DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2, LUDHIANA vs. AB ALCOBEV PRIVATE LIMITED, DELHI

In the result, appeals of Revenue are dismissed, Cross\nObjections of the assessee for

ia) was passed vide order, dated 27.02.2020 as per page 159 of the Paper\nBook.\n.\nA mere survey does not fulfil the statutory requirements for invoking section 153A\nof the Income Tax Act.\n.\nTherefore, the Assessing Officer lacked valid jurisdiction to initiate or proceed\nunder section 153A against the assessee.\n1.4\nThe company was constructing a Mall

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2,, LUDHIANA vs. AB ALCOBEV PRIVATE LIMITED, DELHI

In the result, appeals of Revenue are dismissed, Cross\nObjections of the assessee for

ia) was passed vide order, dated 27.02.2020 as per page 159 of the Paper\nBook.\n•\nA mere survey does not fulfil the statutory requirements for invoking section 153A\nof the Income Tax Act.\nTherefore, the Assessing Officer lacked valid jurisdiction to initiate or proceed\nunder section 153A against the assessee.\n1.4\nThe company was constructing a Mall

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2 LUDHIANA, LUDHIANA vs. AB ALCOBEV PRIVATE LIMITED , DELHI

In the result, appeals of Revenue are dismissed, Cross\nObjections of the assessee for

ia) was passed vide order, dated 27.02.2020 as per page 159 of the Paper\nBook.\nA mere survey does not fulfil the statutory requirements for invoking section 153A\nof the Income Tax Act.\nTherefore, the Assessing Officer lacked valid jurisdiction to initiate or proceed\nunder section 153A against the assessee.\n1.4\nThe company was constructing a Mall

HARYANA BUILDING AND OTHER CONSTRUCTION WORKERS WELFARE BOARD,PANCHKULA vs. DCIT, EXEMPTION, SECTOR 17

In the result, this appeal of the Assessee stands dismissed

property, to contract, and to sue or be sued in its own name, to\nexercise powers conferred on, and perform the functions assigned to it\nunder this Act.\n1. 3. Further, Section 24 of the Act (Relevant extract of Section 24 is\nmentioned at page 13 of the BOCW Act, 1996) lays down that the Board\nshall have the responsibility

HARYANA BUILDING AND OTHER CONSTRUCTION WORKERS WELFARE BOARD,PANCHKULA vs. DCIT, EXEMPTION, CHANDIGARH

In the result, this appeal of the Assessee stands dismissed

property, to contract, and to sue or be sued in its own name, to\nexercise powers conferred on, and perform the functions assigned to it\nunder this Act.\n1. 3. Further, Section 24 of the Act (Relevant extract of Section 24 is\nmentioned at page 13 of the BOCW Act, 1996) lays down that the Board\nshall have the responsibility

SCOTT EDIL ADVANCE RESEARCH LABORATORIES AND EDUCATION LIMITED,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

13]\nSole basis of the addition is only the valuation report furnished by the DVO which has\nbeen obtained by the ld. AO during the course of search assessment proceedings. Then,\nthe said report cannot constitute incriminating material found during the course of\nsearch. Hence, we have no hesitation to hold that no addition could be made by placing\nreliance

HARYANA BUILDING AND OTHER CONSTRUCTION WORKERS WELFARE BOARD,PANCHKULA vs. CIT(EXEMPTION), CHANDIGARH

In the result, this appeal of the Assessee stands dismissed

property, to contract, and to sue or be sued in its own name, to\nexercise powers conferred on, and perform the functions assigned to it\nunder this Act.\n\n1. 3. Further, Section 24 of the Act (Relevant extract of Section 24 is\nmentioned at page 13 of the BOCW Act, 1996) lays down that the Board\nshall have

HARYANA BUILDING AND OTHER CONSTRUCTION WORKERS WELFARE BOARD,PANCHKULA vs. DCIT, EXEMPTION, CHANDIGARH

In the result, this appeal of the Assessee stands dismissed

property, to contract, and to sue or be sued in its own name, to\nexercise powers conferred on, and perform the functions assigned to it\nunder this Act.\n\n1. 3. Further, Section 24 of the Act (Relevant extract of Section 24 is\nmentioned at page 13 of the BOCW Act, 1996) lays down that the Board\nshall have

SCOTT EDIL ADVANCE RESEARCH LABORATORIES AND EDUCATION LIMITED,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

13]\nSole basis of the addition is only the valuation report furnished by the DVO which has\nbeen obtained by the ld. AO during the course of search assessment proceedings. Then,\nthe said report cannot constitute incriminating material found during the course of\nsearch. Hence, we have no hesitation to hold that no addition could be made by placing\nreliance

DCIT, CC 1, CHANDIGARH , CHANDIGARH vs. SANJEEV AGGARWAL , CHANDIGARH

The appeals of the revenue are treated as dismissed

13]\nSole basis of the addition is only the valuation report furnished by the DVO which has\nbeen obtained by the ld. AO during the course of search assessment proceedings. Then,\nthe said report cannot constitute incriminating material found during the course of\nsearch. Hence, we have no hesitation to hold that no addition could be made by placing\nreliance

SCOTT EDIL PHARMACIA LTD.,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

property solely on\nthe basis of DVO report without any other corroborating evidence or incriminating\nevidence found in support of such addition. The Hon’ble Supreme Court in Sargam\n53\nCinema v. CIT (328 ITR 513) has held that a DVO’s report cannot be relied upon unless\nthe books of accounts are found to be incorrect. The Income

MAXPORT INDIA PRIVATE LIMITED,CHANDIGARH vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,CHANDIGARH, CHANDIGARH

1(3),\nAhmedabad [2017] 82 taxmann.com 243 (Ahmedabad - Trib.)\n(iii) Kay Jay Projects Pvt. Ltd. Versus Dcit, Central Circle, Noida 2023 (8) Tmi 431:\nAssessment u/s 153A - Addition towards the cost of construction of the building -\nReference made to ld. DVO u/s 142A - HELD THAT:- Admittedly, no incriminating\nmaterial has been found during the course of search qua this

SANJEEV AGGARWAL,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1 , CHANDIGARH

1(3),\nAhmedabad [2017] 82 taxmann.com 243 (Ahmedabad - Trib.)\n(iii) Kay Jay Projects Pvt. Ltd. Versus Dcit, Central Circle, Noida 2023 (8) Tmi 431:\nAssessment u/s 153A - Addition towards the cost of construction of the building -\nReference made to ld. DVO u/s 142A - HELD THAT:- Admittedly, no incriminating\nmaterial has been found during the course of search qua this

SCOTT EDIL PHARMACIA LTD.,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

property solely on\nthe basis of DVO report without any other corroborating evidence or incriminating\nevidence found in support of such addition. The Hon’ble Supreme Court in Sargam\nCinema v. CIT (328 ITR 513) has held that a DVO’s report cannot be relied upon unless\nthe books of accounts are found to be incorrect. The Income

SHRI BALRAM KRISHAN,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH, CHANDIGARH

1(3),\nAhmedabad [2017] 82 taxmann.com 243 (Ahmedabad - Trib.)\n(iii) Kay Jay Projects Pvt. Ltd. Versus Dcit, Central Circle, Noida 2023 (8) Tmi 431:\nAssessment u/s 153A - Addition towards the cost of construction of the building -\nReference made to ld. DVO u/s 142A - HELD THAT:- Admittedly, no incriminating\nmaterial has been found during the course of search qua this

SCOTT EDIL ADVANCE RESEARCH LABORATORIES AND EDUCATION LIMITED,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

1(3),\nAhmedabad [2017] 82 taxmann.com 243 (Ahmedabad - Trib.)\n(iii) Kay Jay Projects Pvt. Ltd. Versus Dcit, Central Circle, Noida 2023 (8) Tmi 431:\nAssessment u/s 153A - Addition towards the cost of construction of the building -\nReference made to ld. DVO u/s 142A - HELD THAT:- Admittedly, no incriminating\nmaterial has been found during the course of search qua this

M/S ASHA TECHNOLOGIES,SIRMOUR vs. ADDL. CIT, SOLAN

In the result, both the above appeals of the Assessee are partly allowed as aforesaid in respect of impugned orders dt

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

1. during survey u./s 133A on 7th & 8th of December, 2009, which was annexurised as A-5. This day book for A.Y. 2007-08 was computerized and ledger and cash books were prepared, copy of which was handed to the assessee for its comments. But it failed to substantiate the same. Explanation furnished by the assessee is not accepted

M/S ASHA TECHNOLOGIES,KALA AMB vs. ITO, SIRMOUR

In the result, both the above appeals of the Assessee are partly allowed as aforesaid in respect of impugned orders dt

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

1. during survey u./s 133A on 7th & 8th of December, 2009, which was annexurised as A-5. This day book for A.Y. 2007-08 was computerized and ledger and cash books were prepared, copy of which was handed to the assessee for its comments. But it failed to substantiate the same. Explanation furnished by the assessee is not accepted

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