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

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

7%; that the Tribunal, therefore, did not commit any error in accepting the gross profit rate of 8% on the purchases, which were otherwise found in-genuine; that the disclosure of Rs.61.05 lacs made by the assessee in his statement pertained to the bogus purchases and was, therefore, rightly assessed by the ld. CIT(A) and the Tribunal; that

SANJEEV KUMAR KATHURIA,YAMUNA NAGAR vs. INCOME TAX OFFICER WARD 1 , YAMUNANAGAR

In the result, the appeal of the assessee is allowed

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

40A(3) of the Act amounting to Rs. 12,09,560/-. 4. Subsequently, the assessment records were called for and examined by the Ld. PCIT, Panchkula and a show cause under section 263 dt. 12/12/2023 was issued by the Ld. PCIT and the contents thereof read as under: “Perusal of assessment record reveals that you had sold a residential property

M/S AJAY KUMAR SOOD ENGINEERS & CONTRACTORS,SHIMLA vs. DCIT, CHANDIGARH

The appeal of the Revenue is hereby dismissed

Bench: Smt. Diva Singh & Dr. B.R.R. Kumar

Section 40A(3) are not attracted to this transaction and hence the addition is hereby directed to be deleted. Regarding the amount of Rs. 21,275/- it was submitted that it was used for purchase of material at the site of Sanjauli for urgent requirement. Owing to the business expediency, the amount involved in the purpose intended we hereby delete

M/S AJAY KUMAR SOOD ENGINEERS & CONTRACTORS,SHIMLA vs. DCIT, CHANDIGARH

The appeal of the Revenue is hereby dismissed

Bench: Smt. Diva Singh & Dr. B.R.R. Kumar

Section 40A(3) are not attracted to this transaction and hence the addition is hereby directed to be deleted. Regarding the amount of Rs. 21,275/- it was submitted that it was used for purchase of material at the site of Sanjauli for urgent requirement. Owing to the business expediency, the amount involved in the purpose intended we hereby delete

M/S AJAY KUMAR SOOD ENGINEERS & CONTRACTORS,SHIMLA vs. DCIT, CHANDIGARH

The appeal of the Revenue is hereby dismissed

Bench: Smt. Diva Singh & Dr. B.R.R. Kumar

Section 40A(3) are not attracted to this transaction and hence the addition is hereby directed to be deleted. Regarding the amount of Rs. 21,275/- it was submitted that it was used for purchase of material at the site of Sanjauli for urgent requirement. Owing to the business expediency, the amount involved in the purpose intended we hereby delete

M/S AJAY KUMAR SOOD ENGINEERS & CONTRACTORS,SHIMLA vs. DCIT, CHANDIGARH

The appeal of the Revenue is hereby dismissed

Bench: Smt. Diva Singh & Dr. B.R.R. Kumar

Section 40A(3) are not attracted to this transaction and hence the addition is hereby directed to be deleted. Regarding the amount of Rs. 21,275/- it was submitted that it was used for purchase of material at the site of Sanjauli for urgent requirement. Owing to the business expediency, the amount involved in the purpose intended we hereby delete

DCIT, CHANDIGARH vs. M/S AJAY KUMAR SOOD ENGINEERS AND CONTRACTORS, SHIMLA

The appeal of the Revenue is hereby dismissed

Bench: Smt. Diva Singh & Dr. B.R.R. Kumar

Section 40A(3) are not attracted to this transaction and hence the addition is hereby directed to be deleted. Regarding the amount of Rs. 21,275/- it was submitted that it was used for purchase of material at the site of Sanjauli for urgent requirement. Owing to the business expediency, the amount involved in the purpose intended we hereby delete

SH. AJAY GOEL,SHIMLA vs. DCIT, CHANDIGARH

The appeal of the Revenue is hereby dismissed

Bench: Smt. Diva Singh & Dr. B.R.R. Kumar

Section 40A(3) are not attracted to this transaction and hence the addition is hereby directed to be deleted. Regarding the amount of Rs. 21,275/- it was submitted that it was used for purchase of material at the site of Sanjauli for urgent requirement. Owing to the business expediency, the amount involved in the purpose intended we hereby delete

M/S AJAY KUMAR SOOD ENGINEERS & CONTRACTORS,SHIMLA vs. DCIT, CHANDIGARH

The appeal of the Revenue is hereby dismissed

Bench: Smt. Diva Singh & Dr. B.R.R. Kumar

Section 40A(3) are not attracted to this transaction and hence the addition is hereby directed to be deleted. Regarding the amount of Rs. 21,275/- it was submitted that it was used for purchase of material at the site of Sanjauli for urgent requirement. Owing to the business expediency, the amount involved in the purpose intended we hereby delete

M/S AJAY KUMAR SOOD ENGINEERS & CONTRACTORS,SHIMLA vs. DCIT, CHANDIGARH

The appeal of the Revenue is hereby dismissed

Bench: Smt. Diva Singh & Dr. B.R.R. Kumar

Section 40A(3) are not attracted to this transaction and hence the addition is hereby directed to be deleted. Regarding the amount of Rs. 21,275/- it was submitted that it was used for purchase of material at the site of Sanjauli for urgent requirement. Owing to the business expediency, the amount involved in the purpose intended we hereby delete

SH. GURINDER MAKKAR,LUDHIANA vs. DCIT, CC-3, LUDHIANA

In the result, the appeal of the assessee is disposed off in light of aforesaid directions

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

40A(3) of the Act. 6.1 It was submitted that during the course of survey action as well as during the course of assessment proceedings, no other source of income has been identified and all the income which accrues to assessee is on account of its regular business of manufacturing and selling of hosiery goods and fabrics which the assessee

ASSISSTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, EXEMPTION, CHANDIGARH, CHANDIGARH vs. HERITAGE EDUCATIONAL SOCIETY, C/O DELHI PUBLIC SCHOOL

In the result, all the appeals filed by the Department

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

7 with Sections 13(3) and 164(2) thereof invoking the provisions of Section 40A(2)(b), holding such payment to be unreasonable. For this, the AO held that what was allowed as per the Memorandum of Association of the assessee Society was reimbursement of travel and other bonafide expenses, if they were incurred for attending meetings on behalf

ASSISSTANT COMMISSONER OF INCOME TAX, CIRCLE-1, EXEMPTION, CHANDIGARH, CHANDIGARH vs. HERITAGE EDUCATIONAL SOCIETY, C/O DELHI PUBLIC SCHOOL

In the result, all the appeals filed by the Department

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

7 with Sections 13(3) and 164(2) thereof invoking the provisions of Section 40A(2)(b), holding such payment to be unreasonable. For this, the AO held that what was allowed as per the Memorandum of Association of the assessee Society was reimbursement of travel and other bonafide expenses, if they were incurred for attending meetings on behalf

ASSISSTANT COMMISSIONER OF INCOME TAX, CIRCLE-1,EXEMPTION,CHANDIGARH, CHANDIGARH vs. HERITAGE EDUCATIONAL SOCIETY, C/O DELHI PUBLIC SCHOOL

In the result, all the appeals filed by the Department

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

7 with Sections 13(3) and 164(2) thereof invoking the provisions of Section 40A(2)(b), holding such payment to be unreasonable. For this, the AO held that what was allowed as per the Memorandum of Association of the assessee Society was reimbursement of travel and other bonafide expenses, if they were incurred for attending meetings on behalf

ASSISSTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, CHANDIGARH, CHANDIGARH vs. HERITAGE EDUCATION SOCIETY , C/O DELHI PUBLIC SCHOOL

In the result, all the appeals filed by the Department

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

7 with Sections 13(3) and 164(2) thereof invoking the provisions of Section 40A(2)(b), holding such payment to be unreasonable. For this, the AO held that what was allowed as per the Memorandum of Association of the assessee Society was reimbursement of travel and other bonafide expenses, if they were incurred for attending meetings on behalf

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

house, which is owned by Sarashri Sanjay Sardana and Sh. Sandeep Sardana, who are drawing salary as Principal and Director of the Society. The rent which is paid by the Society is being taken into consideration as perquisite in the hands of Sh. Sanjay Sardana and Sh. Sandeep Sardana in their income tax returns. ii. For the purpose of payment

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

house, which is owned by Sarashri Sanjay Sardana and Sh. Sandeep Sardana, who are drawing salary as Principal and Director of the Society. The rent which is paid by the Society is being taken into consideration as perquisite in the hands of Sh. Sanjay Sardana and Sh. Sandeep Sardana in their income tax returns. ii. For the purpose of payment

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

house, which is owned by Sarashri Sanjay Sardana and Sh. Sandeep Sardana, who are drawing salary as Principal and Director of the Society. The rent which is paid by the Society is being taken into consideration as perquisite in the hands of Sh. Sanjay Sardana and Sh. Sandeep Sardana in their income tax returns. ii. For the purpose of payment