KARNAIL SINGH,UK vs. JCIT (OSD) INTL. TAXATION, CIRCLE, CHANDIGARH

In the result, all the appeals of the assessee stands allowed

63, Police Lines Road, Near Maqbool Chandigarh Road, Amritsar, Punjab-143001 "थायी लेखा सं./PAN NO: CMZPS3965B अपीलाथ"/Appellant ""यथ"/Respondent "नधा"रती क" ओर से/Assessee by : Shri Sanat Kapoor राज"व क" ओर से/ Revenue by : Smt. Priyanka Dhar, Sr. DR सुनवाई क" तार"ख/Date of Hearing : 28/09/2022 उदघोषणा क" तार"ख/Date of Pronouncement : 18/11/2022 आदेश

KARNAIL SINGH,UK vs. JCIT (OSD) INTL. TAXATION, CIRCLE, CHANDIGARH

In the result, all the appeals of the assessee stands allowed

63, Police Lines Road, Near Maqbool Chandigarh Road, Amritsar, Punjab-143001 "थायी लेखा सं./PAN NO: CMZPS3965B अपीलाथ"/Appellant ""यथ"/Respondent "नधा"रती क" ओर से/Assessee by : Shri Sanat Kapoor राज"व क" ओर से/ Revenue by : Smt. Priyanka Dhar, Sr. DR सुनवाई क" तार"ख/Date of Hearing : 28/09/2022 उदघोषणा क" तार"ख/Date of Pronouncement : 18/11/2022 आदेश

KARNAIL SINGH,UK vs. JCIT (OSD) INTL. TAXATION, CIRCLE, CHANDIGARH

In the result, all the appeals of the assessee stands allowed

63, Police Lines Road, Near Maqbool Chandigarh Road, Amritsar, Punjab-143001 "थायी लेखा सं./PAN NO: CMZPS3965B अपीलाथ"/Appellant ""यथ"/Respondent "नधा"रती क" ओर से/Assessee by : Shri Sanat Kapoor राज"व क" ओर से/ Revenue by : Smt. Priyanka Dhar, Sr. DR सुनवाई क" तार"ख/Date of Hearing : 28/09/2022 उदघोषणा क" तार"ख/Date of Pronouncement : 18/11/2022 आदेश

KARNAIL SINGH,UK vs. JCIT (OSD) INTL. TAXATION, CIRCLE, CHANDIGARH

In the result, all the appeals of the assessee stands allowed

63, Police Lines Road, Near Maqbool Chandigarh Road, Amritsar, Punjab-143001 "थायी लेखा सं./PAN NO: CMZPS3965B अपीलाथ"/Appellant ""यथ"/Respondent "नधा"रती क" ओर से/Assessee by : Shri Sanat Kapoor राज"व क" ओर से/ Revenue by : Smt. Priyanka Dhar, Sr. DR सुनवाई क" तार"ख/Date of Hearing : 28/09/2022 उदघोषणा क" तार"ख/Date of Pronouncement : 18/11/2022 आदेश

S.SURJIT SINGH,LUDHIANA vs. PR.CIT-1, LUDHIANA

In the result, appeal of the Assessee is allowed

Bench: Smt.Diva Singh & Shri Vikram Singh Yadav

Section 54, there are time limits wherein the assessee is required to purchase a new residential property within one year before or within two years after the date of transfer of the original residential house property or construct a new residential property within three years from the date of transfer of the original residential house property. The ld PCIT observed

KANWALDEEP KAUR,CHANDIGARH vs. DCIT, CIRCLE 1, CHANDIGARH

In the result, appeal filed by the Revenue in ITA No

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

63,21,268/- on account of differencein stamp duty value and total consideration paid by assessee for purchase of immovable property. In my considered view, the main issue is what is the date to be taken for considering stamp duty value as per section 56(2)(vii)(b). AO has taken date of tri-partite agreement dated 02.02.2015 while assessee

INCOME TAX OFFICER, MOHALI vs. GURTEJ SINGH, MOHALI

In the result, appeal filed by the Revenue in ITA No

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

63,21,268/- on account of differencein stamp duty value and total consideration paid by assessee for purchase of immovable property. In my considered view, the main issue is what is the date to be taken for considering stamp duty value as per section 56(2)(vii)(b). AO has taken date of tri-partite agreement dated 02.02.2015 while assessee

AJMER SINGH,MOHALI vs. ITO, W-6(5), MOHAL

In the result, the appeal of the Revenue is dismissed

Bench: Disposal Of Appeal.”

section (2) contended for on behalf of the Revenue were accepted, such difference would also be liable to be added as part of capital gains taxable under the provisions of the Income Tax Act, 1961. This would be an anomalous result which could never have been contemplated by the legislature, since the Income Tax Act, 1961 and the Gift

ITO, W-6(5), MOHALI vs. SMT. GURDEV KAUR, KHARAR

In the result, the appeal of the Revenue is dismissed

Bench: Disposal Of Appeal.”

section (2) contended for on behalf of the Revenue were accepted, such difference would also be liable to be added as part of capital gains taxable under the provisions of the Income Tax Act, 1961. This would be an anomalous result which could never have been contemplated by the legislature, since the Income Tax Act, 1961 and the Gift

AJMER SINGH,MOHALI vs. ITO, W-6(5), MOHAL

In the result, the appeal of the Revenue is dismissed

Bench: Disposal Of Appeal.”

section (2) contended for on behalf of the Revenue were accepted, such difference would also be liable to be added as part of capital gains taxable under the provisions of the Income Tax Act, 1961. This would be an anomalous result which could never have been contemplated by the legislature, since the Income Tax Act, 1961 and the Gift

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

63, the following income shall not be included in the total income of the previous year of the person in receipt of the income— (a) income derived from property held under trust wholly for charitable or religious purposes, to the extent to which such income is applied to such purposes in India; and, where any such income is accumulated

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)

63,130/- including the surrendered income. 3.1 During the course of assessment proceedings, the AO observed that the surrender relates to unexplained investment which is covered under section under section 69/69B/69C and accordingly a show cause was issued as to why the surrender amount of Rs. 50,53,000/- should not be taxed as per the provisions of Section 115BBE

SH. KRISHAN KUMAR,KHANNA vs. DCIT, CC-1, LUDHIANA

In the result, the appeal of the Assessee is allowed

Bench: Shri A.D. Jain & Shri Vikram Singh Yadav

63,646.38/- Total 100,00,000/- 100,00,000/- 28. As regards the provisions of 115BBE of the IT Act. 1961, the same is as under: - 175-Chd-2023– Shri Krishan Kumar, Khanna 4 "Tax on income referred to in section 68 or section 69 or section 69A or section 69B or section 69C or section 69D 115BBE

JOINT COMMISSIONER OF INCOME TAX (OSD), LUDHIANA vs. M/S SHEETAL INDUSTRIES , KHANNA

The appeal of the Revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahay

house property’, (iii) ‘profits and gains from business or profession’, (iv) ‘capital gains’ and (v) ‘income from other sources’ – cannot at all be adjusted against unexplained investment or expenditure. What is necessary as per Hon. Gujarat High Court is that source of acquisition of asset or expenditure should be clearly identifiable. In the case before Hon. Gujarat High Court

M/S AMARJIT & SONS,LUDHIANA vs. DCIT, CC-2, LUDHIANA

In the result, appeal of the assessee is allowed

Bench: The Ld. Cit(A) Have Not Been Appreciated.

63 of the assessee’s paper book. It was further submitted that the AO compared the physical stock as on the date of survey with the stock in the books of account of the assessee which makes it evidently clear that the Department itself accepted that the stock in question belongs to the business of the assessee. It was further

M/S SATWANT AGRO ENGINEERS,BHAWANIGARH vs. DCIT, CENTRAL CIRCLE, PATIALA

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

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

house property, profits and gains of business or profession, or capital gains, nor is it income from "other sources" because the provisions of sections 69,69A, 69B and 69C treat unexplained investment, unexplained money, bullion, etc., and unexplained expenditure as deemed income where the nature and source of investment, acquisition or expenditure, as the case may be, have not been

DHARAMPAL SAGHERA,CHANDIGARH vs. INCOME TAX OFFICER, WARD-1(4), CHANDIGARH , CHANDIGARH

In the result, the appeal of the assessee bearing ITA No

Bench: Sh. Laliet Kumar Hon’Ble & Sh. Manoj Kumar Aggarwal, Hon’Ble

House No. 55, Sector 9-A, Chandigarh, as long-term capital gain, claimed deductions under Sections 54 and 54EC of the Act. The amount was received in lieu of relinquishment of her long-standing possessory and beneficial rights in the property which she had occupied since the 1960s. 3. The assessee, along with her sister Mrs. Manpreet Singh Saghera

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

property’ or ‘investment’ for the assessee and therefore, the reference in itself was illegal and beyond the purview of Sec.142A. An identical reference was sought to be made by Ld. DDIT (inv.) u/s 132(9D) after the conclusion of search. The assessee raised similar objection which was accepted by Ld. DDIT and the valuation exercise was dropped and the proceedings