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, Section 151 and Section 153, in the case of a person where a search is initiated under section 132 or books of account, other documents or any assets

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, Section 151 and Section 153, in the case of a person where a search is initiated under section 132 or books of account, other documents or any assets

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, Section 151 and Section 153, in the case of a person where a search is initiated under section 132 or books of account, other documents or any assets

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, Section 151 and Section 153, in the case of a person where a search is initiated under section 132 or books of account, other documents or any assets

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)

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, Section 151 and Section 153, in the case of a person where a search is initiated under section 132 or books of account, other documents or any assets

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 commenced pursuant to a search, based upon it being found that the proceedings would have sustained bearing in mind the timelines prescribed in Sections 149, 153A and 153C, as they existed prior to the commencement of Finance Act, 2021. This necessarily requires us to advert to the timeframes comprised in both Section 149(1)(b

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

1) Notwithstanding anything contained in section 139, section 147, section\n148, section 149, section 151 and section 153, where the Assessing Officer is\nsatisfied that,—\n(a) any money, bullion, jewellery or other valuable article or thing, seized or\nrequisitioned, belongs to; or\n(b) any books of account or documents, seized or requisitioned, pertains or pertain

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

1) Notwithstanding anything contained in section 139, section 147, section\n148, section 149, section 151 and section 153, where the Assessing Officer is\nsatisfied that,—\n(a) any money, bullion, jewellery or other valuable article or thing, seized or\nrequisitioned, belongs to; or\n(b) any books of account or documents, seized or requisitioned, pertains or pertain

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

1) Notwithstanding anything contained in section 139, section 147, section\n148, section 149, section 151 and section 153, where the Assessing Officer is\nsatisfied that,—\n(a) any money, bullion, jewellery or other valuable article or thing, seized or\nrequisitioned, belongs to; or\n(b) any books of account or documents, seized or requisitioned, pertains or pertain

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

1) Notwithstanding anything contained in section 139, section 147, section\n148, section 149, section 151 and section 153, where the Assessing Officer is\nsatisfied that,—\n(a) any money, bullion, jewellery or other valuable article or thing, seized or\nrequisitioned, belongs to; or\n(b) any books of account or documents, seized or requisitioned, pertains or pertain

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

1) Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that,— (a) 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

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

1) Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that,— (a) 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

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)

Section 147 is attracted. The reasons to believe ought to also paraphrase any investigation report which may form the basis of the reasons and any enquiry conducted by the AO on the same and if so, the conclusions thereof; (iii) where the reasons make a reference to another document, whether as a letter or report, such document and/ or relevant

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

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

b) if delivered electronically—at the time of sending the\nelectronic record.\n14. Upon a conjoint reading of Sections 148, 149, and\n282 of the Income Tax Act, 1961, along with Rule 127 of\nthe Income Tax Rules, 1962, it becomes abundantly clear\nthat a communication shall be deemed to be delivered or\ntransmitted electronically at the moment

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

1) [Notwithstanding anything contained in section 139, section 147, section 148, section 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

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

1) [Notwithstanding anything contained in section 139, section 147, section 148, section 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

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

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

b) if delivered electronically—at the time of sending the\nelectronic record.\n\n14. Upon a conjoint reading of Sections 148, 149, and\n282 of the Income Tax Act, 1961, along with Rule 127 of\nthe Income Tax Rules, 1962, it becomes abundantly clear\nthat a communication shall be deemed to be delivered or\ntransmitted electronically at the moment

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)

reassessment, made is not sustainable and accordingly the same is quashed. We further relied upon the decision of Hon’ble Rajasthan High Court n case of Abdul Majeed Vs. ITO (2022) 140 taxmann.com 485 wherein it was held as under: 20. Therefore, while passing an order under section 148A of the Act, the authority is required to reach satisfaction

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

1) Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that,— (a) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to; or ITA No.873&874/CHD/2025 A.Y.2017-18 and 2020-21 8 (b) any books of account or documents, seized or requisitioned