INCOME TAX OFFIER, WARD 6(1), LUDHIANA vs. BALPREET SINGH, LUDHIANA

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

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

reassessment proceedings, the jurisdictional Assessing Officer as well as the FAU issued several statutory notices under section 142(1) and a show-cause notice under section 144

DCIT, C-1(1) , CHANDIGARH vs. M/S FIDELITY INFORMATION SERVICES INDIA PVT. LTD., CHANDIGARH

In the result, the cross-objection filed by the assessee is dismissed

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

144/-. In the financial statements, the assessee has reported the revenues from the Associated Enterprises at Rs 1,91,42,32,704/- considering the cost base and mark up of 15% and since the additional mark up of 1.60% (over and above 15%) has been determined pursuant to the unilateral Advance Pricing Agreement entered into with CBDT dated 6/02/2017

SBS BIOTECH UNIT II,SIRMOUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX-1, CHANDIGARH

In the result, the appeal of the assessee is allowed

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

1.T. Act, 1961 in A.Y. 2017-18. Therefore, the assessee is entitled to claim deduction u/s 80IC of the I.T. Act at reduced rate of 25% only in A.Y. 2017-18. In this background, the excess claim of deduction u/s 80IC of Rs.10,91,16,920/-[15,12,63,0644,21,46,144

INDO PACIFIC FINLEASE LTD,CHANDIGARH vs. PCIT- CHANDIGARH 1, CHANDIGARH

In the result, both the appeals are filed by the\nassessee are allowed

Section 203(1) supersede all other legal consideration. no appeal against said order filed and any other statutory instrument or medium not undertaken and no objection raised earlier.\n\n3.\nThat having regard to the facts and circumstances of the case, Ld. Pr. CIT has erred in law and on facts in assuming jurisdiction u/s 263 which

INCOME TAX OFFICE, LUDHIANA vs. SRI GURU HARGOBIND EDUCATIONAL SOCIETY, LUDHIANA

In the result, appeal of the Revenue is dismissed

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

1)(d) for non-compliance with statutory notices. 4. Against the order of the AO the assessee went in appeal before the Ld. CIT(A). The learned CIT(A) examined the appeal filed against the reassessment order passed under section 147 read with section 144

SADHU RAM GUPTA,DHURI, SANGRUR vs. ITO, WARD-1, MALERKOTLA, PUNJAB

In the result, both the appeals are allowed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita Nos. 873 & 874/Chd/2025 "नधा"रण वष" / A.Y. : 2017-18 & 2020-21 Shri Sadhu Ram Gupta, The Ito, House No. 263, W.No. 15B, Vs Ward-1, Sangrur, Tehsil Mohalla Dhuri, Malerkotla. Sangrur. "थायी लेखा सं./Pan No: Addpg0223H अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Parikshit Aggarwal, Ca Revenue By : Dr. Ranjit Kaur, Addl. Cit Sr.Dr Date Of Hearing : 23.07.2025 & 21.07.2025 Date Of Pronouncement : 12.08.2025 Physical Hearing O R D E R Per Rajpal Yadav, Vp

144 read with Section 147 of the Income Tax Act. b) The ld. CIT (Appeals) has erred in confirming the addition of Rs.87,34,000/- and Rs.34,00,000/- in assessment year 2017-18 and 2020-21 respectively. 3. The facts on all vital points are common in both the years. For the facility of reference, we take the facts

SADHU RAM GUPTA,DHURI, SANGRUR vs. ITO, WARD-1, MALERKOTLA, PUNJAB

In the result, both the appeals are allowed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita Nos. 873 & 874/Chd/2025 "नधा"रण वष" / A.Y. : 2017-18 & 2020-21 Shri Sadhu Ram Gupta, The Ito, House No. 263, W.No. 15B, Vs Ward-1, Sangrur, Tehsil Mohalla Dhuri, Malerkotla. Sangrur. "थायी लेखा सं./Pan No: Addpg0223H अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Parikshit Aggarwal, Ca Revenue By : Dr. Ranjit Kaur, Addl. Cit Sr.Dr Date Of Hearing : 23.07.2025 & 21.07.2025 Date Of Pronouncement : 12.08.2025 Physical Hearing O R D E R Per Rajpal Yadav, Vp

144 read with Section 147 of the Income Tax Act. b) The ld. CIT (Appeals) has erred in confirming the addition of Rs.87,34,000/- and Rs.34,00,000/- in assessment year 2017-18 and 2020-21 respectively. 3. The facts on all vital points are common in both the years. For the facility of reference, we take the facts

OSWAL POLYCOT (INDIA) PVT. LTD.,LUDHIANA vs. DCIT, CC-I, LUDHIANA

In the result, the appeal of the assessee in ITA No

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

144,147,153A,153C and each and every type of assessment is dealt with by the separate set of Sections right from the start of the assessment till the very end. It was submitted that there is no provision of the Act in which the AO can shuffle such set of Sections and the AO cannot start an assessment from

DCIT, CC-I, LUDHIANA vs. OSWAL POLYCOT (INDIA) PVT. LTD., LUDHIANA

In the result, the appeal of the assessee in ITA No

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

144,147,153A,153C and each and every type of assessment is dealt with by the separate set of Sections right from the start of the assessment till the very end. It was submitted that there is no provision of the Act in which the AO can shuffle such set of Sections and the AO cannot start an assessment from

DCIT, CC-I, LUDHIANA vs. OSWAL POLYCOT (INDIA) PVT. LTD., LUDHIANA

In the result, the appeal of the assessee in ITA No

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

144,147,153A,153C and each and every type of assessment is dealt with by the separate set of Sections right from the start of the assessment till the very end. It was submitted that there is no provision of the Act in which the AO can shuffle such set of Sections and the AO cannot start an assessment from

OSWAL POLYCOT (INDIA) PVT. LTD.,LUDHIANA vs. DCIT, CC-I, LUDHIANA

In the result, the appeal of the assessee in ITA No

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

144,147,153A,153C and each and every type of assessment is dealt with by the separate set of Sections right from the start of the assessment till the very end. It was submitted that there is no provision of the Act in which the AO can shuffle such set of Sections and the AO cannot start an assessment from

OSWAL POLYCOT (INDIA) PVT. LTD.,LUDHIANA vs. DCIT, CC-I, LUDHIANA

In the result, the appeal of the assessee in ITA No

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

144,147,153A,153C and each and every type of assessment is dealt with by the separate set of Sections right from the start of the assessment till the very end. It was submitted that there is no provision of the Act in which the AO can shuffle such set of Sections and the AO cannot start an assessment from

VIMAL ALLOYS PRIVATE LIMITED, MANDI GOBINDGARH,PUNJAB vs. JAO THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE, PATIALA, PUNJAB

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

144 (Gujrat) as per copy placed at pages 212 to 214 of JS-II wherein it is held as under: INCOME TAX : Where Assessing Officer issued reopening notice under section 148A(b) on ground that a search conducted upon a party revealed that said party provided accommodation entries in form of loan to assessee, since Assessing Officer failed to consider

AJAY TANTA,SHIMLA vs. INCOME TAX OFFICER, SHIMLA

In the result, appeal of the assessee is allowed

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

144 cannot survive. All additions made therein, including the addition under section 69 of the Act, are rendered academic and do not require adjudication on merits. 8.5 As regards the dismissal of the appeal by the Ld. CIT(A) for non- prosecution, it is well settled that a jurisdictional defect goes to the root of the matter

VINEET KUMAR,DHARAMSHALA vs. INCOME TAX OFFICER, DHARMSHALA

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

Bench: SHRI. LALIET KUMAR (Judicial Member)

reassessment proceedings, invocation of section 144, violation of principles of natural justice, and also the addition made under section 69A of the Act. The grounds, inter alia, include challenge to jurisdiction on account of alleged invalid issuance of notice under section 148, non-compliance of procedure prescribed under section 148A, improper invocation of best judgment assessment despite compliance, and failure

AMARJIT SINGH,LUDHIANA vs. INCOME TAX OFFICER,WARD 6(1) LUDHIANA, LUDHIANA

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

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 1171 /Chd/2024 निर्धारण वर्ष / Assessment Year : 2017-18 Shri Amarjit Singh बनाम The ITO C/o V V Bhalla & Company Ward 6(1) SCF-39, Rishi Nagar Main Market, Ludhiana Adjoining Subway, Ludhiana-141001, Punjab स्थायी लेखा सं./PAN NO: ABTPS8558B अपीलार्थी/Appellant प्रत्यर्थी/Respondent निर्धारिती की ओर से / Assessee by : Shri Pankaj Bhalla, C.A राजस्व की ओर से/ Revenue by : Shri Vivek Vardhan, Addl. CIT, Sr

1)(d). The Ld. AO had initiated reassessment proceedings under section 148 read with section 144A alleging escapement of income and made the aforesaid addition, which was also followed by initiation of penalty proceedings under the mentioned sections. The assessee objected to the reassessment proceedings on grounds of invalid approval under section 151, lack of opportunity of being heard

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

section 148 and ground No. 4 8t 5 is the reference to the fact that even no notice u/s 142(1) or 143(2) has been served upon the assessee. FACTS ABOUT SERVICE OF NOTICE U/S 148 ii). The assessment proceedings were framed exparte, since no notice either u/s 148 or 142(1) or 143(2) had been served upon

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

section 148 and ground No. 4 8t 5 is the reference to the fact that even no notice u/s 142(1) or 143(2) has been served upon the assessee. FACTS ABOUT SERVICE OF NOTICE U/S 148 ii). The assessment proceedings were framed exparte, since no notice either u/s 148 or 142(1) or 143(2) had been served upon