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, which had abated, shall be made, for which extension of time has been provided under section 153B. 53. The question

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, which had abated, shall be made, for which extension of time has been provided under section 153B. 53. The question

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, which had abated, shall be made, for which extension of time has been provided under section 153B. 53. The question

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, which had abated, shall be made, for which extension of time has been provided under section 153B. 53. The question

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 shall be passed by an Assessing\nOfficer below the rank of Joint Commissioner in respect of each assessment\nyear referred to in clause (b) of subsection (1) of section 153A or the assessment\nyear referred to in clause (b) of sub-section (1) of section 153B

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 shall be passed by an Assessing\nOfficer below the rank of Joint Commissioner in respect of each assessment\nyear referred to in clause (b) of subsection (1) of section 153A or the assessment\nyear referred to in clause (b) of sub-section (1) of section 153B

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 shall be passed by an Assessing\nOfficer below the rank of Joint Commissioner in respect of each assessment\nyear referred to in clause (b) of subsection (1) of section 153A or the assessment\nyear referred to in clause (b) of sub-section (1) of section 153B

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 shall be passed by an Assessing\nOfficer below the rank of Joint Commissioner in respect of each assessment\nyear referred to in clause (b) of subsection (1) of section 153A or the assessment\nyear referred to in clause (b) of sub-section (1) of section 153B

M/S SINGLA BUILDERS AND PROMOTERS LIMITED,RUPNAGAR, PUNJAB vs. DCIT/ACIT(CEN)-1 CHD, CHANDIGARH

The appeals stand partly allowed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No.487/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2013-14) M/S Singla Builders & Promoters Ltd. Dcit / Acit Central-1 बनाम/ Plot No 1265, Sector 82, Industrial Area C.R. Building, Sector 17 Vs. Rupnagar (Punjab) 140308 Chandigarh-160017 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaocs-6503-M (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकर अपील सं. / Ita No.482/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2017-18) & 3. आयकर अपील सं. / Ita No.484/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2018-19) M/S Credo Assets Private Ltd. Dcit / Acit Central-1 बनाम/ Plot No 1265-C, Sector 82, Industrial Area C.R. Building, Sector 17 Vs. Rupnagar (Punjab) 140308 Chandigarh-160017 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aafcc-6400-L (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Parikshit Aggarwal (Ca) & Smt. Shruti Khandelwal (Ca) – Ld. Ars ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) & Shri Rajat Kumar Kureel (Cit) – Ld. Drs (Virtual) Date Of Final Hearing : 27-01-2026 Date Of Pronouncement : 03-02-2026

153B of the Act so as to provide that the time period beginning with the date on which the reference is made to the valuation officer and ending with the date on which his report is received by the Assessing Officer shall be excluded from the time period provided under aforesaid sections for completion of assessment or reassessment

M/S CREDO ASSETS PVT. LTD.,RUPNAGAR PUNJAB vs. DCIT/ACIT(CEN)-1 CHD, CHANDIGARH

The appeals stand partly allowed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No.487/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2013-14) M/S Singla Builders & Promoters Ltd. Dcit / Acit Central-1 बनाम/ Plot No 1265, Sector 82, Industrial Area C.R. Building, Sector 17 Vs. Rupnagar (Punjab) 140308 Chandigarh-160017 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaocs-6503-M (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकर अपील सं. / Ita No.482/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2017-18) & 3. आयकर अपील सं. / Ita No.484/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2018-19) M/S Credo Assets Private Ltd. Dcit / Acit Central-1 बनाम/ Plot No 1265-C, Sector 82, Industrial Area C.R. Building, Sector 17 Vs. Rupnagar (Punjab) 140308 Chandigarh-160017 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aafcc-6400-L (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Parikshit Aggarwal (Ca) & Smt. Shruti Khandelwal (Ca) – Ld. Ars ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) & Shri Rajat Kumar Kureel (Cit) – Ld. Drs (Virtual) Date Of Final Hearing : 27-01-2026 Date Of Pronouncement : 03-02-2026

153B of the Act so as to provide that the time period beginning with the date on which the reference is made to the valuation officer and ending with the date on which his report is received by the Assessing Officer shall be excluded from the time period provided under aforesaid sections for completion of assessment or reassessment

M/S CREDO ASSETS PVT. LTD.,RUPNAGAR PUNJAB vs. DCIT/ACIT(CEN)-1 CHD, CHANDIGARH

The appeals stand partly allowed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No.487/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2013-14) M/S Singla Builders & Promoters Ltd. Dcit / Acit Central-1 बनाम/ Plot No 1265, Sector 82, Industrial Area C.R. Building, Sector 17 Vs. Rupnagar (Punjab) 140308 Chandigarh-160017 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaocs-6503-M (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकर अपील सं. / Ita No.482/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2017-18) & 3. आयकर अपील सं. / Ita No.484/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2018-19) M/S Credo Assets Private Ltd. Dcit / Acit Central-1 बनाम/ Plot No 1265-C, Sector 82, Industrial Area C.R. Building, Sector 17 Vs. Rupnagar (Punjab) 140308 Chandigarh-160017 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aafcc-6400-L (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Parikshit Aggarwal (Ca) & Smt. Shruti Khandelwal (Ca) – Ld. Ars ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) & Shri Rajat Kumar Kureel (Cit) – Ld. Drs (Virtual) Date Of Final Hearing : 27-01-2026 Date Of Pronouncement : 03-02-2026

153B of the Act so as to provide that the time period beginning with the date on which the reference is made to the valuation officer and ending with the date on which his report is received by the Assessing Officer shall be excluded from the time period provided under aforesaid sections for completion of assessment or reassessment

ACIT, CIRCLE, PANCHKULA vs. SHRI SURINDER GARG, PANCHKULA

Bench: Us:

153B and section 153C, all other provisions of this Act shall apply to assessment made under this section. This implies that nature of assessment or reassessment

M/S AGGARWAL SALES,ZIRAKPUR vs. DCIT, CC, PATIALA

Bench: The High Court Of Bombay In The Case Of Cit Vs. M/S Murli Agro Products Ltd. (Supra), Wherein On The Issue Of Exercise Of Revisionary Powers By The Commissioner Of Income Tax U/S 263 Of The Act, On The Order Passed By The Assessing Officer Under Section 153A, It Was Contended By The Revenue That The Impugned Order Was Erroneous & Prejudicial To The Interest Of The Revenue Since The Assessing Officer Had Only Determined The Undisclosed Income & Not The Total Income Which Is The Mandate Of Section 153A .The Hon'Ble High Court, While Adjudicating The Issue, Dealt At Length With The Purpose Of Introduction Of The New Search Assessment Procedures, As Against The Earlier Block Assessment Procedures & Then Went On To Interpret The Proviso To Section 153A(1) & Held That It Is Only Pending Proceedings Which Are Abated On Initiation Of Proceedings Under Section 153A Of The Act, While The Assessments Which Have Attained Finality Cannot Be Disturbed Unless Materials Gathered In The Course Of Proceedings Under Section 153A Of The Act Established Otherwise.

153B and section 153C, all other provisions of this Act shall apply to assessment made under this section. This implies that nature of assessment or reassessment

M/S AGGARWAL SALES,ZIRAKPUR vs. DCIT, CC, PATIALA

Bench: The High Court Of Bombay In The Case Of Cit Vs. M/S Murli Agro Products Ltd. (Supra), Wherein On The Issue Of Exercise Of Revisionary Powers By The Commissioner Of Income Tax U/S 263 Of The Act, On The Order Passed By The Assessing Officer Under Section 153A, It Was Contended By The Revenue That The Impugned Order Was Erroneous & Prejudicial To The Interest Of The Revenue Since The Assessing Officer Had Only Determined The Undisclosed Income & Not The Total Income Which Is The Mandate Of Section 153A .The Hon'Ble High Court, While Adjudicating The Issue, Dealt At Length With The Purpose Of Introduction Of The New Search Assessment Procedures, As Against The Earlier Block Assessment Procedures & Then Went On To Interpret The Proviso To Section 153A(1) & Held That It Is Only Pending Proceedings Which Are Abated On Initiation Of Proceedings Under Section 153A Of The Act, While The Assessments Which Have Attained Finality Cannot Be Disturbed Unless Materials Gathered In The Course Of Proceedings Under Section 153A Of The Act Established Otherwise.

153B and section 153C, all other provisions of this Act shall apply to assessment made under this section. This implies that nature of assessment or reassessment

ITO, WARD, SIRHIND vs. SH. KESAR SINGH, SIRHIND

The appeals of the Revenue is allowed whereas Cross

Bench: Smt. Diva Singh & Dr. B.R.R. Kumar

153B, 154, 155, 158BE and 231 and for the purposes of payment of interest under section 243 or 244 or, as the case may be, section 244A, for making the assessment or reassessment

ITO, WARD, SIRHIND vs. SH. HARJIT SINGH, SIRHIND

The appeals of the Revenue is allowed whereas Cross

Bench: Smt. Diva Singh & Dr. B.R.R. Kumar

153B, 154, 155, 158BE and 231 and for the purposes of payment of interest under section 243 or 244 or, as the case may be, section 244A, for making the assessment or reassessment

DCIT, CIRCLE, MANDI GOBINGARH vs. SH. GURINDERJIT SINGH, SIRHIND

The appeals of the Revenue is allowed whereas Cross

Bench: Smt. Diva Singh & Dr. B.R.R. Kumar

153B, 154, 155, 158BE and 231 and for the purposes of payment of interest under section 243 or 244 or, as the case may be, section 244A, for making the assessment or reassessment

S. P. SINGLA CONSTRUCTIONS PRIVATE LIMITED,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CHANDIGARH

In the result, all the appeals of the assessee are allowed whereas the stay applications are dismissed

Bench: Shri Mahavir Singh & Dr Krinwant Sahay

reassessment shall be passed by an Assessing Officer below the rank of Joint Commissioner in respect of each assessment year referred to in clause (b) of sub- section (1) of section 153A or the assessment year referred to in clause (b) of sub-section (1) of section 153B