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)

reassess the same. Section 153A of the Act reads as under: "153A. Assessment in case of search or requisition - (1) Notwithstanding anything contained in Section 139, Section 147, Section 148, Section 149

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)

reassess the same. Section 153A of the Act reads as under: "153A. Assessment in case of search or requisition - (1) Notwithstanding anything contained in Section 139, Section 147, Section 148, Section 149

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)

reassess the same. Section 153A of the Act reads as under: "153A. Assessment in case of search or requisition - (1) Notwithstanding anything contained in Section 139, Section 147, Section 148, Section 149

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)

reassess the same. Section 153A of the Act reads as under: "153A. Assessment in case of search or requisition - (1) Notwithstanding anything contained in Section 139, Section 147, Section 148, Section 149

ANIL KUMAR,UNA vs. INCOME TAX OFFICER, WARD, UNA, UNA

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Krinwant Sahay, Am M.A. No. 121/Chandi/2025 [In Ita No.25/Chandi/2022] (िनधा"रणवष" / Assessment Year: 2010-11) Dcit, Central Circle-1, M/S Oswal Apparels Pvt. Ltd., बनाम/ Vs. Ludhiana Ludhiana "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaaco-9177-H (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Gaurav Sharma (Ca) ""थ"कीओरसे/Respondent By : Dr. Ranjit Kaur (Addl. Cit) Sr. Dr (Virtual)

reassessment action may be initiated stands fortified by the First Proviso appearing in Section 149, and which came to be introduced

DEPUTY COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2, LUDHIANA , LUDHIANA vs. PERIWAL ENTERPRISES PRIVATE LIMITED, DELHI

The appeals are dismissed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahay

149, section 151 and section .753. where the Assessing Officer is satisfied that,— (b) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to; or (b) any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to, a person other than the person referred

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2, LUDHIANA , LUDHIANA vs. PERIWAL ENTERPRISES PRIVATE LIMITED, DELHI

The appeals are dismissed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahay

149, section 151 and section .753. where the Assessing Officer is satisfied that,— (b) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to; or (b) any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to, a person other than the person referred

DHARAMVIR SINGH ,VILLAGE THAMBER vs. ITO WARD 1 , AMBALA

In the result, the impugned order and the proceedings are unsustainable in law

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

149 (1)(a) of the Act and therefore the reopening is required to be made within three years from the end of the relevant year. In the present case the Assessment Year involved is 2014-15. However the proceedings were initiated under section 148A on 23/03/2022 by issuing the notice and therefore, period of limitation which is required

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

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

reassessment order passed was illegal and invalid due to following:-\n1. Notice u/s 148 issued on 01.04.2021 is time barred for the above Assessment\nYear.\nRegarding the date of issue of notice, there is no date mentioned on ITBA\nportal when the notice was uploaded and column is left blank. The snapshot\nis as under:\nIncome Tax Portal, Government

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

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

Sections 148, 149, and 282 of the Act,\nalong with Rule 127 of the Rules. These are reproduced\nbelow for ready reference:\n\nSection 148\nIssue of Notice where Income has\n\n\n\nITA Nos.208/CHD/2021 & Ors.\nA.Ys.2018-19& Ors.\n24\n\nEscaped Assessment\n(1) Before making the assessment, reassessment

AMICO TEXTILES,SOLAN vs. DCIT CC-1, CHANDIGARTH

The appeal stand allowed in terms of our above order

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.430/Chandi/2022 (िनधा"रणवष" / Assessment Year: 2013-14) M/S Amico Textiles Dcit Village Bir Plassi, Ropar Road, Central Circle-1 बनाम/ Vs. Nalagarh, Solan Chandigarh Himachal Pradesh 176077 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaqfa-9823-K (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Neeraj Jain (Ca) – Ld. Ar ""थ"कीओरसे/Respondent By : Sh. Manav Bansal (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 23-06-2025 घोषणाकीतारीख /Date Of Pronouncement : 15-07-2025. आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2013-14 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals)-3, Gurgaon [Cit(A)] Dated 31-03-2022 In The Matter Of An Assessment Framed By Ld. Ao U/S 147 R.W.S. 153A Of The Act On 17-12- 2018. The Assessee Is Aggrieved By Confirmation Of Addition Of Rs.46.87 Lacs.

reassess total income of such other person of such assessment year in the manner provided in section 153-A." 10. A bare perusal of this Section would reveal that it starts with a non obstante clause “notwithstanding anything contained in Section” meaning thereby this Section has an over-riding effect over other Sections namely; 139, 147, 148, 149

SUBHASH CHANDER GUPTA, H.NO. 16528 VISHNU COLONY, RALIWAY ROAD, KURUKSHETRA,HARYANA vs. JOINT COMMISSIONER OF INCOME TAX, KURUKSHETRA

In the result, both appeals of the assessee are

Bench: Shri Rajpal Yadav & Shri Krinwant Sahay

reassess total income of such other person of such assessment year in the manner provided in section 153-A." 10. A bare perusal of this Section would reveal that it starts with a non obstante clause “not withstanding anything contained in Section” meaning thereby this Section has an over-riding effect over other Sections namely; 139, 147, 148, 149

SUBHASH CHANDER GUPTA, H.NO. 1652 8 VISHNU COLONY, RAILWAY ROAD, KURUKSHETRA,HARYANA vs. ITO WARD-3, KURUKSHETRA, HARYANA

In the result, both appeals of the assessee are

Bench: Shri Rajpal Yadav & Shri Krinwant Sahay

reassess total income of such other person of such assessment year in the manner provided in section 153-A." 10. A bare perusal of this Section would reveal that it starts with a non obstante clause “not withstanding anything contained in Section” meaning thereby this Section has an over-riding effect over other Sections namely; 139, 147, 148, 149

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

reassess ITA No.873&874/CHD/2025 A.Y.2017-18 and 2020-21 9 total income of such other person of such assessment year in the manner provided in section 153-A." 11. A bare perusal of this Section would reveal that it starts with a non obstante clause “not withstanding anything contained in Section” meaning thereby this Section has an over-riding effect over

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

reassess ITA No.873&874/CHD/2025 A.Y.2017-18 and 2020-21 9 total income of such other person of such assessment year in the manner provided in section 153-A." 11. A bare perusal of this Section would reveal that it starts with a non obstante clause “not withstanding anything contained in Section” meaning thereby this Section has an over-riding effect over

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2,, LUDHIANA vs. AB ALCOBEV PRIVATE LIMITED, DELHI

In the result, appeals of Revenue are dismissed, Cross\nObjections of the assessee for

reassessment order, as the case may be, is required to be passed by the\nAssessing Officer with the prior approval of the Principal Commissioner or\nCommissioner under sub-section (12) of section 144BA”\n10. In view of the above provision, the ld. Counsel for the Assessee stated that the\nCIT(A) has explained the procedure contained in Instruction No. F.No

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2, LUDHIANA vs. AB ALCOBEV PRIVATE LIMITED, DELHI

In the result, appeals of Revenue are dismissed, Cross\nObjections of the assessee for

reassessment order, as the case may be, is required to be passed by the\nAssessing Officer with the prior approval of the Principal Commissioner or\nCommissioner under sub-section (12) of section 144BA”\n10. In view of the above provision, the ld. Counsel for the Assessee stated that the\nCIT(A) has explained the procedure contained in Instruction No. F.No

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2 LUDHIANA, LUDHIANA vs. AB ALCOBEV PRIVATE LIMITED , DELHI

In the result, appeals of Revenue are dismissed, Cross\nObjections of the assessee for

reassessment order, as the case may be, is required to be passed by the\nAssessing Officer with the prior approval of the Principal Commissioner or\nCommissioner under sub-section (12) of section 144BA”\n10. In view of the above provision, the ld. Counsel for the Assessee stated that the\nCIT(A) has explained the procedure contained in Instruction No. F.No