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 would constitute transfer. Thus, according to him, the case of the assessee falls within sub- clause (iv) and (vi) of Section 2(47) of the Income Tax Act. 11. We have duly considered the rival contentions and gone through the record carefully. There is no dispute qua the fact that agricultural land measuring 24 kanal 9 marla situated

DCIT, C-,1 (E), CHANDIGARH vs. M/S PUNJAB MEDICAL FOUNDATION CHARITABLE TRUST, JALANDHAR

In the result, appeal of the Revenue is dismissed

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-"नधा"रण वष"/ Asstt.Year: 2014-15 Dcit, Cir.1(Exemption) M/S.Punjab Medical Foundation Chandigarh. Vs. Charitable Trust 63-64, Waryam Nagar Cool Road, Jalandhar Pan : Aaatp 5171 B (Applicant) (Responent) : Shri Sudhir Sehal, Advocate Assessee By Revenue By : Shri Ashok K. Khana, Addl.Cit सुनवाई क" तार"ख/Date Of Hearing : 18/11/2020 घोषणा क" तार"ख /Date Of Pronouncement: 21/12/2020 आदेश/O R D E R

251 CTR Page 237 2 The A.O. stated that profit rate of Pharmacy is being run on 20.02 is commercial where as he commercial basis himself accepted 22.43% during 6 previous year (2014-2015 Asstt. Yr.) and his predecessor during all the previous years. The entire profit is utilized for the fulfillment of the objects of the society, which

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)

House Clamp, Cable, Cable Lug, Jointing Sleeve, Tie Strap, Insulating Cover, Plastic Feeder Clamps, Adaptor, Threaded Rod, Screw, Nuts, Washer, Marking Label, Ladder, Ladder Joint, Ladder Hook, Pendulum, Wall Bracket, Flexible Conductor, lug, Bolt, Junction, Angle Support, Rivet, Tube Holder, Cable Chute, Modular Box etc. etc. The purchase bills of these materials by the assessee firm also clearly mention

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)

House Clamp, Cable, Cable Lug, Jointing Sleeve, Tie Strap, Insulating Cover, Plastic Feeder Clamps, Adaptor, Threaded Rod, Screw, Nuts, Washer, Marking Label, Ladder, Ladder Joint, Ladder Hook, Pendulum, Wall Bracket, Flexible Conductor, lug, Bolt, Junction, Angle Support, Rivet, Tube Holder, Cable Chute, Modular Box etc. etc. The purchase bills of these materials by the assessee firm also clearly mention

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)

251 ITR 522 (SC)] has held that the locker rent received by the assessee was a part of ordinary banking business as shown by section 6(1)(a) of the Banking (Regulation) Act, 1949 and, therefore, the income derived by the assessee bank from hiring out of safe deposit vaults was income from banking business and deductible u/s.80P(2

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

251(1) regarding alleged understatement of investment in\nproperty at 28/6, Industrial Area, Phase-2, Chandigarh.\nIssue 5 : Directions by CIT(A) to AO to initiate 147/148 proceedings taking shelter of\ns. 150(1)(2) for AY 2010-11 and 2012-13.\nIssue 6: Shortage of stock found during search held as undisclosed sale.\nIssue 7: Commission/profit earned at estimated

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

251(1) regarding alleged understatement of investment in\nproperty at 28/6, Industrial Area, Phase-2, Chandigarh.\nIssue 5 : Directions by CIT(A) to AO to initiate 147/148 proceedings taking shelter of\ns. 150(1)(2) for AY 2010-11 and 2012-13.\nIssue 6: Shortage of stock found during search held as undisclosed sale.\nIssue 7: Commission/profit earned at estimated

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

251(1) regarding alleged understatement of investment in\nproperty at 28/6, Industrial Area, Phase-2, Chandigarh.\nIssue 5 : Directions by CIT(A) to AO to initiate 147/148 proceedings taking shelter of\ns. 150(1)(2) for AY 2010-11 and 2012-13.\nIssue 6: Shortage of stock found during search held as undisclosed sale.\nIssue 7: Commission/profit earned at estimated

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

251(1) regarding alleged understatement of investment in\nproperty at 28/6, Industrial Area, Phase-2, Chandigarh.\nIssue 5 : Directions by CIT(A) to AO to initiate 147/148 proceedings taking shelter of\ns.150(1)(2) for AY 2010-11 and 2012-13.\nIssue 6: Shortage of stock found during search held as undisclosed sale.\nIssue 7: Commission/profit earned at estimated rate

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

251(1) regarding alleged understatement of investment in\nproperty at 28/6, Industrial Area, Phase-2, Chandigarh.\nIssue 5 : Directions by CIT(A) to AO to initiate 147/148 proceedings taking shelter of\ns.150(1)(2) for AY 2010-11 and 2012-13.\nIssue 6: Shortage of stock found during search held as undisclosed sale.\nIssue 7: Commission/profit earned at estimated rate

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

251(1) regarding alleged understatement of investment in\nproperty at 28/6, Industrial Area, Phase-2, Chandigarh.\nIssue 5 : Directions by CIT(A) to AO to initiate 147/148 proceedings taking shelter of\ns.150(1)(2) for AY 2010-11 and 2012-13.\nIssue 6: Shortage of stock found during search held as undisclosed sale.\nIssue 7: Commission/profit earned at estimated rate

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

251(1) regarding alleged understatement of investment in\nproperty at 28/6, Industrial Area, Phase-2, Chandigarh.\nIssue 5 : Directions by CIT(A) to AO to initiate 147/148 proceedings taking shelter of\ns.150(1)(2) for AY 2010-11 and 2012-13.\nIssue 6: Shortage of stock found during search held as undisclosed sale.\nIssue 7: Commission/profit earned at estimated rate

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

251(1) regarding alleged understatement of investment in\nproperty at 28/6, Industrial Area, Phase-2, Chandigarh.\nIssue 5 : Directions by CIT(A) to AO to initiate 147/148 proceedings taking shelter of\ns.150(1)(2) for AY 2010-11 and 2012-13.\nIssue 6: Shortage of stock found during search held as undisclosed sale.\nIssue 7: Commission/profit earned at estimated rate

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

251(1) regarding alleged understatement of investment in\nproperty at 28/6, Industrial Area, Phase-2, Chandigarh.\nIssue 5 : Directions by CIT(A) to AO to initiate 147/148 proceedings taking shelter of\ns.150(1)(2) for AY 2010-11 and 2012-13.\nIssue 6: Shortage of stock found during search held as undisclosed sale.\nIssue 7: Commission/profit earned at estimated rate

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

251(1) regarding alleged understatement of investment in\nproperty at 28/6, Industrial Area, Phase-2, Chandigarh.\nIssue 5 : Directions by CIT(A) to AO to initiate 147/148 proceedings taking shelter of\ns.150(1)(2) for AY 2010-11 and 2012-13.\nIssue 6: Shortage of stock found during search held as undisclosed sale.\nIssue 7: Commission/profit earned at estimated rate

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

251(1) regarding alleged understatement of investment in\nproperty at 28/6, Industrial Area, Phase-2, Chandigarh.\nIssue 5 : Directions by CIT(A) to AO to initiate 147/148 proceedings taking shelter of\ns.150(1)(2) for AY 2010-11 and 2012-13.\nIssue 6: Shortage of stock found during search held as undisclosed sale.\nIssue 7: Commission/profit earned at estimated rate

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

251(1) regarding alleged understatement of investment in\nproperty at 28/6, Industrial Area, Phase-2, Chandigarh.\nIssue 5 : Directions by CIT(A) to AO to initiate 147/148 proceedings taking shelter of\ns.150(1)(2) for AY 2010-11 and 2012-13.\nIssue 6: Shortage of stock found during search held as undisclosed sale.\nIssue 7: Commission/profit earned at estimated rate

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

251(1) regarding alleged understatement of investment in\nproperty at 28/6, Industrial Area, Phase-2, Chandigarh.\nIssue 5 : Directions by CIT(A) to AO to initiate 147/148 proceedings taking shelter of\ns.150(1)(2) for AY 2010-11 and 2012-13.\nIssue 6: Shortage of stock found during search held as undisclosed sale.\nIssue 7: Commission/profit earned at estimated rate