SH. ASHISH JAIN,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the ground no

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

38. On a conspectus of section 153A(1) of the Act, read with the provisos thereto, and in the light of the law explained in the aforementioned decisions, the legal position that emerges is as under: i. Once a search takes place under section 132 of the Act, notice under section 153A(1) will have to be mandatorily issued

SH. BIPAN JAIN,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the ground no

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

38. On a conspectus of section 153A(1) of the Act, read with the provisos thereto, and in the light of the law explained in the aforementioned decisions, the legal position that emerges is as under: i. Once a search takes place under section 132 of the Act, notice under section 153A(1) will have to be mandatorily issued

SH. VIBHAV JAIN,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the ground no

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

38. On a conspectus of section 153A(1) of the Act, read with the provisos thereto, and in the light of the law explained in the aforementioned decisions, the legal position that emerges is as under: i. Once a search takes place under section 132 of the Act, notice under section 153A(1) will have to be mandatorily issued

SHRI ABHISHEK SOIN,LUDHIANA vs. DCIT, CC-II, LUDHIANA

The appeals are partly allowed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 321 & 322/Chd/2019 "नधा"रण वष" / Assessment Year: 2010-11, 2011-12 Shri Abhishek Soin, The Dcit, C/O Sigma Cartons Pvt. Ltd., Vs Central Circle-Ii, Unit-Ii, Industrial Area-C, Ludhiana. Sua Road, Ludhiana. "थायी लेखा सं./Pan No: Anbps9446A अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Aditya Kumar, Ca Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 03.06.2025 Date Of Pronouncement : 29.07.2025 Hybrid Hearing O R D E R

38) of the Income tax Act 1961. In the meantime the operators rig the price of the stock and gradually rise its price many times, often 500 to 1000 times. This is done through low volume transaction indulged in by the dummies of the operator at a pre-determined price. When the price reaches the desired level the beneficiary

SHRI ABHISHEK SOIN,LUDHIANA vs. DCIT, CC-II, LUDHIANA

The appeals are partly allowed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 321 & 322/Chd/2019 "नधा"रण वष" / Assessment Year: 2010-11, 2011-12 Shri Abhishek Soin, The Dcit, C/O Sigma Cartons Pvt. Ltd., Vs Central Circle-Ii, Unit-Ii, Industrial Area-C, Ludhiana. Sua Road, Ludhiana. "थायी लेखा सं./Pan No: Anbps9446A अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Aditya Kumar, Ca Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 03.06.2025 Date Of Pronouncement : 29.07.2025 Hybrid Hearing O R D E R

38) of the Income tax Act 1961. In the meantime the operators rig the price of the stock and gradually rise its price many times, often 500 to 1000 times. This is done through low volume transaction indulged in by the dummies of the operator at a pre-determined price. When the price reaches the desired level the beneficiary

M/S JAIN AMAR CLOTHING PVT. LTD.,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the ground no

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

38. On a conspectus of section 153A(1) of the Act, read with the provisos thereto, and in the light of the law explained in the aforementioned decisions, the legal position that emerges is as under: i. Once a search takes place under section 132 of the Act, notice under section 153A(1) will have to be mandatorily issued

SHRI SATISH SOIN,LUDHIANA vs. ACIT, CC-II, LUDHIANA

In the result, appeal of the assessee is allowed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 303/Chd/2019 "नधा"रण वष" / Assessment Year : 2012-13 Shri Satish Soin, बनाम The Acit, House No.31, Garden Enclave, Central Circle-2, Vs South City-Ii, Ludhiana. Ludhiana. "थायी लेखा सं./Pan /Tan No: Advps6254N अपीलाथ"/Appellant ""यथ"/Respondent "नधा"रती क" ओर से/Assessee By : Shri Ashwani Kumar & Ms. Muskan Garg, Cas राज"व क" ओर से/ Revenue By : Smt. Kusum Bansal, Cit Dr तार"ख/Date Of Hearing : 26.05.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 23.07.2025 Hybrid Hearing आदेश/Order Per Rajpal Yadav, Vp

38) of the Income tax Act 1961. In the meantime the operators rig the price of the stock and gradually rise its price many times, often 500 to 1000 times. This is done through low volume transaction indulged in by the dummies of the operator at a pre- determined price. When the price reaches the desired level the beneficiary

SH. DINESH SOIN,LUDHIANA vs. ACIT, LUDHIANA

The appeals are partly allowed

10(38) of the Income\ntax Act 1961. In the meantime the operators rig the price of the\nstock and gradually rise its price many times, often 500 to 1000\ntimes. This is done through low volume transaction indulged in by\nthe dummies of the operator at a pre-determined price. When the\nprice reaches the desired level the beneficiary

SMT. GINNY SOIN,LUDHIANA vs. ACIT, CC-II, LUDHIANA

The appeals are partly allowed

10(38) of the Income\ntax Act 1961. In the meantime the operators rig the price of the\nstock and gradually rise its price many times, often 500 to 1000\ntimes. This is done through low volume transaction indulged in by\nthe dummies of the operator at a pre-determined price. When the\nprice reaches the desired level the beneficiary

SMT. GINNY SOIN,LUDHIANA vs. ACIT, CC-II, LUDHIANA

The appeals are partly allowed

10(38) of the Income\ntax Act 1961. In the meantime the operators rig the price of the\nstock and gradually rise its price many times, often 500 to 1000\ntimes. This is done through low volume transaction indulged in by\nthe dummies of the operator at a pre-determined price. When the\nprice reaches the desired level the beneficiary

SMT. RITU SOIN,LUDHIANA vs. ACIT, CC-II, LUDHIANA

In the result, both the appeals are allowed

10(38) of the Income tax\nAct 1961. In the meantime the operators rig the price of the stock\nand gradually rise its price many times, often 500 to 1000 times.\nThis is done through low volume transaction indulged in by the\ndummies of the operator at a pre-determined price. When the price\nreaches the desired level the beneficiary

ACIT, CIRCLE 1(1), CHANDIGARH vs. M/S SML ISUZU LTD., CHANDIGARH

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

10. impugned order of the Ld. CIT(A) is correct and that it has been rightly held that the reassessment order dt. 27/09/2021 is bad in law for reasons as under: (a) No escapement of income – reassessment proceedings without jurisdiction and illegal. (b) No fresh / tangible material to reopen the closed assessment and proceedings initiated merely on the basis

WINSOME TEXTILE INDUSTRIES LIMITED,CHANDIGARH vs. ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-4(1), CHANDIGARH, CHANDIGARH

In the result, the appeal of the assessee is partly allowed and the appeal of the Revenue is dismissed

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

reassessment proceedings under section 147 vide letter dt. 19/12/2018 which were disposed off by the AO by passing a separate order dt. 19/12/2018. Thereafter, after issuance of notice under section 143(2) and 142(1) and after calling for necessary information and documentation as well as issue of specific show cause notice, the AO made an addition

SH. BALJINDER KUMAR AGGARWAL 171, MODEL TOWN LUDHIANA,PUNJAB vs. JATIN ABBI THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1 LUDHIANA, PUNJAB

In the result, appeal of the Assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 689/Chd/2024 िनधा"रण वष" / Assessment Year : 2012-13 बनाम Shri Baljinder Kumar Aggarwal, The Acit, 171, Model Town, Circle-1, Vs Ludhiana. Ludhiana. "थायी लेखा सं./Pan /Tan No: Bmcpk7473A 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 तारीख/Date Of Hearing : 21.08.2025 उदघोषणा क" तारीख/Date Of Pronouncement : 17.09.2025

Section 147 would indicate that it contemplates that AO has a reason to believe that income has escaped assessment. This formation of belief is to be based on the information which prima-facie suggests escapement of income. To our mind, at the stage of ITA 689/CHD/2024 A.Y. 2012-13 9 forming a belief that income has escaped assessment

SURJEET SINGH,SIRSA vs. PCIT, ROHTAK, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

10- 10.11 in 315 ITR 1 was pronounced on 16.07.2009 i.e. post Finance Bill 2009 was proposed (i.e. in February 2009) and which also proves that amendment vide Finance (No.2) Act was introduced to nullify the effect of Hon'ble Supreme Court's ruling in the case of Rama Bai reported in 181 ITR 400 and not Ghanshyam HUF reported

SH. PARAMJEET SINGH,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

10- 10.11 in 315 ITR 1 was pronounced on 16.07.2009 i.e. post Finance Bill 2009 was proposed (i.e. in February 2009) and which also proves that amendment vide Finance (No.2) Act was introduced to nullify the effect of Hon'ble Supreme Court's ruling in the case of Rama Bai reported in 181 ITR 400 and not Ghanshyam HUF reported

SH. RANDHIR SINGH,SIRSA vs. PCIT ROHTAK, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

10- 10.11 in 315 ITR 1 was pronounced on 16.07.2009 i.e. post Finance Bill 2009 was proposed (i.e. in February 2009) and which also proves that amendment vide Finance (No.2) Act was introduced to nullify the effect of Hon'ble Supreme Court's ruling in the case of Rama Bai reported in 181 ITR 400 and not Ghanshyam HUF reported

DHUNI CHAND HUF,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

10- 10.11 in 315 ITR 1 was pronounced on 16.07.2009 i.e. post Finance Bill 2009 was proposed (i.e. in February 2009) and which also proves that amendment vide Finance (No.2) Act was introduced to nullify the effect of Hon'ble Supreme Court's ruling in the case of Rama Bai reported in 181 ITR 400 and not Ghanshyam HUF reported