S.P. SINGLA CONSTRUCTION PRIVATE LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CHANDIGARH

In the result, the appeal is allowed

Bench: SHRI MAHAVIR SINGH (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

House No.202, GH-68, Sector 20, Panchkula. The AO further noted that the Sub Contractor firms have been used by assessee company to book bogus expenses to bring down its overall profit. The DDIT (Investigation) passed on the information to the AO of the assessee i.e. DCIT Circle-22 New Delhi and DCIT Circle 22 New Delhi after verifying

ITO, W-4, PANCHKULA vs. SMT. SEEMA BISHNOI, PANCHKULA

In the result appeal of the Department is dismissed

Bench: Shri N.K. Saini & Shri Sanjay Gargthe Ito Vs. Smt. Seema Bishnoi Ward-4, Panchkula H.No. 906, Sec-08, Panchkula

148 of the Act. The Assessing Officer observed that as per the information from DDIT (Investigation) the assessee claimed that the land purchased was an agriculture land however as per the enquiry carried out by the said office no agricultural activity was being carried out on the said land and therefore the deduction under section

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

SH. JAI RAM,JAGADHARI vs. ITO, YAMUNANAGAR

In the result, both the appeal of different assessees are allowed

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

148 of the Act. 6.1 It is further noted that the appellant has sold agricultural land for a consideration of Rs.5,50,00,000/- through a sale deed registered on 20.03.2007. As per the deed, the sale consideration comprised of Rs.8,50,000/- in cash, Rs.41,50,000/- through cheque dated 15.03.2007 and Rs.5,00,00,000/- through undated cheque

SH. AMAR SINGH,JAGADHARI vs. ITO, YAMUNANAGAR

In the result, both the appeal of different assessees are allowed

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

148 of the Act. 6.1 It is further noted that the appellant has sold agricultural land for a consideration of Rs.5,50,00,000/- through a sale deed registered on 20.03.2007. As per the deed, the sale consideration comprised of Rs.8,50,000/- in cash, Rs.41,50,000/- through cheque dated 15.03.2007 and Rs.5,00,00,000/- through undated cheque

SH. JASWINDER SINGH LOTA,MOHALI vs. DY. DIRECTOR OF INCOME TAX, CHANDIGARH

In the result, the appeal of the assessee is allowed

Bench: Ms. Diva Singh & Shri B.R.R.Kumarassessment Year: 2008-09

148 of the Income Tax Act, 1961 is against the law and facts on the file in as much as the Ld. CIT (A) was not justified to uphold the action of the Ld. AO in refusing the exemption claimed by the appellant u/s 54 of the Act ibid on the sole ground that the appellant had purchased/constructed a residential

DEVI DAYAL,KAITHAL vs. INCOME TAX OFFICER, WARD-1 , KAITHAL

In the result, appeal is allowed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 899/Chd/2024 "नधा"रण वष" / Assessment Year: 2008-09 Shri Devi Dayal, Vs The Ito, Pundri Anaj Mandi, Ward – 1, Kaithal-Haryana 136026. Kaithal. "थायी लेखा सं./Pan No: Aajpd5851H अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Parikshit Aggarwal, Ca & Ms. Shruti Khandelwal, Advocate Revenue By : Shri Manav Bansal, Cit, Dr Date Of Hearing : 30.07.2025 Date Of Pronouncement : 08.09.2025

property, as envisaged by a the parties. We are, therefore, of the view that this clause will also not rope in the present transaction. 24. The matter can also be viewed from a slightly different angle. Shri Vohra is right when he ha referred to Sections 45 and 48 of the Income Tax Act and has then argued that some

M/S GREATER MOHALI AREA DEVELOPMENT AUTHORITY,MOHALI vs. DCIT, C-6(1), MOHALI

In the result, the appeal of the assessee is hereby dismissed

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumarassessment Year : 2009-10

148 and assessment framed under section 147 of the Act for AY 2009-10. The notice had been sent to the assessee beyond 4 years and therefore, section 147 R/W Explanation 1 would be applicable to the facts of this case. The assessee has been incorporated in 2006 under the Punjab Regional And Town Planning and development

ANUP KUMAR AGGARWAL,PANCHKULA vs. ACIT(CENTRAL) SHIMLA, SHIMLA

Appeal stand allowed in terms of our above order

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No.1019/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2021-22) Sh. Anup Kumar Aggarwal Acit (Central) बनाम/ Vs. House No.218,Sector-10 Shimla 171001 Panchkula – 134113 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Adjpk-5842-L (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Ajay Jain (Ca) A/W Shri Lovesh Bansal (Ca) – Ld. Ars ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 15-09-2025 घोषणाकीतारीख /Date Of Pronouncement : 24/11/2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2021-22 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals)-3, Gurgaon [Cit(A)] Dated 31-07-2025 In The Matter Of An Assessment Framed By Ld. Ao U/S 147 Of The Act On 12-03-2025. The Assessee Is Aggrieved By Confirmation Of Additions Of Rs.10.95 Lacs U/S 69 & Another Addition Of Rs.16.21 Lacs U/S 69A. The Additions Stem From Search Action By The Department On Assessee-Group On 04-

House No.218,Sector-10 Shimla 171001 Panchkula – 134113 "ायीलेखासं./जीआइआरसं./PAN/GIR No. ADJPK-5842-L (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant by : Sh. Ajay Jain (CA) a/w Shri Lovesh Bansal (CA) – Ld. ARs ""थ"कीओरसे/Respondent by : Smt. Kusum Bansal (CIT) – Ld. DR सुनवाईकीतारीख/Date of Hearing : 15-09-2025 घोषणाकीतारीख /Date of Pronouncement : 24/11/2025 आदेश

POOJA AGGARWAL,PANCHKULA vs. ACIT(CENTRAL) SHIMLA, SHIMLA

Appeal stand allowed in terms of our above order

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No.1026/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2021-22) Ms. Pooja Aggarwal Acit Central बनाम/ Vs. House No.218,Sector-10 Shimla 171001 Panchkula – 134113 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Abnpa-6660-N (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Ajay Jain (Ca)A/W Shri Lovesh Bansal (Ca) – Ld. Ars ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 15-09-2025 घोषणाकीतारीख /Date Of Pronouncement : 24/11/2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2021-22 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals)-3, Gurgaon [Cit(A)] Dated 31-07-2025 In The Matter Of An Assessment Framed By Ld. Ao U/S 147 Of The Act On 12-03-2025. The Assessee Is Aggrieved By Confirmation Of Substantive Addition Of Rs.16.21 Lacs & Protective Addition Of Rs.10.95 Lacs. The Additions Stem From Search Action By The Department On Assessee-Group On 04-

House No.218,Sector-10 Shimla 171001 Panchkula – 134113 "ायीलेखासं./जीआइआरसं./PAN/GIR No. ABNPA-6660-N (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant by : Sh. Ajay Jain (CA)a/w Shri Lovesh Bansal (CA) – Ld. ARs ""थ"कीओरसे/Respondent by : Smt. Kusum Bansal (CIT) – Ld. DR सुनवाईकीतारीख/Date of Hearing : 15-09-2025 घोषणाकीतारीख /Date of Pronouncement : 24/11/2025 आदेश

ANUP KUMAR AGGARWAL,PANCHKULA vs. ACIT(CENTRAL) SHIMLA, SHIMLA

Appeal stand allowed in terms of our above order

Bench: SHRI RAJPAL YADAV (Vice President), SHRI MANOJ KUMAR AGGARWAL (Accountant Member)

House No.218,Sector-10 Shimla 171001 Panchkula – 134113 "ायीलेखासं./जीआइआरसं./PAN/GIR No. ADJPK-5842-L (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant by : Sh. Ajay Jain (CA)a/w Shri Lovesh Bansal (CA) – Ld. ARs ""थ"कीओरसे/Respondent by : Smt. Kusum Bansal (CIT) – Ld. DR सुनवाईकीतारीख/Date of Hearing : 15-09-2025 घोषणाकीतारीख /Date of Pronouncement : 24/11/2025 आदेश

DCIT, CC-3, LUDHIANA, KITCHLU NAGAR vs. MANI RAM BALWANT RAI HUF, CIVIL LINES

In the result, Cross Objection filed by the assessee is allowed and appeal of the Revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 1042/Chd/2024 "नधा"रण वष" / Assessment Year: 2019-20 The Dcit, Mani Ram Balwant Rai, Huf, Central Circle-3, Vs Civil Lines, Opposite Session Court(Old) Kitchlu Nagar, Ludhiana. Ludhiana. "थायी लेखा सं./Pan No: Aaghm1535C अपीलाथ"/Appellant ""यथ"/Respondent & C.O. 43/Chd/2024 In आयकर अपील सं./ Ita No. 1042/Chd/2024 "नधा"रण वष" / Assessment Year: 2019-20 Mani Ram Balwant Rai, Huf, The Dcit, Civil Lines, Opposite Session Court(Old) V Central Circle-3, Ludhiana. S Kitchlu Nagar, Ludhiana. "थायी लेखा सं./Pan No: Aaghm1535C अपीलाथ"/Appellant ""यथ"/Respondent Revenue By : Smt. Kusum Bansal, Cit Dr Assessee By : Shri Pankaj Bhalla, Ca & Shri Hunny Bajaj, Advocate Date Of Hearing : 17.07.2025 Date Of Pronouncement : 01.09.2025 Hybrid Hearing O R D E R Per Rajpal Yadav, Vp

Section 151A of the Income Tax Act. According to this Notification, the notices for re-opening were required to be issued by the Faceless Authority instead of jurisdictional AO. In the present case, 148 notice has been issued on 29.03.2022 by jurisdictional AO instead of Faceless AO, hence, this assessment order is not sustainable in the eyes of various judgements

ITO, W-4, PANCHKULA vs. MRS. SUNITA, PANCHKULA

In the result, the appeal of the Revenue is dismissed

Bench: Smt. Diva Singh & Shri B.R.R. Kumarassessment Year: 2008-09

property Act and Registration Act were not conclusive for interpretation of provisions of Income Tax Act? 17. Whether on the facts and circumstances of the case and in law Ld. CIT(A) is right in holding that the provisions of section 2(47)(ii) are not applicable when all the member of society surrendered their individual rights in the plots