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

reassessment proceedings were not valid." The copy of the judgment is in the Judgment Set at pages 34 to 36. xiv). In our case, neither the person, whose signatures are there is an employee or a family member, which we have challenged at the first instance and, therefore, the service of notice is bad in law. Similarly, in the other

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

reassessment proceedings were not valid." The copy of the judgment is in the Judgment Set at pages 34 to 36. xiv). In our case, neither the person, whose signatures are there is an employee or a family member, which we have challenged at the first instance and, therefore, the service of notice is bad in law. Similarly, in the other

LATE SH. RAJ KUMAR WADHWA THROUGH L/H SMT. USHA WADHWA,PATIALA vs. DCIT, CIRCLE, PATIALA

In the result, the above appeal of the assessee is partly allowed

Bench: The Appeal Is Finally Heard Or Disposed Off.” 3. Ground No 1 & 4 Being General In Nature Need No Adjudication.

159. (1) Where a person dies, his legal representative shall be liable to pay any sum which the deceased would have been liable to pay if he had not died, in the like manner and to the same extent as the deceased. (2) For the purpose of making an assessment (including an assessment, reassessment or recomputation under section

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

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

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

SH. RANDHIR SINGH,SIRSA vs. PCIT ROHTAK, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

159 taxmann.com 715 distinguished judgement of Hon’ble Punjab and Haryana High Court in the case of Mahender Pal Narang reported in 423 ITR 13 endorsed by the Hon'ble Supreme Court of India by dismissing the SLP as reported in 279 Taxman 74(SC) vide its order dated 4th March 2021 and treated this issue as debatable issue

SH. ARVAIL SINGH,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

159 taxmann.com 715 distinguished judgement of Hon’ble Punjab and Haryana High Court in the case of Mahender Pal Narang reported in 423 ITR 13 endorsed by the Hon'ble Supreme Court of India by dismissing the SLP as reported in 279 Taxman 74(SC) vide its order dated 4th March 2021 and treated this issue as debatable issue

SH. PARAMJEET SINGH,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

159 taxmann.com 715 distinguished judgement of Hon’ble Punjab and Haryana High Court in the case of Mahender Pal Narang reported in 423 ITR 13 endorsed by the Hon'ble Supreme Court of India by dismissing the SLP as reported in 279 Taxman 74(SC) vide its order dated 4th March 2021 and treated this issue as debatable issue

SURJEET SINGH,SIRSA vs. PCIT, ROHTAK, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

159 taxmann.com 715 distinguished judgement of Hon’ble Punjab and Haryana High Court in the case of Mahender Pal Narang reported in 423 ITR 13 endorsed by the Hon'ble Supreme Court of India by dismissing the SLP as reported in 279 Taxman 74(SC) vide its order dated 4th March 2021 and treated this issue as debatable issue

SH. KASHMIR SINGH SANDHA,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

159 taxmann.com 715 distinguished judgement of Hon’ble Punjab and Haryana High Court in the case of Mahender Pal Narang reported in 423 ITR 13 endorsed by the Hon'ble Supreme Court of India by dismissing the SLP as reported in 279 Taxman 74(SC) vide its order dated 4th March 2021 and treated this issue as debatable issue

M/S GANESH DASS HUF,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

159 taxmann.com 715 distinguished judgement of Hon’ble Punjab and Haryana High Court in the case of Mahender Pal Narang reported in 423 ITR 13 endorsed by the Hon'ble Supreme Court of India by dismissing the SLP as reported in 279 Taxman 74(SC) vide its order dated 4th March 2021 and treated this issue as debatable issue

DHUNI CHAND HUF,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

159 taxmann.com 715 distinguished judgement of Hon’ble Punjab and Haryana High Court in the case of Mahender Pal Narang reported in 423 ITR 13 endorsed by the Hon'ble Supreme Court of India by dismissing the SLP as reported in 279 Taxman 74(SC) vide its order dated 4th March 2021 and treated this issue as debatable issue

M/S GREATER MOHALI AREA DEVELOPMENT AUTHORITY,MOHALI vs. DCIT, C-6(1), MOHALI

In the result, the appeal of the assessee is hereby dismissed

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumarassessment Year : 2009-10

reassessment beyond the period of four years. Therefore the section postulates a duty on every assessee to disclose fully and truly all material facts necessary for his assessment. 6. A catena of judgments, both of the Hon’ble Supreme Court and of the Hon’ble High Courts have given judgments bringing certain broad principles on this issue. The undersigned

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)

159 taxmann.com 51 (Bombay)[29-01-2024] Section 37(1), read with sections 36(1)(iii), 36(1)(va), 43A and 147/148, of the Income-tax Act, 1961 - Business expenditure - Allowability of (Reassessment

GURDISH KAUR KHULAR,JALANDHAR vs. ACIT( INTERNATIONAL TAXATION), CIRCLE, CHANDIGARH

In the result, appeal of the assessee is allowed

section 144 r.w.s 147 of the Act and made the addition of Rs. 35,01,000/-. 5. Being aggrieved the assessee carried the matter to the Ld. CIT(A) and furnished the written submission which reads as under: This is the case of assessee, individual, NRI residing in Surrey, Canada. Case was reopened u/s 147 of the Act, notice

DHARAMPAL SAGHERA,CHANDIGARH vs. INCOME TAX OFFICER, WARD-1(4), CHANDIGARH , CHANDIGARH

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

Bench: Sh. Laliet Kumar Hon’Ble & Sh. Manoj Kumar Aggarwal, Hon’Ble

reassessment, the AO held that since the assessee lacked legal ownership, the amount could not be treated as consideration for the transfer of a capital asset. The AO treated it the same as a gift under Section 56(2) and assessed it as “income from other sources”. 5. In appeal, the Ld. CIT(A) upheld the AO's action, observing

RKS BUILDERS PROMOTERS 1189, NEAR AARTI CHOWK, KRISHNA NAGAR, LUDHIANA,PUNJAB vs. THE DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2, LUDHIANA , PUNJAB

Appeal stand allowed accordingly

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं./ Ita No.815/Chandi/2024 (िनधा"रणवष" / Assessment Year: 2016-17) & 2.आयकरअपीलसं./ Ita No.816/Chandi/2024 (िनधा"रणवष" / Assessment Year: 2017-18) & आयकरअपीलसं./ Ita No.817/Chandi/2024 3. (िनधा"रणवष" / Assessment Year: 2018-19) Dcit-Central Circle-2 M/S Rks Builders & Promoters बनाम/ Ludhiana. #1189, Near Aarti Chowk Vs. Krishna Nagar, Ludhiana – 141 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aatfr-5642-N (अपीलाथ"/Appellant) : (""थ" / Respondent) & 4. आयकरअपीलसं./ Co No.2/Chandi/2025 (In Ita No.815/Chandi/2024) (िनधा"रणवष" / Assessment Year: 2016-17) & 5. आयकरअपीलसं./ Co No.3/Chandi/2025 (In Ita No.816/Chandi/2024) (िनधा"रणवष" / Assessment Year: 2017-18) & 6. आयकरअपीलसं./ Ita No.649/Chandi/2024 (िनधा"रणवष" / Assessment Year: 2018-19) & 7. आयकरअपीलसं./ Ita No.648/Chandi/2024

reassess the income of such other person in the manner contemplated by the provisions of Section 153A.Similar is the view in Pr. CIT vs. G. Lakshmi Aruna (159