in support

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)

B) Miscellaneous expenses. The explanation offered by the assessee is logical and plausible. We hold that lower authority before ordering addition of Rs. 2,52,41,328/- (Reducing deduction u/s 80IC) to assessed income of Rs. 26,09,88,806/- ought to have examined this explanation extensively on merits as the explanation given was accompanied with the evidences in support

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)

B) Miscellaneous expenses. The explanation offered by the assessee is logical and plausible. We hold that lower authority before ordering addition of Rs. 2,52,41,328/- (Reducing deduction u/s 80IC) to assessed income of Rs. 26,09,88,806/- ought to have examined this explanation extensively on merits as the explanation given was accompanied with the evidences in support

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)

B) Miscellaneous expenses. The explanation offered by the assessee is logical and plausible. We hold that lower authority before ordering addition of Rs. 2,52,41,328/- (Reducing deduction u/s 80IC) to assessed income of Rs. 26,09,88,806/- ought to have examined this explanation extensively on merits as the explanation given was accompanied with the evidences in support

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)

B) Miscellaneous expenses. The explanation offered by the assessee is logical and plausible. We hold that lower authority before ordering addition of Rs. 2,52,41,328/- (Reducing deduction u/s 80IC) to assessed income of Rs. 26,09,88,806/- ought to have examined this explanation extensively on merits as the explanation given was accompanied with the evidences in support

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)

B) Miscellaneous expenses. The explanation offered by the assessee is logical and plausible. We hold that lower authority before ordering addition of Rs. 2,52,41,328/- (Reducing deduction u/s 80IC) to assessed income of Rs. 26,09,88,806/- ought to have examined this explanation extensively on merits as the explanation given was accompanied with the evidences in support

DCIT-CIRCLE, PARWANOO vs. M/S SHIVOM COTSPIN LTD., SIRMOUR

In the result, this appeal of the Revenue stands partly allowed

Bench: Shri Sanjay Garg & Ms. Annapurna Guptaआयकरअपीलसं./Ita No.560/Chd/2019 "नधा"रणवष" / Assessment Year :2015-16 Shivam Cotspin Limited, The Dcit, Circle, बनाम Village Kheri, Parwanoo Kala Amb, Trilokpur Road, Sirmour Himachal Pradesh "थायीलेखासं./Pan No: Aajs9111L अपीलाथ"/Appellant ""यथ"/Respondent

B”,CHANDIGARH "ी संजय गग", "या"यकसद"य एवं "ीमती अ"नपूणा" गु"ता, लेखा सद"य BEFORE SHRI SANJAY GARG, JUDICIAL MEMBER AND Ms. ANNAPURNA GUPTA, ACCOUNTANT MEMBER आयकरअपीलसं./ITA No.560/CHD/2019 "नधा"रणवष" / Assessment Year :2015-16 Shivam Cotspin Limited, The DCIT, Circle, बनाम Village Kheri, Parwanoo Kala Amb, Trilokpur Road, Sirmour Himachal Pradesh "थायीलेखासं./PAN NO: AAJS9111L अपीलाथ"/Appellant

ACIT, CIRCLE, PARWANOO vs. SHIVOM COTSPIN LIMITED, SIRMOUR

In the result, this appeal of the Revenue stands partly allowed

Bench: Shri Sanjay Garg & Ms. Annapurna Guptaआयकरअपीलसं./Ita No.560/Chd/2019 "नधा"रणवष" / Assessment Year :2015-16 Shivam Cotspin Limited, The Dcit, Circle, बनाम Village Kheri, Parwanoo Kala Amb, Trilokpur Road, Sirmour Himachal Pradesh "थायीलेखासं./Pan No: Aajs9111L अपीलाथ"/Appellant ""यथ"/Respondent

B”,CHANDIGARH "ी संजय गग", "या"यकसद"य एवं "ीमती अ"नपूणा" गु"ता, लेखा सद"य BEFORE SHRI SANJAY GARG, JUDICIAL MEMBER AND Ms. ANNAPURNA GUPTA, ACCOUNTANT MEMBER आयकरअपीलसं./ITA No.560/CHD/2019 "नधा"रणवष" / Assessment Year :2015-16 Shivam Cotspin Limited, The DCIT, Circle, बनाम Village Kheri, Parwanoo Kala Amb, Trilokpur Road, Sirmour Himachal Pradesh "थायीलेखासं./PAN NO: AAJS9111L अपीलाथ"/Appellant

SHIVOM COTSPIN LIMITED,KALA AMB vs. DCIT, CIRCLE, PARWANOO

In the result, this appeal of the Revenue stands partly allowed

Bench: Shri Sanjay Garg & Ms. Annapurna Guptaआयकरअपीलसं./Ita No.560/Chd/2019 "नधा"रणवष" / Assessment Year :2015-16 Shivam Cotspin Limited, The Dcit, Circle, बनाम Village Kheri, Parwanoo Kala Amb, Trilokpur Road, Sirmour Himachal Pradesh "थायीलेखासं./Pan No: Aajs9111L अपीलाथ"/Appellant ""यथ"/Respondent

B”,CHANDIGARH "ी संजय गग", "या"यकसद"य एवं "ीमती अ"नपूणा" गु"ता, लेखा सद"य BEFORE SHRI SANJAY GARG, JUDICIAL MEMBER AND Ms. ANNAPURNA GUPTA, ACCOUNTANT MEMBER आयकरअपीलसं./ITA No.560/CHD/2019 "नधा"रणवष" / Assessment Year :2015-16 Shivam Cotspin Limited, The DCIT, Circle, बनाम Village Kheri, Parwanoo Kala Amb, Trilokpur Road, Sirmour Himachal Pradesh "थायीलेखासं./PAN NO: AAJS9111L अपीलाथ"/Appellant

DCIT-CIRCLE, PARWANOO vs. M/S SHIVOM COTSPIN LTD., SIRMOUR

In the result, this appeal of the Revenue stands partly allowed

Bench: Shri Sanjay Garg & Ms. Annapurna Guptaआयकरअपीलसं./Ita No.560/Chd/2019 "नधा"रणवष" / Assessment Year :2015-16 Shivam Cotspin Limited, The Dcit, Circle, बनाम Village Kheri, Parwanoo Kala Amb, Trilokpur Road, Sirmour Himachal Pradesh "थायीलेखासं./Pan No: Aajs9111L अपीलाथ"/Appellant ""यथ"/Respondent

B”,CHANDIGARH "ी संजय गग", "या"यकसद"य एवं "ीमती अ"नपूणा" गु"ता, लेखा सद"य BEFORE SHRI SANJAY GARG, JUDICIAL MEMBER AND Ms. ANNAPURNA GUPTA, ACCOUNTANT MEMBER आयकरअपीलसं./ITA No.560/CHD/2019 "नधा"रणवष" / Assessment Year :2015-16 Shivam Cotspin Limited, The DCIT, Circle, बनाम Village Kheri, Parwanoo Kala Amb, Trilokpur Road, Sirmour Himachal Pradesh "थायीलेखासं./PAN NO: AAJS9111L अपीलाथ"/Appellant

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