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

192.\nb) Winsome Textile Industries Vs. Union of India 278 ITR 470.\nc) Navkar share and stock brokers Vs. ACIT 390 ITR 362 &\nd) Haryana Acrylics Manufacturing company Vs. CIT 308 ITR 38\nii) That it is relevant to point out that after initiation of the reassessment\nproceedings, a notice was issued U/s 142(1) was issued on 4th July

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

reassessment. These amendments were to take effect from 01-10-2014. It was thus stated that the legislature specifically laid out emphasis on the limitation period to file report by the DVO. In the present case, the report was never served upon the assessee by DVO and secondly, the report was furnished to AO beyond 6 months from

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

reassessment. These amendments were to take effect from 01-10-2014. It was thus stated that the legislature specifically laid out emphasis on the limitation period to file report by the DVO. In the present case, the report was never served upon the assessee by DVO and secondly, the report was furnished to AO beyond 6 months from

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

reassessment. These amendments were to take effect from 01-10-2014. It was thus stated that the legislature specifically laid out emphasis on the limitation period to file report by the DVO. In the present case, the report was never served upon the assessee by DVO and secondly, the report was furnished to AO beyond 6 months from

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

Bench: Us:

section shall be governed by the normal provisions of the Act In case it is an assessment made for the first time, all provisions of assessment which are applicable to assessments made u/s 143(3) shall apply and in case it is a reassessment being made all principles of reassessment which are applicable in case of proceedings u/s 147/148 shall

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.

section shall be governed by the normal provisions of the Act. In case it is an assessment made for the first time, all provisions of assessment which are applicable to assessments made u/s 143(3) shall apply and in case it is a reassessment being made all principles of reassessment which are applicable in case of proceedings u/s 147/148 shall

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.

section shall be governed by the normal provisions of the Act. In case it is an assessment made for the first time, all provisions of assessment which are applicable to assessments made u/s 143(3) shall apply and in case it is a reassessment being made all principles of reassessment which are applicable in case of proceedings u/s 147/148 shall

INDER KAUR,SIRSA vs. PR.CIT, 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)

section 263 read with Explanation 2(a). 14. Accordingly, exercising powers u/s 263, the Ld. Pr. CIT set aside the assessment order and directed the Assessing Officer to make a de novo assessment after conducting requisite enquiries and proper verification with regard to taxability of interest on enhanced compensation, after granting adequate opportunity of being heard to the assessee

KARAN PRATAP SINGH,SIRSA, HARYANA vs. ITO, WARD-1, SIRSA, HARYANA

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)

section 263 read with Explanation 2(a). 14. Accordingly, exercising powers u/s 263, the Ld. Pr. CIT set aside the assessment order and directed the Assessing Officer to make a de novo assessment after conducting requisite enquiries and proper verification with regard to taxability of interest on enhanced compensation, after granting adequate opportunity of being heard to the assessee

SH. DEVENDER KUMAR,YAMUNA NAGAR vs. ITO, WARD -1, YAMUNA NAGAR

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)

section 263 read with Explanation 2(a). 14. Accordingly, exercising powers u/s 263, the Ld. Pr. CIT set aside the assessment order and directed the Assessing Officer to make a de novo assessment after conducting requisite enquiries and proper verification with regard to taxability of interest on enhanced compensation, after granting adequate opportunity of being heard to the assessee

ANIL TUTEJA,FATEHABAD vs. PR. COMMISSIONER OF INCOME TAX, ROHTAK, ROHTAK

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

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

section 263 read with Explanation 2(a). 14. Accordingly, exercising powers u/s 263, the Ld. Pr. CIT set aside the assessment order and directed the Assessing Officer to make a de novo assessment after conducting requisite enquiries and proper verification with regard to taxability of interest on enhanced compensation, after granting adequate opportunity of being heard to the assessee

SH. AMARJEET SINGH,SIRSA vs. PR.CIT, 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)

section 263 read with Explanation 2(a). 14. Accordingly, exercising powers u/s 263, the Ld. Pr. CIT set aside the assessment order and directed the Assessing Officer to make a de novo assessment after conducting requisite enquiries and proper verification with regard to taxability of interest on enhanced compensation, after granting adequate opportunity of being heard to the assessee

MANINDER JEET SINGH V.P.O. UDHAMGARH,JAGADHRI,HARYANA vs. PRABHJOT KAUR,PCIT, PANCHKULA

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

section 263 read with Explanation 2(a). 14. Accordingly, exercising powers u/s 263, the Ld. Pr. CIT set aside the assessment order and directed the Assessing Officer to make a de novo assessment after conducting requisite enquiries and proper verification with regard to taxability of interest on enhanced compensation, after granting adequate opportunity of being heard to the assessee

MUNISH KUMAR LEGAL HEIR LATE SH GURDEEP SINGH,VILL MANAKPUR, YAMUNANAGAR vs. ITO, WARD 5, YAMUNANAGAR

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)

section 263 read with Explanation 2(a). 14. Accordingly, exercising powers u/s 263, the Ld. Pr. CIT set aside the assessment order and directed the Assessing Officer to make a de novo assessment after conducting requisite enquiries and proper verification with regard to taxability of interest on enhanced compensation, after granting adequate opportunity of being heard to the assessee

RAKESH KUMAR,JAGADHRI vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, PANCHKULA

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)

section 263 read with Explanation 2(a). 14. Accordingly, exercising powers u/s 263, the Ld. Pr. CIT set aside the assessment order and directed the Assessing Officer to make a de novo assessment after conducting requisite enquiries and proper verification with regard to taxability of interest on enhanced compensation, after granting adequate opportunity of being heard to the assessee

SH. RAM LAL,FATEHABAD vs. PR.CIT, 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)

section 263 read with Explanation 2(a). 14. Accordingly, exercising powers u/s 263, the Ld. Pr. CIT set aside the assessment order and directed the Assessing Officer to make a de novo assessment after conducting requisite enquiries and proper verification with regard to taxability of interest on enhanced compensation, after granting adequate opportunity of being heard to the assessee

PARVEEN KUMAR,229,VILLAGE MANAKPUR-II,TEHSIL JAGADHRI,HARYANA vs. PRABHJOT KAUR,PCIT PANCHKULA, CHANDIGARH

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

Bench: the Tribunal as pointed out by the Registry. Considering that the issue involved is purely legal in nature, and respectfully following the ratio laid down by the Hon'ble Supreme Court in Collector, Land Acquisition v. Mst. Katiji & Others [(1987) 167 ITR 471 (SC)], which emphasizes that substantial justice should prevail over technical considerations, we condone the delay in filing these appeals.3. We shall take appeal of the assessee in ITA No. 167/Chd/2023 for A.Y 2018-19 as a lead case f

section 263 read with Explanation 2(a). 14. Accordingly, exercising powers u/s 263, the Ld. Pr. CIT set aside the assessment order and directed the Assessing Officer to make a de novo assessment after conducting requisite enquiries and proper verification with regard to taxability of interest on enhanced compensation, after granting adequate opportunity of being heard to the assessee

RAM NIWAS,FATEHABAD vs. INCOME TAX OFFICER, INCOME TAX OFFICE, SIRSA ROAD, INDUSTRIAL AREA, FATEHABAD

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)

section 263 read with Explanation 2(a). 14. Accordingly, exercising powers u/s 263, the Ld. Pr. CIT set aside the assessment order and directed the Assessing Officer to make a de novo assessment after conducting requisite enquiries and proper verification with regard to taxability of interest on enhanced compensation, after granting adequate opportunity of being heard to the assessee

ASHOK KUMAR THAKRAL,JAGADHRI vs. PRINCIPAL COMMISSIONER OF INCOME TAX, PANCHKULA , PANCHKULA

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

Bench: the Tribunal as pointed out by the Registry. Considering that the issue involved is purely legal in nature, and respectfully following the ratio laid down by the Hon'ble Supreme Court in Collector, Land Acquisition v. Mst. Katiji & Others [(1987) 167 ITR 471 (SC)], which emphasizes that substantial justice should prevail over technical considerations, we condone the delay in filing these appeals.3. We shall take appeal of the assessee in ITA No. 167/Chd/2023 for A.Y 2018-19 as a lead case f

section 263 read with Explanation 2(a). 14. Accordingly, exercising powers u/s 263, the Ld. Pr. CIT set aside the assessment order and directed the Assessing Officer to make a de novo assessment after conducting requisite enquiries and proper verification with regard to taxability of interest on enhanced compensation, after granting adequate opportunity of being heard to the assessee