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)

reassessment under sections 147/148 of the Act has to be saved, otherwise the Revenue would be left without remedy. 12

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)

reassessment under sections 147/148 of the Act has to be saved, otherwise the Revenue would be left without remedy. 12

SH. AKHIL 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)

reassessment under sections 147/148 of the Act has to be saved, otherwise the Revenue would be left without remedy. 12

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)

reassessment under sections 147/148 of the Act has to be saved, otherwise the Revenue would be left without remedy. 12

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)

reassessment under sections 147/148 of the Act has to be saved, otherwise the Revenue would be left without remedy. 12

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)

reassessment under sections 147/148 of the Act has to be saved, otherwise the Revenue would be left without remedy. 12

M/S GENIUS EDUCATION SOCIETY,MANDI vs. ACIT, C-2, (E), CHANDIGARH

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

Bench: Shri Sanjay Garg & Ms. Annapurna Guptam/S Genius Education Society, Vs. The A.C.I.T., Tanda Balt, Sadar, Mandi, Circle-2(Exemptions), Himachal Pradesh. Chandigarh. Pan: Aaajg1473H (Appellant) (Respondent)

12 on account of not having complied with the requirements of section 12A(1)(b) of the Act. Since this was the sole basis for upholding the validity of the reassessment

SHRI MOHAN LAL GUPTA,SHIMLA vs. PR.CIT-1, CHANDIGARH

In the result, appeal of the Assessee is partly allowed

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

reassessment proceedings, the period of limitation for the completion of proceeding under section 263 have to be read from the completion of the original assessment proceedings and even on this count, the order so passed is clearly barred by limitation as so provided in the statute u/s 263(2) of the Act which provides that no order shall be passed

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

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)

section 147 o f the Act. The Assessing Officer ordering reassessment cannot sit as a court o f appeal over the Assessing Officer making the original assessment and it is not open to the Assessing Officer ordering reassessment to substitute his own opinion for that o f the Assessing Officer, who made the original assessment." (emphasis supplied) In final analysis

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, LUDHIANA , LUDHIANA vs. AVINASH SINGLA, KHANNA

In the result, all the appeals of the Revenue are dismissed

Bench: Shri Rajpal Yaday & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 814 & 815/Chd/2023 "नधा"रण वष" / Assessment Years :2013-14 & 2014-15 Dcit, Vs. Avinash Singla, Central Circle-1, बनाम C-47, C.O Avinash Ludhiana Industries, Focal Point, Khanna "थायी लेखा सं./Pan No. Acypk9591N अपीलाथ"/Appellant ""यथ"/Respondent & आयकर अपील सं./ Ita No. 15/Chd/2024 "नधा"रण वष" / Assessment Year : 2014-15 Dcit, Vs. Meenu Singla, बनाम Central Circle-1, C-47, C.O Avinash Ludhiana Industries, Focal Point, Khanna "थायी लेखा सं./Pan No.Afips6556G अपीलाथ"/Appellant ""यथ"/Respondent

reassessment under sections 147/148 of the Act has to be saved, otherwise the Revenue would be left without remedy. 814-815-Chd-2023 & 15-Chd-2024- Avinash Singla & Meenu Singla, Khanna 18 12

HARYANA BUILDING AND OTHER CONSTRUCTION WORKERS WELFARE BOARD,PANCHKULA vs. DCIT, EXEMPTION, CHANDIGARH

In the result, this appeal of the Assessee stands dismissed

reassessment on account of revision under section 263 is bad in law\nand liable to be quashed?\n3.1 Complete Enquiry Conducted by the Learned Assessing Officer\n3.1.1 In this case, the original assessment order passed under Section 143(3) was not an\ninstance of non-application of mind or a failure to conduct inquiry. It is\nrespectfully submitted that

HARYANA BUILDING AND OTHER CONSTRUCTION WORKERS WELFARE BOARD,PANCHKULA vs. DCIT, EXEMPTION, SECTOR 17

In the result, this appeal of the Assessee stands dismissed

reassessment on account of revision under section 263 is bad in law\nand liable to be quashed?\n3.1 Complete Enquiry Conducted by the Learned Assessing Officer\n3.1.1 In this case, the original assessment order passed under Section 143(3) was not an\ninstance of non-application of mind or a failure to conduct inquiry. It is\nrespectfully submitted that

HARYANA BUILDING AND OTHER CONSTRUCTION WORKERS WELFARE BOARD,PANCHKULA vs. CIT(EXEMPTION), CHANDIGARH

In the result, this appeal of the Assessee stands dismissed

reassessment on account of revision under section 263 is bad in law\nand liable to be quashed?\n\n3.1 Complete Enquiry Conducted by the Learned Assessing Officer\n\n3.1.1 In this case, the original assessment order passed under Section 143(3) was not an\ninstance of non-application of mind or a failure to conduct inquiry. It is\nrespectfully submitted

HARYANA BUILDING AND OTHER CONSTRUCTION WORKERS WELFARE BOARD,PANCHKULA vs. DCIT, EXEMPTION, CHANDIGARH

In the result, this appeal of the Assessee stands dismissed

reassessment on account of revision under section 263 is bad in law\nand liable to be quashed?\n\n3.1 Complete Enquiry Conducted by the Learned Assessing Officer\n\n3.1.1 In this case, the original assessment order passed under Section 143(3) was not an\ninstance of non-application of mind or a failure to conduct inquiry. It is\nrespectfully submitted

JAMNA DASS NIKKAMAL JAIN SARAF PRIVATE LIMITED, LUDHIANA,LUDHIANA vs. THE DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 1, LUDHIANA, LUDHIANA

In the result, the appeal filed by Revenue is dismissed and the appeal filed by the Assessee is allowed

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

reassessment under section 147 read with section 148, which is the special mechanism for bringing to tax the income discovered in consequence of a search. 13.5 Although section 148 (inserted w.e.f. 01.04.2021) does not begin with a non-obstante clause similar to the erstwhile section 153A, its context and Explanation 2 make it clear that where a search is initiated

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, LUDHIANA, LUDHIANA vs. M/S JAMNA DASS NIKKAMAL JAIN SARAF PVT. LTD., LUDHIANA

In the result, the appeal filed by Revenue is dismissed and the appeal filed by the Assessee is allowed

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

reassessment under section 147 read with section 148, which is the special mechanism for bringing to tax the income discovered in consequence of a search. 13.5 Although section 148 (inserted w.e.f. 01.04.2021) does not begin with a non-obstante clause similar to the erstwhile section 153A, its context and Explanation 2 make it clear that where a search is initiated

M/S PNG TRADING PRIVATE LIMITED,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

In the result, all four appeals are allowed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwal

reassessment under sections 147/148 of the Act has to be saved, otherwise the Revenue would be left without remedy. 12

M/S PNG TRADING PRIVATE LIMITED,CHANDIGARH vs. DCIT, CHANDIGARH

In the result, all four appeals are allowed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwal

reassessment under sections 147/148 of the Act has to be saved, otherwise the Revenue would be left without remedy. 12