M/S APEEJAY EDUCATION SOCIETY,JALANDHAR vs. DCIT, C-1 (EXEMPTIONS), CHANDIGARH

In the result, the appeal is allowed

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

section 271(1 )(b) of the act was passed. 02.12.2019 Hon'ble Punjab & Haryana High Court had granted a stay on the assessment proceedings. 8. In ‘Asian Paints Ltd. Vs Dy. Commissioner of Income Tax’, 296 ITR 90 (Bom), it has been held that in case the AO does not accept the objections filed by the assessee against the notice

SURINDER SINGH RYAIT,LUDHIANA vs. DCIT, CC-II, LUDHIANA

In the result, appeal of the Assessee is allowed

Bench: This Tribunal. The Assesse Is Aggrieved By The Order Bearing Number: 09/It/Cit(A)-5/Ldh/2017-18 Dt. 29/08/2019 Passed Under Section 154 Of The Act Which Is Hereinafter Referred To As The “Impugned Order”. The Relevant Assessment Year Is 2015-16 & The Corresponding Previous Year Period Is From 01/04/2014 To 31/03/2015. 2. Factual Matrix 2.1 That By An Order In First Appeal Bearing Number 09/It/Cit(A)- 5/Ldh/2017-18 Dt. 21/12/2018 The Ld. Cit(A) In Terms Of Section 250(6) Of The Act Had Allowed The Appeal Of The Assessee Against The Penalty Order Dt. 12/05/2017 Wherein Penalty Of Rs. 12,30,000/- Was Imposed On 2 The Assessee U/S 271Aab(1)(A). The 1St Appeal Of The Assessee Was Thus

Penalty Proceedings U/s has been initiated in the case of 271(1)(c) has been initiated assessee while passing the in the above case. Refer assessment order U/s 143(3) by para no. 4 of Page No. 7 of the Ld. A.O. (Refer page No. 2 the order of Allahabad HC para No. 6 of the Assessment at page

SH. DINESH SETHI,LUDHIANA vs. ITO, LUDHIANA

The appeals are dismissed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 376/Chd/2014 & "नधा"रण वष" / Assessment Year : 2006-07 Shri Janesh Sethi, Legal Heir Of बनाम The Ito, Late Shri Dinesh Sethi, Ward – 1(1), Vs Prop. M/S R.S. Trading Corp., Ludhiana. C-434, Urban Estate Focal Point, Ludhiana. "थायी लेखा सं./Pan /Tan No: Aaqpk1200Q अपीलाथ"/Appellant ""यथ"/Respondent "नधा"रती क" ओर से/Assessee By : Shri Sudhir Sehgal, Advocate राज"व क" ओर से/ Revenue By : Shri Manav Bansal, Cit Dr तार"ख/Date Of Hearing : 23.06.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 04.8.2025

penalty order passed u/s 271(1)(c) vide order dated 25.06.2009 against whom appeal has been dismissed by the CIT (Appeals) by way of the impugned order). 2. It has been brought to our notice that assessee Shri Dinesh Sethi has died on 14.02.2024. Death Certificate of the assessee has been annexed by the ld. counsel for the assessee

SHRI DINESH SETHI,LUDHIANA vs. ITO, LUDHIANA

The appeals are dismissed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 376/Chd/2014 & "नधा"रण वष" / Assessment Year : 2006-07 Shri Janesh Sethi, Legal Heir Of बनाम The Ito, Late Shri Dinesh Sethi, Ward – 1(1), Vs Prop. M/S R.S. Trading Corp., Ludhiana. C-434, Urban Estate Focal Point, Ludhiana. "थायी लेखा सं./Pan /Tan No: Aaqpk1200Q अपीलाथ"/Appellant ""यथ"/Respondent "नधा"रती क" ओर से/Assessee By : Shri Sudhir Sehgal, Advocate राज"व क" ओर से/ Revenue By : Shri Manav Bansal, Cit Dr तार"ख/Date Of Hearing : 23.06.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 04.8.2025

penalty order passed u/s 271(1)(c) vide order dated 25.06.2009 against whom appeal has been dismissed by the CIT (Appeals) by way of the impugned order). 2. It has been brought to our notice that assessee Shri Dinesh Sethi has died on 14.02.2024. Death Certificate of the assessee has been annexed by the ld. counsel for the assessee

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)

Penalty proceedings are initiated u/s 271AAC of the Income Tax Act, 1961. The AR has also submitted that the addition in the partner's capita! account of Rs. 50 lacs should be considered as explained under the unaccounted sales transactions of Rs. 42.80 lacs in the impounded documents and other discrepancies of Rs. 7.2 lacs found during the course

SHRI BALBIR SINGH VERMA,SHIMLA vs. PR.CIT, SHIMLA

In the result, appeal of the Assessee is allowed

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

90,323/- from the assessee’s wife, Smt. Meena Verma. Despite providing her PAN and a joint bank statement, the assessee failed to submit confirmation or her income tax returns. The AO treated this amount as unexplained cash credit under Section 68 and initiated penalty proceedings under Section 271(1)(c). 4 3.7 Ld. AO stated that a Survey under

J. K. EDUCATIONAL SOCIETY,JAMMU vs. DCIT, CIRCLE-1, CHANDIGARH

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

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

penalty u/s 271(1)(c) of the Act for A.Y 2009-10. 2. All these cases are heard together and are being disposed off by this consolidated order. With the consent of both the parties, appeal in ITA No. 126/Asr/2019 for A.Y 2008-09 was taken as a lead case wherein the assessee has taken the following grounds of appeal

J.K. EDUCATIONAL SOCIETY,JAMMU & KASHMIR vs. DCIT (EXEMPTION)-CIRCLE-1,, CHANDIGARH

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

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

penalty u/s 271(1)(c) of the Act for A.Y 2009-10. 2. All these cases are heard together and are being disposed off by this consolidated order. With the consent of both the parties, appeal in ITA No. 126/Asr/2019 for A.Y 2008-09 was taken as a lead case wherein the assessee has taken the following grounds of appeal

J.K.EDUCATIONAL SOCIETY,JAMMU vs. INCOME TAX OFFICER (EXEMPTION), CHANDIGARH

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

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

penalty u/s 271(1)(c) of the Act for A.Y 2009-10. 2. All these cases are heard together and are being disposed off by this consolidated order. With the consent of both the parties, appeal in ITA No. 126/Asr/2019 for A.Y 2008-09 was taken as a lead case wherein the assessee has taken the following grounds of appeal

SHRI NARINDER SINGH,ROPAR vs. ITO, W-2(2), ROPAR

The appeal of the assessee is dismissed as withdrawn

section 274 r.w.s 271(1)(c) was issued. Thereafter after taking into consideration the submissions filed by the assessee and the fact that the assessee has not filed any appeal against the quantum proceedings, the AO held that it is a case of concealment of particulars of his income and he recorded his satisfaction and penalty amounting to Rs.2

M/S ASHA TECHNOLOGIES,KALA AMB vs. ITO, SIRMOUR

In the result, both the above appeals of the Assessee are partly allowed as aforesaid in respect of impugned orders dt

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

u/s 133A of the IT Act to find out the true facts of the case when there was no compliance and cooperation on the part of the assessee to prove its primary onus. And on the basis of survey only true facts of the case were ascertained which helped in ascertaining the factual reality. The assessing office collected information u/s

M/S ASHA TECHNOLOGIES,SIRMOUR vs. ADDL. CIT, SOLAN

In the result, both the above appeals of the Assessee are partly allowed as aforesaid in respect of impugned orders dt

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

u/s 133A of the IT Act to find out the true facts of the case when there was no compliance and cooperation on the part of the assessee to prove its primary onus. And on the basis of survey only true facts of the case were ascertained which helped in ascertaining the factual reality. The assessing office collected information u/s

SUNRISE INFRATEC PRIVATE LIMITED,PANCHKULA vs. INCOME TAX OFFICER, CHANDIGARH

In the result, all the appeal of the Assessee stand allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 1196/Chd/2024 "नधा"रण वष" / Assessment Year : 2012-13 Sunrise Infratec Private The Ito, बनाम Limited, Ward 3(5), H.No. 858, Sector 4, Chandigarh Vs. Panchkula 134112 "थायी लेखा सं./ Pan No: Aaqcs4002D अपीलाथ"/Appellant ""यथ"/Respondent ( Hybrid Hearing ) "नधा"रती क" ओर से/Assessee By : Sh. T.N. Singla, Ca (Virtual Mode) राज"व क" ओर से/ Revenue By : Sh. Rajat Kumar Kureel, Cit Dr

90,000/- on account of share capital/ share application money received by the assessee company in respect from the following a) Addition of Rs. 5,50,000/- as given by Sh. Anubhav Chauhan as per para 7.1 of the order of the Assessing Officer. b) Addition of Rs. 20,000/- as given by Sh. Chaitanya Aggarwal as per para

INCOME TAX OFFICER, LUDHIANA vs. KP EXIM INC, LUDHIANA

In the result, appeal of the Revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 561/Chd/2025 "नधा"रण वष" / Assessment Year: 2015-16 The Ito, K.P.Exim Inc, Ward 3(1), Vs Main Bahadur K.Road, Rishi Nagar, Ludhiana. Khaira,Lodhowal B.O., Ludhiana. "थायी लेखा सं./Pan No: Aakfk2926M अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Y.K. Saxena, Advocate & Shri Amandeep Saxena, Ca Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 17.02.2026 Date Of Pronouncement : 20.02.2026

271(1)(c) of the Income Tax Act. 3. The brief facts of the case are that assessee has filed its return of income on 30.09.2015 declaring total income at Rs.8,90,880/-. This return was processed u/s 143(1) and returned income was accepted. The AO, thereafter, reopened the assessment by issuance of a notice u/s

M/S LUXMI BUILDERS,CHANDIGARH vs. DCIT, CHANDIGARH

In the result, the respective appeals and stay applications are disposed off in light of aforesaid directions

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

u/s 153D, as part of the assessment record and draft assessment order, even though addition was made by the Ld. AO on 54 plots for which documents were found during the search. The Ld. AR highlighted the affidavit from Shri Kashmiri Lal which is also part of seized record in respect of those 4 plots which affidavit contained completely different

M/S GANESH BUILDERS,PANCHKULA vs. DCIT, CC-1, CHANDIGARH

In the result, the respective appeals and stay applications are disposed off in light of aforesaid directions

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

u/s 153D, as part of the assessment record and draft assessment order, even though addition was made by the Ld. AO on 54 plots for which documents were found during the search. The Ld. AR highlighted the affidavit from Shri Kashmiri Lal which is also part of seized record in respect of those 4 plots which affidavit contained completely different

CSJ INFRASTRUCTURE PVT.LTD,CHANDIGARH vs. ACIT,CIRCLE--2(1), CHANDIGARH

In the result, both the appeals of the assessee are allowed and that of the Revenue are dismissed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 131,132 /Chd/2020 "नधा"रण वष" / A.Y.: 2014-15, 2015-16, M/S Csj Infrastructure Pvt.Ltd., The Acit, C/O C.A. Ajay Kumar Jain, Vs Circle 2(1), Sco 80-81, 4Th Floor, Sector 17-C, Chandigarh. Chandigarh. "थायी लेखा सं./Pan No: Aaccc8021G अपीलाथ"/Appellant ""यथ"/Respondent आयकर अपील सं./ Ita No. 146, 147/Chd/2020 "नधा"रण वष" / A.Y.: 2014-15, 2015-16, The Acit, Vs M/S Csj Infrastructure Pvt. Ltd., Circle 2(1), C/O C.A. Ajay Kumar Jain, Chandigarh. Sco 80-81, 4Th Floor, Sector 17-C, Chandigarh. "थायी लेखा सं./Pan No: Aaccc8021G अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ajay Jain, Ca Revenue By : Shri Manav Bansal, Cit, Dr Date Of Hearing : 19.05.2025 Date Of Pronouncement : 28.05.2025 Physical Hearing O R D E R

penalty proceedings u/s 271(1)(c) of the I.T. Act are being initiated separately for furnishing inaccurate particulars of income. Assessed. Issue demand notice. (Abhinav Agnihotri) Asstt. Commissioner of Income Tax, Circle- 2(1), Chandigarh 11.1 A perusal of the above would indicate that the difference in the value for the purpose of deemed sale consideration is Rs.10

CSJ INFRASTRUCTURE PVT.LTD,CHANDIGARH vs. ACIT,CIRCLE--2(1), CHANDIGARH

In the result, both the appeals of the assessee are allowed and that of the Revenue are dismissed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 131,132 /Chd/2020 "नधा"रण वष" / A.Y.: 2014-15, 2015-16, M/S Csj Infrastructure Pvt.Ltd., The Acit, C/O C.A. Ajay Kumar Jain, Vs Circle 2(1), Sco 80-81, 4Th Floor, Sector 17-C, Chandigarh. Chandigarh. "थायी लेखा सं./Pan No: Aaccc8021G अपीलाथ"/Appellant ""यथ"/Respondent आयकर अपील सं./ Ita No. 146, 147/Chd/2020 "नधा"रण वष" / A.Y.: 2014-15, 2015-16, The Acit, Vs M/S Csj Infrastructure Pvt. Ltd., Circle 2(1), C/O C.A. Ajay Kumar Jain, Chandigarh. Sco 80-81, 4Th Floor, Sector 17-C, Chandigarh. "थायी लेखा सं./Pan No: Aaccc8021G अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ajay Jain, Ca Revenue By : Shri Manav Bansal, Cit, Dr Date Of Hearing : 19.05.2025 Date Of Pronouncement : 28.05.2025 Physical Hearing O R D E R

penalty proceedings u/s 271(1)(c) of the I.T. Act are being initiated separately for furnishing inaccurate particulars of income. Assessed. Issue demand notice. (Abhinav Agnihotri) Asstt. Commissioner of Income Tax, Circle- 2(1), Chandigarh 11.1 A perusal of the above would indicate that the difference in the value for the purpose of deemed sale consideration is Rs.10

ACIT,CIRCLE--2(1), CHANDIGARH vs. CSJ INFRASTRUCTURE PVT.LTD, CHANDIGARH

In the result, both the appeals of the assessee are allowed and that of the Revenue are dismissed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 131,132 /Chd/2020 "नधा"रण वष" / A.Y.: 2014-15, 2015-16, M/S Csj Infrastructure Pvt.Ltd., The Acit, C/O C.A. Ajay Kumar Jain, Vs Circle 2(1), Sco 80-81, 4Th Floor, Sector 17-C, Chandigarh. Chandigarh. "थायी लेखा सं./Pan No: Aaccc8021G अपीलाथ"/Appellant ""यथ"/Respondent आयकर अपील सं./ Ita No. 146, 147/Chd/2020 "नधा"रण वष" / A.Y.: 2014-15, 2015-16, The Acit, Vs M/S Csj Infrastructure Pvt. Ltd., Circle 2(1), C/O C.A. Ajay Kumar Jain, Chandigarh. Sco 80-81, 4Th Floor, Sector 17-C, Chandigarh. "थायी लेखा सं./Pan No: Aaccc8021G अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ajay Jain, Ca Revenue By : Shri Manav Bansal, Cit, Dr Date Of Hearing : 19.05.2025 Date Of Pronouncement : 28.05.2025 Physical Hearing O R D E R

penalty proceedings u/s 271(1)(c) of the I.T. Act are being initiated separately for furnishing inaccurate particulars of income. Assessed. Issue demand notice. (Abhinav Agnihotri) Asstt. Commissioner of Income Tax, Circle- 2(1), Chandigarh 11.1 A perusal of the above would indicate that the difference in the value for the purpose of deemed sale consideration is Rs.10