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)

17. We therefore find that the term “incriminating material” have to be read and understood in the context of one or more of the conditions stipulated in section 132(1) and on satisfaction of which, a search can be authorised and search warrant can be issued. That is, there is information in possession of the competent authority and basis which

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)

17. We therefore find that the term “incriminating material” have to be read and understood in the context of one or more of the conditions stipulated in section 132(1) and on satisfaction of which, a search can be authorised and search warrant can be issued. That is, there is information in possession of the competent authority and basis which

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)

17. We therefore find that the term “incriminating material” have to be read and understood in the context of one or more of the conditions stipulated in section 132(1) and on satisfaction of which, a search can be authorised and search warrant can be issued. That is, there is information in possession of the competent authority and basis which

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)

17. We therefore find that the term “incriminating material” have to be read and understood in the context of one or more of the conditions stipulated in section 132(1) and on satisfaction of which, a search can be authorised and search warrant can be issued. That is, there is information in possession of the competent authority and basis which

SHRI MOHAN LAL GUPTA,SHIMLA vs. PR.CIT-1, CHANDIGARH

In the result, appeal of the Assessee is partly allowed

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

section 147 is totally silent on the said matter and even there is no inquiry whatsoever which have been conducted by the AO during the reassessment proceedings and therefore the order so passed by the AO is clearly erroneous in so far as prejudicial to the interest of the Revenue. 16. Regarding transfer expenses and CLU charges, it was submitted

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)

17. Also it is relevant to point out that the issue relating to GDR receipts is not part of the reasons recorded for reassessment proceeding against which notice u/s 148 issued on 31st March, 2018. However you have sought to justify the same by referring to the provisions of Section

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, LUDHIANA , LUDHIANA vs. AVINASH SINGLA, KHANNA

In the result, all the appeals of the Revenue are dismissed

Bench: Shri Rajpal Yaday & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 814 & 815/Chd/2023 "नधा"रण वष" / Assessment Years :2013-14 & 2014-15 Dcit, Vs. Avinash Singla, Central Circle-1, बनाम C-47, C.O Avinash Ludhiana Industries, Focal Point, Khanna "थायी लेखा सं./Pan No. Acypk9591N अपीलाथ"/Appellant ""यथ"/Respondent & आयकर अपील सं./ Ita No. 15/Chd/2024 "नधा"रण वष" / Assessment Year : 2014-15 Dcit, Vs. Meenu Singla, बनाम Central Circle-1, C-47, C.O Avinash Ludhiana Industries, Focal Point, Khanna "थायी लेखा सं./Pan No.Afips6556G अपीलाथ"/Appellant ""यथ"/Respondent

Section 132A, 814-815-Chd-2023 & 15-Chd-2024- Avinash Singla & Meenu Singla, Khanna 17 the AO gets the jurisdiction to assess or reassess

ACIT, CIRCLE 1(1), CHANDIGARH vs. M/S SML ISUZU LTD., CHANDIGARH

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

Reassessment without jurisdiction and illegal :- It is submitted by the assessee company is that during the relevant assessment year 2015-16, the assessee had in terms of Section 36(1)(vii) of the Act, claimed deduction for bad debts written off aggregating to Rs. 62,15,000/- viz(1) Bank guarantee invoked by the Jalandhar City Transport Services

AMARJIT SINGH,LUDHIANA vs. INCOME TAX OFFICER,WARD 6(1) LUDHIANA, LUDHIANA

In the result, appeal of the assessee is allowed for statistical purposes

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 1171 /Chd/2024 निर्धारण वर्ष / Assessment Year : 2017-18 Shri Amarjit Singh बनाम The ITO C/o V V Bhalla & Company Ward 6(1) SCF-39, Rishi Nagar Main Market, Ludhiana Adjoining Subway, Ludhiana-141001, Punjab स्थायी लेखा सं./PAN NO: ABTPS8558B अपीलार्थी/Appellant प्रत्यर्थी/Respondent निर्धारिती की ओर से / Assessee by : Shri Pankaj Bhalla, C.A राजस्व की ओर से/ Revenue by : Shri Vivek Vardhan, Addl. CIT, Sr

reassessment proceedings under section 148 read with section 144A, and defective approval under section 151. The assessee also disputed the addition of Rs 17

JAMNA DASS NIKKAMAL JAIN SARAF PRIVATE LIMITED, LUDHIANA,LUDHIANA vs. THE DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 1, LUDHIANA, LUDHIANA

In the result, the appeal filed by Revenue is dismissed and the appeal filed by the Assessee is allowed

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

reassessment not only. procedurally defective but also without jurisdiction. 33. Even we find while framing the assessment under section 143(3), the Assessing Officer (AO) has, on the last page of the assessment order, referred to an approval obtained from the supervisory authority. However, a bare perusal of this approval shows that it was obtained in reference

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, LUDHIANA, LUDHIANA vs. M/S JAMNA DASS NIKKAMAL JAIN SARAF PVT. LTD., LUDHIANA

In the result, the appeal filed by Revenue is dismissed and the appeal filed by the Assessee is allowed

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

reassessment not only. procedurally defective but also without jurisdiction. 33. Even we find while framing the assessment under section 143(3), the Assessing Officer (AO) has, on the last page of the assessment order, referred to an approval obtained from the supervisory authority. However, a bare perusal of this approval shows that it was obtained in reference

MANDEEP KAUR,FATEHABAD vs. ITO, WARD - 1, FATEHABAD

The appeal stand allowed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No.630/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2016-17) Ms. Mandeep Kaur Ito Ward -1 बनाम/ Vs. Vpo Museh Ali Hizrawan, Khurd, To Fatehabad Rohtak - 124001 Fatehabad, Haryana – 125050 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Datpk-9813-D (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Mukesh Kumar Jain (Ca) – Ld. Ar (Virtual) ""थ"कीओरसे/Respondent By : Sh. Dr. Ranjit Kaur (Addl. Cit) – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 10.02.2026 घोषणाकीतारीख /Date Of Pronouncement : 16.02.2026 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2016- 17 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), Nfac [Cit(A)] Dated 17-02-2025 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S 147 R.W.S. 144Of The Act On30-04-2023. 2. The Ld. Ar, At The Outset, Urged Legal Ground No.4 To Assail The Jurisdiction Of Ld. Ao. In This Ground Of Appeal, It Has Been Pleaded That The Order Passed U/S 148A(D) As Well As Issue Of Notice U/S 148

reassessment proceedings. 4. Pursuant to the said judgment, CBDT issued instruction no. 01/2022 on 11-05-2022 detailing the procedure to be followed in compliance with the order of Hon’ble Supreme Court. Considering the same, the underlying information / material as relied upon by Ld. AO on the basis of which proceedings u/s 148 were initiated

DEPUTY COMMISSIONER OF INCOME TAX, CHANDIGARH vs. WINSOME TEXTILE INDUSTRIES LTD, CHANDIGARH

17.\nAlso it is relevant to point out that the issue relating to GDR receipts is not part of\nthe reasons recorded for reassessment proceeding against which notice u/s 148\nissued on 31st March, 2018. However you have sought to justify the same by\nreferring to the provisions of Section

SHRI SATISH SOIN,LUDHIANA vs. ACIT, CC-II, LUDHIANA

In the result, appeal of the assessee is allowed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 303/Chd/2019 "नधा"रण वष" / Assessment Year : 2012-13 Shri Satish Soin, बनाम The Acit, House No.31, Garden Enclave, Central Circle-2, Vs South City-Ii, Ludhiana. Ludhiana. "थायी लेखा सं./Pan /Tan No: Advps6254N अपीलाथ"/Appellant ""यथ"/Respondent "नधा"रती क" ओर से/Assessee By : Shri Ashwani Kumar & Ms. Muskan Garg, Cas राज"व क" ओर से/ Revenue By : Smt. Kusum Bansal, Cit Dr तार"ख/Date Of Hearing : 26.05.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 23.07.2025 Hybrid Hearing आदेश/Order Per Rajpal Yadav, Vp

17. The ld. Counsel for the assessee while impugning the orders of Revenue Authorities submitted that original assessments were framed under Section 153A. According to the position of law propounded by the Hon'ble Supreme Court in the case of Abhisar Buildwell Pvt. Ltd. 149 taxman.com 399, the additions in an assessment under Section 153A was to be made

M/S PNG TRADING PRIVATE LIMITED,CHANDIGARH vs. DCIT, CHANDIGARH

In the result, all four appeals are allowed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwal

17-B,Chandigarh. Chandigarh. "थायी लेखा सं./PAN NO: AADCP3942J अपीलाथ"/Appellant ""यथ"/Respondent Assessee by : Shri Nikhil Goyal, Advocate and Shri Ashok Goyal,CA Revenue by : Smt. Kusum Bansal, CIT DR and Dr. Ranjit Kaur, Addl. CIT, Sr.DR Date of Hearing : 18.03.2025 Date of Pronouncement : 19.03.2025 HYBRID HEARING O R D E R PER RAJPAL YADAV, VP The present

M/S PNG TRADING PRIVATE LIMITED,CHANDIGARH vs. DCIT, CHANDIGARH

In the result, all four appeals are allowed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwal

17-B,Chandigarh. Chandigarh. "थायी लेखा सं./PAN NO: AADCP3942J अपीलाथ"/Appellant ""यथ"/Respondent Assessee by : Shri Nikhil Goyal, Advocate and Shri Ashok Goyal,CA Revenue by : Smt. Kusum Bansal, CIT DR and Dr. Ranjit Kaur, Addl. CIT, Sr.DR Date of Hearing : 18.03.2025 Date of Pronouncement : 19.03.2025 HYBRID HEARING O R D E R PER RAJPAL YADAV, VP The present

M/S PNG TRADING PRIVATE LIMITED,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

In the result, all four appeals are allowed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwal

17-B,Chandigarh. Chandigarh. "थायी लेखा सं./PAN NO: AADCP3942J अपीलाथ"/Appellant ""यथ"/Respondent Assessee by : Shri Nikhil Goyal, Advocate and Shri Ashok Goyal,CA Revenue by : Smt. Kusum Bansal, CIT DR and Dr. Ranjit Kaur, Addl. CIT, Sr.DR Date of Hearing : 18.03.2025 Date of Pronouncement : 19.03.2025 HYBRID HEARING O R D E R PER RAJPAL YADAV, VP The present

M/S PNG TRADING PRIVATE LIMITED,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

In the result, all four appeals are allowed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwal

17-B,Chandigarh. Chandigarh. "थायी लेखा सं./PAN NO: AADCP3942J अपीलाथ"/Appellant ""यथ"/Respondent Assessee by : Shri Nikhil Goyal, Advocate and Shri Ashok Goyal,CA Revenue by : Smt. Kusum Bansal, CIT DR and Dr. Ranjit Kaur, Addl. CIT, Sr.DR Date of Hearing : 18.03.2025 Date of Pronouncement : 19.03.2025 HYBRID HEARING O R D E R PER RAJPAL YADAV, VP The present