RICO AUTO INDUSTRIES LIMITED,LUDHIANA vs. PR. COMMISSIONER OF INCOME TAX-1, LUDHIANA

The appeals stand allowed in terms of our above order

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.702/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2020-21) & 2. आयकर अपील सं. / Ita No.703/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2021-22) M/S Rico Auto Industries Ltd. Pr. Cit-1 बनाम/ B-26, Focal Point Aaykar Bhawan, Rishi Nagar Vs. Ludhiana (Punjab)-141010 Ludhiana (Punjab) - 141001 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aaacr-8724-R (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Sudhir Sehgal (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) (Virtual) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 07-10-2025 घोषणाकीतारीख /Date Of Pronouncement : 10/11/2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. In These Twin Appeals, The Assessee Assails Proposed Revision Of The Assessment Order By Revisionary Authority U/S 263 For Assessment Years (Ay) 2020-21 & 2021-22. Facts Are Stated To Be Identical In Both The Years. First, We Take Up Appeal For Ay 2020-21 Wherein The Assessee Challenges Invocation Of Revisionary Jurisdiction U/S 263 By Ld. Pr.

property; (iii) Interest on loan to subsidiaries for Rs.285.96 Lacs reduced from computation of income; (iv) genuineness of loan transactions; (v) no enquiry on reconciliation of turnover as per Profit & Loss Account and turnover as per GST; (vi) Large difference in opening stock of current year and closing stock of previous year, non-verification of stock register; (vii) non-verification

SHRI SATISH KUMAR,SANGRUR vs. ITO, WARD, SANGRUR

In the result, appeal of the assessee’s are allowed

House Property, Capital Gain and other sources residing at C/o Sangrur Surgical and Laparoscopic Centre, Haripura Road, Sangrur. The appellant filed his return of income on dtd. 30/11/2015, declaring income of Rs. 1,59,87,590/- for the assessment year 2015-16 and paid total tax and interest of Rs. 37,78,150/- The return was processed

SMT. URMILA GARG,SANGRUR vs. ITO, WARD, SANGRUR

In the result, appeal of the assessee’s are allowed

House Property, Capital Gain and other sources residing at C/o Sangrur Surgical and Laparoscopic Centre, Haripura Road, Sangrur. The appellant filed his return of income on dtd. 30/11/2015, declaring income of Rs. 1,59,87,590/- for the assessment year 2015-16 and paid total tax and interest of Rs. 37,78,150/- The return was processed

SH. AKHIL JAIN,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the ground no

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

House No. 60-A, Kitchlu Nagar, CC-III, Ludhiana Ludhiana- 141008 "थायी लेखा सं./PAN NO: AESPJ2222B अपीलाथ"/Appellant ""थ"/Respondent आयकर अपील सं./ ITA NO. 354/Chd/2023 िनधा"रण वष" / Assessment Year : 2013-14 Shri Bipan Jain The DCIT बनाम C/o Jain Amar Clothing Pvt. Ltd. CC-III, Ludhiana Chawal Bazar, Ludhiana- 141008 "थायी लेखा सं./PAN NO: ABLPJ0336J अपीलाथ

SH. ASHISH JAIN,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the ground no

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

House No. 60-A, Kitchlu Nagar, CC-III, Ludhiana Ludhiana- 141008 "थायी लेखा सं./PAN NO: AESPJ2222B अपीलाथ"/Appellant ""थ"/Respondent आयकर अपील सं./ ITA NO. 354/Chd/2023 िनधा"रण वष" / Assessment Year : 2013-14 Shri Bipan Jain The DCIT बनाम C/o Jain Amar Clothing Pvt. Ltd. CC-III, Ludhiana Chawal Bazar, Ludhiana- 141008 "थायी लेखा सं./PAN NO: ABLPJ0336J अपीलाथ

SH. ASHISH JAIN,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the ground no

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

House No. 60-A, Kitchlu Nagar, CC-III, Ludhiana Ludhiana- 141008 "थायी लेखा सं./PAN NO: AESPJ2222B अपीलाथ"/Appellant ""थ"/Respondent आयकर अपील सं./ ITA NO. 354/Chd/2023 िनधा"रण वष" / Assessment Year : 2013-14 Shri Bipan Jain The DCIT बनाम C/o Jain Amar Clothing Pvt. Ltd. CC-III, Ludhiana Chawal Bazar, Ludhiana- 141008 "थायी लेखा सं./PAN NO: ABLPJ0336J अपीलाथ

SH. BIPAN JAIN,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the ground no

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

House No. 60-A, Kitchlu Nagar, CC-III, Ludhiana Ludhiana- 141008 "थायी लेखा सं./PAN NO: AESPJ2222B अपीलाथ"/Appellant ""थ"/Respondent आयकर अपील सं./ ITA NO. 354/Chd/2023 िनधा"रण वष" / Assessment Year : 2013-14 Shri Bipan Jain The DCIT बनाम C/o Jain Amar Clothing Pvt. Ltd. CC-III, Ludhiana Chawal Bazar, Ludhiana- 141008 "थायी लेखा सं./PAN NO: ABLPJ0336J अपीलाथ

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

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

Housing Projects Ltd. 343 ITR 329 (Del); and iv) PCIT V Delhi Airport Metro Express (P) Ltd. 398 ITR 8 (Del) 13.10 Moreover, as noted, where two views are possible and the AO has taken a view with which the CIT/PCIT does not agree, the assessment order cannot be termed as erroneous and prejudicial to the interests of the Revenue

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

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

Housing Projects Ltd. 343 ITR 329 (Del); and iv) PCIT V Delhi Airport Metro Express (P) Ltd. 398 ITR 8 (Del) 13.10 Moreover, as noted, where two views are possible and the AO has taken a view with which the CIT/PCIT does not agree, the assessment order cannot be termed as erroneous and prejudicial to the interests of the Revenue

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

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

Housing Projects Ltd. 343 ITR 329 (Del); and iv) PCIT V Delhi Airport Metro Express (P) Ltd. 398 ITR 8 (Del) 13.10 Moreover, as noted, where two views are possible and the AO has taken a view with which the CIT/PCIT does not agree, the assessment order cannot be termed as erroneous and prejudicial to the interests of the Revenue

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(1)(c) is to judge the reasonableness of the payments made to the members of the society and secondly and more importantly, there is no finding of the AO that the society is not working towards the objects of education etc. as defined in its Memorandum and Rules and Regulations. No case of siphoning off of the funds

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(1)(c) is to judge the reasonableness of the payments made to the members of the society and secondly and more importantly, there is no finding of the AO that the society is not working towards the objects of education etc. as defined in its Memorandum and Rules and Regulations. No case of siphoning off of the funds

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(1)(c) is to judge the reasonableness of the payments made to the members of the society and secondly and more importantly, there is no finding of the AO that the society is not working towards the objects of education etc. as defined in its Memorandum and Rules and Regulations. No case of siphoning off of the funds

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(1)(c) is to judge the reasonableness of the payments made to the members of the society and secondly and more importantly, there is no finding of the AO that the society is not working towards the objects of education etc. as defined in its Memorandum and Rules and Regulations. No case of siphoning off of the funds

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(1)(c) is to judge the reasonableness of the payments made to the members of the society and secondly and more importantly, there is no finding of the AO that the society is not working towards the objects of education etc. as defined in its Memorandum and Rules and Regulations. No case of siphoning off of the funds

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(1)(c) is to judge the reasonableness of the payments made to the members of the society and secondly and more importantly, there is no finding of the AO that the society is not working towards the objects of education etc. as defined in its Memorandum and Rules and Regulations. No case of siphoning off of the funds

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(1)(c) is to judge the reasonableness of the payments made to the members of the society and secondly and more importantly, there is no finding of the AO that the society is not working towards the objects of education etc. as defined in its Memorandum and Rules and Regulations. No case of siphoning off of the funds

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(1)(c) is to judge the reasonableness of the payments made to the members of the society and secondly and more importantly, there is no finding of the AO that the society is not working towards the objects of education etc. as defined in its Memorandum and Rules and Regulations. No case of siphoning off of the funds