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

69, 69B or 69D is like an open ended hypothesis which is not supported by any specific finding that the matter shall fall under which of the specific sections and how the conditions stated therein are satisfied before the said provisions are invoked. It is like laying a general rule, which to our mind is beyond the mandate

SANJEEV KUMAR GOYAL,FATEHABAD vs. DCIT, CC-2, LUDHIANA

In the result, the appeal of the assesse is allowed

Bench: This Hon’Ble Tribunal Under Section 253 Of The Income Tax Act, 1961 As Amended From Time To Time. 2. The Assessee Is Aggrieved By The Order Of The Ld. Cit(A) Dt. 20/01/2023 In Appeal No. 10853/2018-19/It/Cit(A)-5/Ldh/2021-22 For The A.Y. 2019-20 Under Section 250(6) Of The Income Tax Act, 1961 Which Was Dismissed. Therefore The Present Second Appeal Under Section 253 Of The Income Tax Act, 1961 Before Us Against The Aforesaid Order Dt. 20/01/2023 Which Is Hereinafter Referred To As The Impugned Order.

sections 69, 69A and 69C being treated separately, because such deemed income is not income from salary, house property, profits

RAJIV KUMAR GOYAL,DHURI vs. DCIT, CC-2, LUDHIANA

In the result, the appeal of the assessee is allowed

Bench: This Hon’Ble Tribunal Under Section 253 Of The Income Tax Act, 1961 As Amended From Time To Time. 2. The Assessee Is Aggrieved By Order Of The Ld. Cit(A) Dated 03/02/2023 In Appeal No. 10850/2018-19/It/Cit(A)-5/Ldh/2021-22 For A.Y. 2019-20 Under Section 250(6) Of The Income Tax Act, 1961 Which Was Dismissed. Therefore The Present Second Appeal Under Section 253 Of The Income Tax Act, 1961 Before Us Against The Aforesaid Order Dt. 03/02/2023 Which Is Hereiafter Referred To As The Impugned Order. Factual Matrix 3. The Assessee Had For The Relevant Year I.E; A.Y. 2019-20 Was Also Engaged In The Same Business I.E; Manufacturing Of Pvc Pipes & Had Filed

sections 69, 69A, 69B and 69C being treated separately, because such deemed income is not income from salary, house property

TARLOCHAN SINGH ,BHAWANIGARH vs. DCIT, CENTRAL CIRCLE, PATIALA

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

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

69 of the Act. In case of Fashion Fashion World Vs. ACIT (IT Appeal No. 1634(Ahd.) of 10. 2006, dt. 12/02/2010), the Coordinate Ahmedabad Benches has held as under: “11. But this does not mean that loss computed under any of the five heads mentioned in section 14 – (i) ‘salary’, (ii) ‘income from house property

M/S JASHAN FINLEASE LTD.,KHANNA vs. DCIT, CC-1, LUDHIANA

In the result, the appeal of the assessee is allowed

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

69, 69B or 69D is like an open ended hypothesis which is not supported by any specific finding that the matter shall fall under which of the specific sections and how the conditions stated therein are satisfied before the said provisions are invoked. It is like laying a general rule, which to our mind is beyond the mandate

RAV SHARAN SINGH,PATIALA vs. ACIT, C.C., PATIALA

In the result, appeal of the assessee is allowed

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

69, 69B or 69D is like an open ended hypothesis which is not supported by any specific finding that the matter shall fall under which of the specific sections and how the conditions stated therein are satisfied before the said provisions are invoked. It is like laying a general rule, which to our mind is beyond the mandate

M/S VEER ENTERPRISES,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the appeal is allowed

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

69, 69B or 69D is like an open ended hypothesis which is not supported by any specific finding that the matter shall fall under which of the specific sections and how the conditions stated therein are satisfied before the said provisions are invoked. It is like laying a general rule, which to our mind is beyond the mandate

MRS. KIRAN BALA,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the appeal is allowed

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

69, 69B or 69D is like an open ended hypothesis which is not supported by any specific finding that the matter shall fall under which of the specific sections and how the conditions stated therein are satisfied before the said provisions are invoked. It is like laying a general rule, which to our mind is beyond the mandate

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

69, 69B or 69D is like an open ended hypothesis which is not supported by any specific finding that the matter shall fall under which of the specific sections and how the conditions stated therein are satisfied before the said provisions are invoked. It is like laying a general rule, which to our mind is beyond the mandate

M/S A.P. KNIT FAB,LUDHIANA vs. DCIT CC-3, LUDHIANA

In the result, the appeal of the assessee is allowed

Bench: The Ld. Cit(A) Have Not Been Appreciated. 4. That The Ld. Cit(A) Has Failed To Appreciate That During The Course Of Survey, No Other Income Was Noticed By The Department And, As Such, Taxing The Amount Offered As Deemed Income, Is Against The Facts & Circumstances Of The Case. 5. That The Ld. Cit(A) Has Also Failed To Appreciate That At The Time Of Survey, It Was Agreed That The Applicant Shall Pay The Taxes On The Amount Offered

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.

69 read with section 115BBE of the Income Tax Act, 1961. 2. That the Ld. CIT (A) has failed to appreciate the various judgments of the Jurisdictional Bench of the ITAT, Chandigarh Bench in many cases, where the amount offered during survey under similar circumstances have been taxed at the normal rate of tax especially the judgment in the case

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)

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

ANILJIT SINGH ARORA,PATIALA vs. ACIT DCIT CEN CIR , PATIALA, PATIALA

In the result, the appeal of the assessee is allowed

Bench: SHRI. SANJAY GARG (Judicial Member), SHRI. VIKRAM SINGH YADAV (Accountant Member)

House No. 153, Ajit Nagar Central Circle Patiala, Punjab - 147001 Patiala "थायी लेखा सं./PAN NO: ADCPA4614M अपीलाथ"/Appellant ""यथ"/Respondent िनधा"रती क" ओर से/Assessee by : Shri Rakesh Cajla, Advocate राज"व क" ओर से/ Revenue by : Smt. Amanpreet Kaur, Sr. DR सुनवाई क" तारीख/Date of Hearing : 19/12/2023 उदघोषणा क" तारीख/Date of Pronouncement : 15/02/2024 आदेश/Order

SH. ABHISHEK BANSAL,BARNALA vs. PR. CIT, PATIALA

In the result, the Assessee’s appeal is partly allowed

Bench: Shri A.D. Jain & Dr Krinwant Sahayआयकर अपील सं./ Ita No. 131/Chd/2023 "नधा"रण वष" / Assessment Year : 2017-18 Abhishek Bansal, Vs. Pr. Commissioner बनाम Prop. M/S Lifeline Multi Income Tax, Specialilty Hospitality, 25 Acre Patiala Extn., Near Fountain Chowk, Barnala, Punjab "थायी लेखा सं./Pan No: Acgpb5740E अपीलाथ" ./ Appellant ""यथ" / Respondent ( Hybrid Mode ) "नधा"रती क" ओर से/Assessee By : Sh. Sudhir Sehgal, Advocate राज"व क" ओर से/ Revenue By : Shri Rohit Sharma, Cit Dr सुनवाई क" तार"ख/Date Of Hearing : 09.05.2024 उदघोषणा क" तार"ख/Date Of Pronouncement : 13.06.2024 आदेश/Order Per Dr. Krinwant Sahay, A.M.:

House Property" and Rs. 131-Chd-2023 – Shri Abhishek Bansal, Barnala 6 10,76,719/- under the head "Income from Other Sources." It is submitted that a survey action was conducted at the professional premises of the assessee on 26.09.2016. During the said survey, certain discrepancies were found and statement of the assessee was recorded. In the said statement

SMT. SHAKUNTLA DEVI,CHANDIGARH vs. ACIT, CHANDIGARH

In the result, the appeal of the assessee is allowed

House No. 506, Sector-7, Panchkula |\nThe ACIT Investigation Central Circle-1 Chandigarh |\nस्थायीलेखासं./PAN NO:\nअपीलार्थी/ Appellant |\nप्रत्यर्थी/Respondent |\n\nनिर्धारिती की ओर से/Assessee by : Shri M.R. Sharma, Advocate\nराजस्व की ओर से / Revenue by : Smt. Kusum Bansal, CIT, DR\nसुनवाई की तारीख/Date of Hearing : 11/11/2024\nउदघोषणा की तारीख / Date of Pronouncement : 06/02/2025\nआदेश/Order\nPER VIKRAM

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)

house. 2. The PCIT has wrongly enhanced the scope of scrutiny assessment while faming order under section 263 of Income Tax Act. 3. Briefly the facts of the case are that the assessee filed his return of income declaring total income of Rs. 69,52,590/-. Subsequently, return of income was selected for complete scrutiny and notice under section

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

In the result, the appeal of the Revenue is dismissed

Bench: Disposal Of Appeal.”

section 69 of IT Act. 30. While making addition of Rs. 1,73,10,000/-, the Assessing officer had duly ignored the assessee's plea that land was sold for a sum of Rs. 2,30,00,000/- on the ground that assessee had not filed any evidence. However the learned CIT(A) had treated it as if assessee

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 69 of IT Act. 30. While making addition of Rs. 1,73,10,000/-, the Assessing officer had duly ignored the assessee's plea that land was sold for a sum of Rs. 2,30,00,000/- on the ground that assessee had not filed any evidence. However the learned CIT(A) had treated it as if 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 69 of IT Act. 30. While making addition of Rs. 1,73,10,000/-, the Assessing officer had duly ignored the assessee's plea that land was sold for a sum of Rs. 2,30,00,000/- on the ground that assessee had not filed any evidence. However the learned CIT(A) had treated it as if assessee