ROPAR DISTRICT CO-OPERATIVE UNION LIMITED,MOHALI vs. PCIT, CHANDIGAR-1, CHANDIGARH

In the result, the appeal is allowed

Bench: SHRI AAKASH DEEPJAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)

house property” shown by the assessee in its return of income. The assessee had furnished copy of notice issued u/s 142(1), dated 25.11.2020 and notice dated 10.12.2020, notice dated 27.01.2021 and notice dated 05.02.2021 and reply dated 10.02.2021 pages 6 to 19 respectively. It was stated that the assessee had returned rental income from the three properties, amounting

NOOR RESORTS PRIVATE LIMITED,KULLU vs. PR.CIT, SHIMLA

In the result, appeal of the Assessee is allowed

House Property" & not under the head "Income from Business & Profession". The learned Pr. Commissioner of Income Tax has failed to appreciate that the company's professed objective is to derive trading/ major income from letting out of properties irrespective of the nature of the property. The reliance has been placed on the judgments in case of Rayala Corporation

PREM SINGH,CHAMBA vs. ACIT CIRCLE PALAMPUR, PALAMPUR

In the result, the appeal for AY 2017-18 stands partly allowed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No. 946/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2015-16) & 2. आयकर अपील सं. / Ita No. 947/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2017-18) Shri Prem Singh Dcit Circle, Palampur बनाम/ The Palace. Chamba Himachal Pradesh - 176061 Vs. Himachal Pradesh – 176310 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aampr-8876-P (अपीलाथ"/Appellant) : (""थ" / Respondent) Assessee By : Shri Ajay Jain (Ca) – Ld. Ar Revenue By : Shri Bharat Bhushan Garg (Cit) (Virtual) - Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 13-11-2025 घोषणाकीतारीख /Date Of Pronouncement : 13-01-2026 आदेश / O R D E R Manoj Kumar Aggarwal () 1. The Assessee Is In Further Appeals Before Us For Assessment Years (Ay) 2015-16 & 2017-18 Which Arises Out Of Separate Orders Of Learned First Appellate Authority. First, We Take Up Appeal For Assessment Year (Ay) 2015-16 Which Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), Nfac [Cit(A)] Dated 22-07-2025 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S 143(3) Of The Act On 29-12-2017. The Assessee Is Aggrieved By Computation Of Capital

Disallowing claim of Rs.5,37,533 spent on account of property tax and claimed as deduction while calculating the capital gain on account of expenditure incurred wholly and exclusively in connection with transfer of the house

JANTA LAND PROMOTERS PRIVATE LIMITED ,MOHALI vs. INCOME TAX OFFICER WARD 6(1) CHANDIGARH , MOHALI

In the result, appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 907/Chd/2024 "नधा"रण वष" / Assessment Year : 2017-18 बनाम M/S Janta Land Promoters Pvt.Ltd. The Ito, Sco 39-42, Sector 82, Ward 6(1), Vs Mohali. Chandigarh. "थायी लेखा सं./Pan /Tan No: Aabcj3450D अपीलाथ"/Appellant ""यथ"/Respondent "नधा"रती क" ओर से/Assessee By : Shri Pankaj Bhalla, Ca राज"व क" ओर से/ Revenue By : Shri Vivek Vardhan, Addl. Cit, Sr.Dr तार"ख/Date Of Hearing : 07.05.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 30.07.2025

disallowance will not be made. Accordingly, this ground of appeal is partly allowed. 5.1 As far as assessment of notional rent qua inventory of flats unsold, the assessee has filed written submissions. ITA 907/CHD/2024 A.Y. 2017-18 4 6. The assessee company is engaged in the business of Real Estate as a Colonizer and Developer of Sectors in the State

KARNAIL SINGH,UK vs. JCIT (OSD) INTL. TAXATION, CIRCLE, CHANDIGARH

In the result, all the appeals of the assessee stands allowed

house property”. Thereafter, the AO analyze the provisions of Article 12 of Indo-UK DTAA as well as definition of interest as per Section 2(28A) of the Act and has held that the money paid by the assessee to M/s Omaxe Ltd. is a capital investment for purchase of the property, the assessee will get back the capital asset

KARNAIL SINGH,UK vs. JCIT (OSD) INTL. TAXATION, CIRCLE, CHANDIGARH

In the result, all the appeals of the assessee stands allowed

house property”. Thereafter, the AO analyze the provisions of Article 12 of Indo-UK DTAA as well as definition of interest as per Section 2(28A) of the Act and has held that the money paid by the assessee to M/s Omaxe Ltd. is a capital investment for purchase of the property, the assessee will get back the capital asset

KARNAIL SINGH,UK vs. JCIT (OSD) INTL. TAXATION, CIRCLE, CHANDIGARH

In the result, all the appeals of the assessee stands allowed

house property”. Thereafter, the AO analyze the provisions of Article 12 of Indo-UK DTAA as well as definition of interest as per Section 2(28A) of the Act and has held that the money paid by the assessee to M/s Omaxe Ltd. is a capital investment for purchase of the property, the assessee will get back the capital asset

KARNAIL SINGH,UK vs. JCIT (OSD) INTL. TAXATION, CIRCLE, CHANDIGARH

In the result, all the appeals of the assessee stands allowed

house property”. Thereafter, the AO analyze the provisions of Article 12 of Indo-UK DTAA as well as definition of interest as per Section 2(28A) of the Act and has held that the money paid by the assessee to M/s Omaxe Ltd. is a capital investment for purchase of the property, the assessee will get back the capital asset

KARNAIL SINGH,UK vs. JCIT (OSD) INTL. TAXATION, CIRCLE, CHANDIGARH

In the result, all the appeals of the assessee stands allowed

house property”. Thereafter, the AO analyze the provisions of Article 12 of Indo-UK DTAA as well as definition of interest as per Section 2(28A) of the Act and has held that the money paid by the assessee to M/s Omaxe Ltd. is a capital investment for purchase of the property, the assessee will get back the capital asset

KARNAIL SINGH,UK vs. JCIT (OSD) INTL. TAXATION, CIRCLE, CHANDIGARH

In the result, all the appeals of the assessee stands allowed

house property”. Thereafter, the AO analyze the provisions of Article 12 of Indo-UK DTAA as well as definition of interest as per Section 2(28A) of the Act and has held that the money paid by the assessee to M/s Omaxe Ltd. is a capital investment for purchase of the property, the assessee will get back the capital asset

KARNAIL SINGH vs. THE ASSISTANT DIRECTOR OF INCOME TAX, CHANDIGARH

In the result, ground no. 9 of the assessee’s appeal is allowed in favour of the assessee and against the Revenue

Bench: Us.

Property. The interest claimed has been wrongly disallowed. In any case, the interest paid on the borrowed capital was allowable deduction from the income whether assessed as Rental Income or assessed under the head other sources. 11. That the deductions claimed by the Appellant have been wrongly disallowed. The observation made by the Ld. A.O. are against facts

KARNAIL SINGH vs. THE ASSISTANT DIRECTOR OF INCOME TAX, CHANDIGARH

In the result, ground no. 9 of the assessee’s appeal is allowed in favour of the assessee and against the Revenue

Bench: Us.

Property. The interest claimed has been wrongly disallowed. In any case, the interest paid on the borrowed capital was allowable deduction from the income whether assessed as Rental Income or assessed under the head other sources. 11. That the deductions claimed by the Appellant have been wrongly disallowed. The observation made by the Ld. A.O. are against facts

KARNAIL SINGH vs. THE ASSISTANT DIRECTOR OF INCOME TAX, CHANDIGARH

In the result, ground no. 9 of the assessee’s appeal is allowed in favour of the assessee and against the Revenue

Bench: Us.

Property. The interest claimed has been wrongly disallowed. In any case, the interest paid on the borrowed capital was allowable deduction from the income whether assessed as Rental Income or assessed under the head other sources. 11. That the deductions claimed by the Appellant have been wrongly disallowed. The observation made by the Ld. A.O. are against facts

KARNAIL SINGH vs. THE ASSISTANT DIRECTOR OF INCOME TAX, CHANDIGARH

In the result, ground no. 9 of the assessee’s appeal is allowed in favour of the assessee and against the Revenue

Bench: Us.

Property. The interest claimed has been wrongly disallowed. In any case, the interest paid on the borrowed capital was allowable deduction from the income whether assessed as Rental Income or assessed under the head other sources. 11. That the deductions claimed by the Appellant have been wrongly disallowed. The observation made by the Ld. A.O. are against facts

KARNAIL SINGH vs. THE ASSISTANT DIRECTOR OF INCOME TAX, CHANDIGARH

In the result, ground no. 9 of the assessee’s appeal is allowed in favour of the assessee and against the Revenue

Bench: Us.

Property. The interest claimed has been wrongly disallowed. In any case, the interest paid on the borrowed capital was allowable deduction from the income whether assessed as Rental Income or assessed under the head other sources. 11. That the deductions claimed by the Appellant have been wrongly disallowed. The observation made by the Ld. A.O. are against facts

KARNAIL SINGH vs. THE ASSISTANT DIRECTOR OF INCOME TAX, CHANDIGARH

In the result, ground no. 9 of the assessee’s appeal is allowed in favour of the assessee and against the Revenue

Bench: Us.

Property. The interest claimed has been wrongly disallowed. In any case, the interest paid on the borrowed capital was allowable deduction from the income whether assessed as Rental Income or assessed under the head other sources. 11. That the deductions claimed by the Appellant have been wrongly disallowed. The observation made by the Ld. A.O. are against facts

DCIT, CIRCLE, PATIALA vs. M/S PUNJAB STATE POWER CORPORATION LTD., PATIALA

In the result, ground no. 1 & 3 of the Revenue’s appeal is allowed and ground no

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

disallowed the deduction by holding that the payment of income-tax could not be for the purpose of business. It was claimed before the Tribunal that if the tax liability had not been discharged, then the entire business would have crippled and therefore, interest on such overdraft account be allowed as an expenditure for business purposes. The Tribunal refused

S.SURJIT SINGH,LUDHIANA vs. PR.CIT-1, LUDHIANA

In the result, appeal of the Assessee is allowed

Bench: Smt.Diva Singh & Shri Vikram Singh Yadav

house property on 29/02/2011 and has claimed entire capital gains as exempt u/s 54 being money deposited in capital gain account scheme on 12/09/2012. Therefore, it is an undisputed fact that before filing of the return of income on 30/09/2012, the assessee has invested the entire capital gain amounting to Rs. 26,00,000/- in the Capital Gain Account Scheme