M/S CREDO ASSETS PVT. LTD.,RUPNAGAR PUNJAB vs. DCIT/ACIT(CEN)-1 CHD, CHANDIGARH

The appeals stand partly allowed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No.487/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2013-14) M/S Singla Builders & Promoters Ltd. Dcit / Acit Central-1 बनाम/ Plot No 1265, Sector 82, Industrial Area C.R. Building, Sector 17 Vs. Rupnagar (Punjab) 140308 Chandigarh-160017 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaocs-6503-M (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकर अपील सं. / Ita No.482/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2017-18) & 3. आयकर अपील सं. / Ita No.484/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2018-19) M/S Credo Assets Private Ltd. Dcit / Acit Central-1 बनाम/ Plot No 1265-C, Sector 82, Industrial Area C.R. Building, Sector 17 Vs. Rupnagar (Punjab) 140308 Chandigarh-160017 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aafcc-6400-L (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Parikshit Aggarwal (Ca) & Smt. Shruti Khandelwal (Ca) – Ld. Ars ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) & Shri Rajat Kumar Kureel (Cit) – Ld. Drs (Virtual) Date Of Final Hearing : 27-01-2026 Date Of Pronouncement : 03-02-2026

section (6) of Sec.142A was not complied with in the present case and the report of DVO was to be discarded since DVO became functus officio on 30-09-2022. 4.2 In support of the above contention, it was reiterated that inspection of few of the projects was carried out even after 30-09-2022 as tabulated below: - Company & Date

M/S SINGLA BUILDERS AND PROMOTERS LIMITED,RUPNAGAR, PUNJAB vs. DCIT/ACIT(CEN)-1 CHD, CHANDIGARH

The appeals stand partly allowed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No.487/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2013-14) M/S Singla Builders & Promoters Ltd. Dcit / Acit Central-1 बनाम/ Plot No 1265, Sector 82, Industrial Area C.R. Building, Sector 17 Vs. Rupnagar (Punjab) 140308 Chandigarh-160017 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaocs-6503-M (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकर अपील सं. / Ita No.482/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2017-18) & 3. आयकर अपील सं. / Ita No.484/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2018-19) M/S Credo Assets Private Ltd. Dcit / Acit Central-1 बनाम/ Plot No 1265-C, Sector 82, Industrial Area C.R. Building, Sector 17 Vs. Rupnagar (Punjab) 140308 Chandigarh-160017 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aafcc-6400-L (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Parikshit Aggarwal (Ca) & Smt. Shruti Khandelwal (Ca) – Ld. Ars ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) & Shri Rajat Kumar Kureel (Cit) – Ld. Drs (Virtual) Date Of Final Hearing : 27-01-2026 Date Of Pronouncement : 03-02-2026

section (6) of Sec.142A was not complied with in the present case and the report of DVO was to be discarded since DVO became functus officio on 30-09-2022. 4.2 In support of the above contention, it was reiterated that inspection of few of the projects was carried out even after 30-09-2022 as tabulated below: - Company & Date

M/S CREDO ASSETS PVT. LTD.,RUPNAGAR PUNJAB vs. DCIT/ACIT(CEN)-1 CHD, CHANDIGARH

The appeals stand partly allowed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No.487/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2013-14) M/S Singla Builders & Promoters Ltd. Dcit / Acit Central-1 बनाम/ Plot No 1265, Sector 82, Industrial Area C.R. Building, Sector 17 Vs. Rupnagar (Punjab) 140308 Chandigarh-160017 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaocs-6503-M (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकर अपील सं. / Ita No.482/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2017-18) & 3. आयकर अपील सं. / Ita No.484/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2018-19) M/S Credo Assets Private Ltd. Dcit / Acit Central-1 बनाम/ Plot No 1265-C, Sector 82, Industrial Area C.R. Building, Sector 17 Vs. Rupnagar (Punjab) 140308 Chandigarh-160017 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aafcc-6400-L (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Parikshit Aggarwal (Ca) & Smt. Shruti Khandelwal (Ca) – Ld. Ars ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) & Shri Rajat Kumar Kureel (Cit) – Ld. Drs (Virtual) Date Of Final Hearing : 27-01-2026 Date Of Pronouncement : 03-02-2026

section (6) of Sec.142A was not complied with in the present case and the report of DVO was to be discarded since DVO became functus officio on 30-09-2022. 4.2 In support of the above contention, it was reiterated that inspection of few of the projects was carried out even after 30-09-2022 as tabulated below: - Company & Date

SH.ASHOK KUMAR GUPTA,LUDHIANA vs. PR.CIT-1, LUDHIANA

In the result, the appeal of the assessee is allowed

property. Hence claim of deduction under section 54 of I.T. Act 1961 is not correct and also the AO has wrongly allowed the benefit of deduction u/s 54 of Income Tax Act, 1961 to ttie extent of Rs.2,05,93,405/- (3,32,39,346-1,26,43,941 )on account of modification in residential house bearing House

M/S Y.D. SOLUTIONS,CHANDIGARH vs. ITO, W-4(5), CHANDIGARH

In the result, the appeal of the assessee is dismissed

6. Copy of Assignment of Lease agreement dated 27/02/2012 between Y.D. Solutions, M/s. Spray Engineering Devices Ltd. and Dishnet Wireless Ltd. (PB-44-49) 7. Copy of Lease deed dated 18/04/2012 between Y.D. Solutions and M/s. Spray Engineering Devices Ltd. (PB-50-52) 8. It was also pointed out that in the preceding assessment year when the rental income

M/S FATEH HOMES PRIVATE LIMITED,CHANDIGARH vs. ITO WARD-1(4), CHANDIGARH

In the result, the appeal of the assessee is partly allowed

house property, which is governed by the provisions of chapter IV-C of the Act. As per the charging section 22, the annual value of the property is charged to tax, which annual value has been defined u/s 23 of the Act. The remaining sections deal with deductions from the annual value and provisions relating to arrears of rent

ACIT, CIRCLE, SHIMLA vs. SHRI VINOD SHARMA, NEW DELHI

In the result, the appeal of the Revenue is dismissed

Bench: Shri A.D. Jain & Dr Krinwant Sahayआयकर अपील सं./ Ita No. 1449/Chd/2019 "नधा"रण वष" / Assessment Year: 2015-16 The Acit, Vs. Shri Vinod Sharma, बनाम B-1/3, Circle, Safdarjang Enclave, Shimla New Delhi 110029 "थायी लेखा सं./Pan No: Abkps1560N अपीलाथ"/ Appellant ""यथ"/ Repsondent (Hybrid Mode ) "नधा"रती क" ओर से/Assessee By : Sh. Vishal Mohan, Sr. Advocate With Shri Ahninav Bazwaria, Advocate राज"व क" ओर से/ Revenue By : Smt. Kusum Bansal, Cit Dr सुनवाई क" तार"ख/Date Of Hearing : 10.06.2024 उदघोषणा क" तार"ख/Date Of Pronouncement : 09.07.2024

house and further sum of 1449-Chd-2019 Vinod Sharma, New Delhi 7 Rs. 1.01 crores towards bank charges and cost of improvement on the same. The Assessing Officer made disallowance of claim under section 54 on the ground that the Assessee entered into an agreement dated 10-2-2006 and therefore the late of agreement be treated

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

house property outside India before the amendment to section 54F made by Finance Act,2014 which has come into effect from 01/04/2015 will be entitled for deduction under section 54F of the Income Tax Act,1961. Inviting attention to paragraph 2 of the assessment order, it was submitted that the AO had rejected the claim on the reasoning that

M/S Y.D. SOLUTIONS,CHANDIGARH vs. ITO, CHANDIGARH

The appeal of the assessee is dismissed

Bench: Ms.Diva Singh & Ms. Annapurna Guptay.D. Solutions, Vs. The Income Tax Officer, 2133, Sector 38-C, Ward 4(1), Chandigarh. Chandigarh. Pan: Aabfy0386N (Appellant) (Respondent)

6. Copy of Assignment of Lease agreement dated 27/02/2012 between Y.D. Solutions, M/s. Spray Engineering Devices Ltd. and Dishnet Wireless Ltd. (PB-44-49) 7. Copy of Lease deed dated 18/04/2012 between Y.D. Solutions and M/s. Spray Engineering Devices Ltd. (PB-50-52) 8. It was also pointed out that in the preceding assessment year when the rental income

DESH MITTER GAIND,PANCHKULA vs. INCOME TAX OFFICER, WARD-1, PANCHKULA, PANCHKULA, HARYANA

Bench: This Tribunal. The Assessee Is Aggrieved By The Order Of Cit(A) Bearing No. Itba/Nfac/S/250/2023-

house property, you intend to apply the provisions of Section 50C in the case of assessee In this regard, we wish to submit that the Agreement to Sell of this property was entered by the assessee in January, 2010 i.e. in assessment year 2010-11, when the collector rate o f the property in Sector 6

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

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

Housing Development Company Limited (THDC) and so 'transfer' for the purposes of section 2(47)(v) of the Income Tax Act 1961 read with Section 2(47)(ii), 2(47)((vi) Explanation below Section 2(47) and Section 269UA had taken place7 2. Whether on the facts and circumstances of the case

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

In the result, the appeal of the Revenue is dismissed

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

Housing Development Company Limited (THDC) and so 'transfer' for the purposes of section 2(47)(v) of the Income Tax Act 1961 read with Section 2(47)(ii), 2(47)((vi) Explanation below Section 2(47) and Section 269UA had taken place? 2. Whether on the facts and circumstances of the case

ROPAR DISTRICT CO-OPERATIVE UNION LIMITED,MOHALI vs. PCIT, CHANDIGAR-1, CHANDIGARH

In the result, the appeal is allowed

Bench: SHRI AAKASH DEEPJAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)

house property” shown by the assessee in its return of income. The assessee had furnished copy of notice issued u/s 142(1), dated 25.11.2020 and notice dated 10.12.2020, notice dated 27.01.2021 and notice dated 05.02.2021 and reply dated 10.02.2021 pages 6 to 19 respectively. It was stated that the assessee had returned rental income from the three properties, amounting

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

6 months on terms and conditions stipulated there in, without transferring any right of ownership, use or possession of the property, or transferring any right over the income arising from such property to the purchaser and having decided to execute the sale deed in a future date the transaction of sale of properly was not completed in terms of section

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

6 months on terms and conditions stipulated there in, without transferring any right of ownership, use or possession of the property, or transferring any right over the income arising from such property to the purchaser and having decided to execute the sale deed in a future date the transaction of sale of properly was not completed in terms of section

RAVI BINDAL & MADAN LAL CHAUDHARY,PARWANOO vs. ITO, PARWANOO

In the result, the appeal of the assessee is treated as allowed for statistical purposes

Bench: Shri Sanjay Garg

section 24 of the Act. A perusal of the impugned order of the CIT(A) reveals that the Ld. CIT(A) has rejected the aforesaid claim of the assessee on two grounds; firstly, that the assessee has not placed the copy of the relevant loan agreement / bank papers to show that the aforesaid loan was taken for acquisition / construction

JANTA LAND PROMOTERS PRIVATE LIMITED ,MOHALI vs. INCOME TAX OFFICER WARD 6(1) CHANDIGARH , MOHALI

In the result, appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 907/Chd/2024 "नधा"रण वष" / Assessment Year : 2017-18 बनाम M/S Janta Land Promoters Pvt.Ltd. The Ito, Sco 39-42, Sector 82, Ward 6(1), Vs Mohali. Chandigarh. "थायी लेखा सं./Pan /Tan No: Aabcj3450D अपीलाथ"/Appellant ""यथ"/Respondent "नधा"रती क" ओर से/Assessee By : Shri Pankaj Bhalla, Ca राज"व क" ओर से/ Revenue By : Shri Vivek Vardhan, Addl. Cit, Sr.Dr तार"ख/Date Of Hearing : 07.05.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 30.07.2025

6 "8. True it is, that income derived from the property would always be termed as 'income' from the property, but if the property is used as 'stock- in-trade', then the said property would become or partake the character of the stock, and any income derived from the stock, would be 'income' from the business, and not income from