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)

section 153C of the Act, the AO lacks the necessary jurisdiction and the entire reassessment proceedings stood vitiated and in support

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)

section 153C of the Act, the AO lacks the necessary jurisdiction and the entire reassessment proceedings stood vitiated and in support

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)

section 153C of the Act, the AO lacks the necessary jurisdiction and the entire reassessment proceedings stood vitiated and in support

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 is sought to be initiated for a relevant AY falling prior to 01 April 2021, such an action would have to be in conformity with the time limits specified in Sections 149 (1) (b), Sections 153A or 153C

SHRI RAKESH KUMAR KATARIA,CHANDIGARH vs. DCIT-CC-1, CHANDIGARH

In the result, appeal is allowed as indicated

Bench: Shri A.D. Jain & Shri Vikram Singh Yadavआयकर अपील सं./ Ita No. 159/Chd/2020 "नधा"रण वष" / Assessment Year : 2012-13 Shri Rakesh Kumar Kataria Vs. The Dcit, Central Circle, बनाम Chandigarh Sco 862, Prop. Subhinfra, Ist Floor, Nac, Manimajra, Chandigarh "थायी लेखा सं./Pan No: Aespk5238A अपीलाथ"/Appellant ""यथ"/Respondent "नधा"रती क" ओर से/Assessee By : Sh. Parikshit Aggarwal, Ca राज"व क" ओर से/ Revenue By : Shri Dharamvir, Jcit, Sr. Dr सुनवाई क" तार"ख/Date Of Hearing : 05.03.2024 उदघोषणा क" तार"ख/Date Of Pronouncement : 15.04.2024 आदेश/Order

section 143 has expired or (c) assessment or reassessment, if any, has been made. 5.2 The ld. DR has further contended that in this case, the Assessee filed his return of income on 18.03.2013 and notice u/s 143(2) of the Act was issued on 07.08.2013, and that therefore, notice u/s 153C

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

153C. Assessment of income of any other person.—(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

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

153C. Assessment of income of any other person.—(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

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2 LUDHIANA, LUDHIANA vs. AMARJIT SINGH , BATHINDA

In the result, Cross Objections of the assessee

Bench: Shri Rajpal Yadav & Shri Krinwant Sahay

reassessment of the total income of six assessment years immediately preceding the assessment year relevant to the previous year in which such search is conducted. Section 153C

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)

153C for other assessment years are not sustainable. It was further held by the Hon’ble Bombay High Court that the question whether any material found during the course of proceedings under section 132 is incriminating or otherwise has to be tested based only on the satisfaction note recorded by the AO. It was held that the contents

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)

153C for other assessment years are not sustainable. It was further held by the Hon’ble Bombay High Court that the question whether any material found during the course of proceedings under section 132 is incriminating or otherwise has to be tested based only on the satisfaction note recorded by the AO. It was held that the contents

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)

153C for other assessment years are not sustainable. It was further held by the Hon’ble Bombay High Court that the question whether any material found during the course of proceedings under section 132 is incriminating or otherwise has to be tested based only on the satisfaction note recorded by the AO. It was held that the contents

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)

153C for other assessment years are not sustainable. It was further held by the Hon’ble Bombay High Court that the question whether any material found during the course of proceedings under section 132 is incriminating or otherwise has to be tested based only on the satisfaction note recorded by the AO. It was held that the contents

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)

153C for other assessment years are not sustainable. It was further held by the Hon’ble Bombay High Court that the question whether any material found during the course of proceedings under section 132 is incriminating or otherwise has to be tested based only on the satisfaction note recorded by the AO. It was held that the contents

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)

153C for other assessment years are not sustainable. It was further held by the Hon’ble Bombay High Court that the question whether any material found during the course of proceedings under section 132 is incriminating or otherwise has to be tested based only on the satisfaction note recorded by the AO. It was held that the contents

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.

153C. Assessment of income of any other person.—(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

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

153C. (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

153C. (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

153C. (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