SH. KRISHAN KUMAR GOYAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

In the result, both the appeals of the assessee stand allowed

Bench: Shri Sanjay Garg & Ms. Annapurna Guptaआयकर अपील सं./ Ita No. 226/Chd/2019 "नधा"रण वष" / Assessment Year : 2007-08 The Dcit, Shri Krishan Kumar Goyal, बनाम Central Circle-1, Prop Sagar Enterprise, Chandigarh Scf 153, Sector 26, Grain Market, Chandigarh "थायी लेखा सं./Pan No. Agipk9063H अपीलाथ"/Appellant ""यथ"/Respondent & आयकर अपील सं./ Ita No. 456/Chd/2019 "नधा"रण वष" / Assessment Year : 2007-08 The Dcit, Shri Krishan Kumar Goyal, बनाम Central Circle-1, Prop Sagar Enterprise, Chandigarh Scf 153, Sector 26, Grain Market, Chandigarh "थायी लेखा सं./Pan No. Agipk9063H अपीलाथ"/Appellant ""यथ"/Respondent

3) had been annulled by higher authorities on the ground of legality of notice u/s. 143(2) of the Act, re-opening u/s. 147 on that very ground would mean nothing else but the abuse of process of law. Hence, the contention of the learned DR that as the return was processed u/s. 143(1) and it was a mere

SSMT. CHARU AGGARWAL,PATIALA vs. DCIT-CC, PATIALA

In the result, appeals of both the assesses are allowed

271 (SC) • CIT vs Kamdhenu Steel and Alloys Ltd. 248 CTR 33 (Del.) • Infomediary India (P) Ltd. and Ors. Vs CIT 206 Taxman 254 • CIT vs. Smt. P. K. Noorjahan 237 ITR 570 (SC) 6.3 It was stated before the Ld. CIT(A) that the A.O. had not disputed, the entire purchase and sales of the assessee, books of accounts

KALANEEDHI JEWELLERS LLP,PATIALA vs. DCIT-CC, PATIALA

In the result, appeals of both the assesses are allowed

271 (SC) • CIT vs Kamdhenu Steel and Alloys Ltd. 248 CTR 33 (Del.) • Infomediary India (P) Ltd. and Ors. Vs CIT 206 Taxman 254 • CIT vs. Smt. P. K. Noorjahan 237 ITR 570 (SC) 6.3 It was stated before the Ld. CIT(A) that the A.O. had not disputed, the entire purchase and sales of the assessee, books of accounts

DCIT, C-5, LUDHIANA vs. M/S HERO CYCLES LTD., LUDHIANA

In the result, appeal of the Department is dismissed and the Cross

226/- while the investment as on 31.3.2008 is of Rs.4,64,37,73,922. Therefore, there was an increase of around Rs.80 crores in the investment during the year . While reserves and own funds of the assessee company as on 31.3.2008 are amounting to Rs.6,24,18,74,854/- . From these figures, it is quite clear that own funds

M/S PUNJAB INFRASTRUCTURE DEVELOPMENT BOARD,CHANDIGARH vs. ACIT (TDS), CHANDIGARH

Bench: Shri Sanjay Garg & Ms. Annapurna Gupta

226 (SC) However, the Assessing officer observed that the decision cited by the assessee was not applicable to the facts and circumstances of the case. The Assessing officer observed that since the assessee / PR had failed to collect and deposit tax u/s 206C of the Act, therefore, the assessee was liable to be held as ‘assessee in default’ u/s 206C

PUNJAB INFRASTRUCTURE DEVELOPMENT BOARD,CHANDIGARH vs. JCIT (TDS), CHANDIGARH

Bench: Shri Sanjay Garg & Ms. Annapurna Gupta

226 (SC) However, the Assessing officer observed that the decision cited by the assessee was not applicable to the facts and circumstances of the case. The Assessing officer observed that since the assessee / PR had failed to collect and deposit tax u/s 206C of the Act, therefore, the assessee was liable to be held as ‘assessee in default’ u/s 206C

M/S PUNJAB INFRASTRUCTURE DEVELOPMENT BOARD,CHANDIGARH vs. ACIT (TDS), CHANDIGARH

Bench: Shri Sanjay Garg & Ms. Annapurna Gupta

226 (SC) However, the Assessing officer observed that the decision cited by the assessee was not applicable to the facts and circumstances of the case. The Assessing officer observed that since the assessee / PR had failed to collect and deposit tax u/s 206C of the Act, therefore, the assessee was liable to be held as ‘assessee in default’ u/s 206C

PUNJAB INFRASTRUCTURE DEVELOPMENT BOARD,CHANDIGARH vs. JCIT (TDS), CHANDIGARH

Bench: Shri Sanjay Garg & Ms. Annapurna Gupta

226 (SC) However, the Assessing officer observed that the decision cited by the assessee was not applicable to the facts and circumstances of the case. The Assessing officer observed that since the assessee / PR had failed to collect and deposit tax u/s 206C of the Act, therefore, the assessee was liable to be held as ‘assessee in default’ u/s 206C

PUNJAB INFRASTRUCTURE DEVELOPMENT BOARD,CHANDIGARH vs. JCIT (TDS), CHANDIGARH

Bench: Shri Sanjay Garg & Ms. Annapurna Gupta

226 (SC) However, the Assessing officer observed that the decision cited by the assessee was not applicable to the facts and circumstances of the case. The Assessing officer observed that since the assessee / PR had failed to collect and deposit tax u/s 206C of the Act, therefore, the assessee was liable to be held as ‘assessee in default’ u/s 206C

PUNJAB INFRASTRUCTURE DEVELOPMENT BOARD,CHANDIGARH vs. JCIT (TDS), CHANDIGARH

Bench: Shri Sanjay Garg & Ms. Annapurna Gupta

226 (SC) However, the Assessing officer observed that the decision cited by the assessee was not applicable to the facts and circumstances of the case. The Assessing officer observed that since the assessee / PR had failed to collect and deposit tax u/s 206C of the Act, therefore, the assessee was liable to be held as ‘assessee in default’ u/s 206C

DCIT, LUDHIANA vs. M/S PALACE JEWELLERS PVT. LTD., LUDHIANA

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

Bench: Ms. Diva Singh & Ms. Annapurna Gupta

271 AAB of the income tax act, 1961 on account of any item of jewellery/cash and/or any addition as may be liable to be made on account of profits earned/investment made in some unrecorded transactions as may be later adjudged, opined, considered to be in excess of what already stood recorded in the books regularly maintained as had been shown

PALACE JEWELLERS PVT. LTD.,LUDHIANA vs. DCIT, LUDHIANA

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

Bench: Ms. Diva Singh & Ms. Annapurna Gupta

271 AAB of the income tax act, 1961 on account of any item of jewellery/cash and/or any addition as may be liable to be made on account of profits earned/investment made in some unrecorded transactions as may be later adjudged, opined, considered to be in excess of what already stood recorded in the books regularly maintained as had been shown

M/S CHANDIGARH BOTTLING CO.,CHANDIGARH vs. ACIT, CHANDIGARH

In the result, appeals of the assessee are allowed

Bench: Ms. Diva Singh & Dr.B.R.R.Kumar & Assessment Year: 2006-07

3 decisions of the Hon'ble Apex Court reported in 226 ITR 625; 231 ITR 775 & 249 ITR 214, wherein it has been held that registered deed is not a prerequisite for ownership with reference to section 32(1) of the Income Tax Act, 1961. 13 Respectfully following the decision of Hon'ble Supreme Court, I hold that transfer