DCIT, C-1(1) , CHANDIGARH vs. M/S FIDELITY INFORMATION SERVICES INDIA PVT. LTD., CHANDIGARH

In the result, the cross-objection filed by the assessee is dismissed

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

250 or section 254 or section 260 or section 262 or section 263 or section 264, the amount on which interest was payable under sub-section (1) or sub-section (3) has been increased or reduced, as the case may be, the interest shall be increased or reduced accordingly, and- - In a case where the interest is increased, the Assessing

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)

250 of the Act, which is hereinafter referred to as the “impugned order”. 2. At the outset the Registry has pointed out that the appeal filed by the Revenue is time barred by 05 days for which Revenue has filed a condonation of delay application. 3. Delay of 05 days is condoned for which Revenue has shown sufficient cause

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

250 of the Income Tax Act, 1961 hereinafter referred to as "Act"). 2. That on facts, circumstances and legal position of the case, Worthy CIT(A) has erred in confirming the action of Ld. AO of passing asst. order by illegally assumingjurisdiction u/s 153A and more-so when no incriminating material qua this year was found in search

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

250 of the Income Tax Act, 1961 hereinafter referred to as "Act"). 2. That on facts, circumstances and legal position of the case, Worthy CIT(A) has erred in confirming the action of Ld. AO of passing asst. order by illegally assumingjurisdiction u/s 153A and more-so when no incriminating material qua this year was found in search

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

250 of the Income Tax Act, 1961 hereinafter referred to as "Act"). 2. That on facts, circumstances and legal position of the case, Worthy CIT(A) has erred in confirming the action of Ld. AO of passing asst. order by illegally assumingjurisdiction u/s 153A and more-so when no incriminating material qua this year was found in search

AJAY TANTA,SHIMLA vs. INCOME TAX OFFICER, SHIMLA

In the result, appeal of the assessee is allowed

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

reassessment proceedings, notices were issued by the Assessing Officer. However, according to the assessment order, there was no effective compliance on behalf of the assessee. Consequently, the Assessing Officer completed the assessment ex parte under section 144 read with section 147 of the Act vide order dated 28.03.2024, making additions, inter alia, under section 69 of the Act and determining

THE GAROH CO-OPERATIVE AGRICULTURAL SERVICE SOCIETY LIMITED,DHARAMSHALA, KANGRA vs. INCOME TAX OFFICER, DHARAMSHALA, DHARAMSHALA

In the result, both the above appeals are allowed

Bench: SHRI. LALIET KUMAR (Judicial Member)

250 of the Income Tax Act, 1961, for the A.Y. 2015-16. 3. In the present appeal Assessee has raised the following grounds: 1. That the notice issued w/s 148 of the Act dated 31.03.2022 by the Jurisdictional Assessing Officer is illegal in view of the notifications dated 28.03.2022 and 29.03.2022 which states that the notice under section

THE GAROH CO-OPERATIVE AGRICULTURAL SERVICE SOCIETY LIMITED,DHARAMSHALA, KANGRA vs. INCOME TAX OFFICER, WARD-DHARAMSHALA, DHARAMSHALA

In the result, both the above appeals are allowed

Bench: SHRI. LALIET KUMAR (Judicial Member)

250 of the Income Tax Act, 1961, for the A.Y. 2015-16. 3. In the present appeal Assessee has raised the following grounds: 1. That the notice issued w/s 148 of the Act dated 31.03.2022 by the Jurisdictional Assessing Officer is illegal in view of the notifications dated 28.03.2022 and 29.03.2022 which states that the notice under section

DCIT, CC-3, LUDHIANA, KITCHLU NAGAR vs. MANI RAM BALWANT RAI HUF, CIVIL LINES

The appeal of the Revenue is dismissed

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

250 of the Act dated 19.07.2024, partly allowing the appeal. 3.2 The summary of additions and their outcome before the first appellate authority is as under: Issue Addition made Addition Remarks by AO sustained by CIT(A) Sale suppression 4,94,63,415/- 55,06,010/- The CIT(A) upheld sale suppression but quantified

MASTER TRUST LIMITED,LUDHIANA vs. ASSISTANT COMMISSIONER OF INCOME TAX, LUDHIANA

In the result, ground no. 1 of the assessee’s appeal is allowed

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

250 of the Income Tax Act, 1961 by the Learned Commissioner of Income Tax (Appeals), NFAC, Delhi is against law and facts on the file in as much as he was not justified to uphold the action of the Learned Assessing Officer in initiating proceedings u/s 147. 2. That the Learned CIT (Appeals), NFAC, was not justified to arbitrarily uphold

M/S INTERNATIONAL CUSTOMER RELATED MANAGEMENT SERVICES PRIVATE LIMITED,CHANDIGARH vs. D.C.I.T., CIRCLE 6(1), MOHALI

In the result, for statistical purposes, the appeal is

Bench: SHRI A.D.JAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)

reassessment proceedings under section 147 of the Act having being initiated merely on the basis of information received, without independent application of mind by the assessing officer to such information and forming opinion thereof, is illegal and bad in law. 4.4. That on the facts and circumstances of the case and in law, the assessing officer erred in making additions

VINEET KUMAR,DHARAMSHALA vs. INCOME TAX OFFICER, DHARMSHALA

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

Bench: SHRI. LALIET KUMAR (Judicial Member)

reassessment proceedings, invocation of section 144, violation of principles of natural justice, and also the addition made under section 69A of the Act. The grounds, inter alia, include challenge to jurisdiction on account of alleged invalid issuance of notice under section 148, non-compliance of procedure prescribed under section 148A, improper invocation of best judgment assessment despite compliance, and failure

INCOME TAX OFFICER WARD-5 YAMUNA NAGAR, YAMUNA NAGAR vs. SHIVALIK FILLING STATION, KHIZRABAD

In the result, appeal of the Assessee is dismissed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. MANOJ KUMAR AGGARWAL (Accountant Member)

250 of the Income Tax Act, 1961, for Assessment Year 2013–14. 2. The sole effective grievance of the Revenue is that the Ld. CIT(A) erred in law and on facts in deleting the addition of Rs.7,59,50,015/- made under section 69A and on account of contract receipts, without appreciating that the transactions were reported under

ASHISH SOOD,ZIRAKPUR vs. THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), CHANDIGARH, CHANDIGARH

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

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

250 of the Act, dt. 23/10/2023 of Ld. CIT (A), the assesse was called upon to file counter arguments and grant of opportunity to submit objections which read as under: ANNEXURE “Counter Arguments and grant of opportunity to submit objections For the AY 2020-21, it is an admitted fact that form 67 was filed beyond the due date specified

CHHERING TOMDAN,SPITI, HIMACHAL PRADESH vs. INCOME TAX OFFICER, RAMPUR BUSHAHR, HIMACHAL PRADESH

In the result, the appeal is allowed

Bench: Shri A.D. Jain & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 170/Chd/2024 "नधा"रण वष" / Assessment Year : 2017-18 Chhering Tomdan, Vs. The Ito, Village Khurik, बनाम Rampur Bushahr, Po Rangreek, Himachal Pradesh Rangrik B.O. Khurik (78), Lauhaul & Spiti, H.P. 171114 "थायी लेखा सं./Pan No: Bhxpt8803P अपीलाथ"/ Appellant ""यथ"/ Repsondent ( Hybrid Mode ) "नधा"रती क" ओर से/Assessee By : Shri Nikhil Goyal, Advocate, Shri Viren Sibbal, Advocate & Shri Ashok Goyal, Ca राज"व क" ओर से/ Revenue By : Shri Ved Parkash Kalia, Jcit, Sr. Dr

reassessment proceedings are bad in law and non-est as the same have been concluded without following the directions of Hon'ble Supreme Court in the case of Union of India v. Ashish Agarwal (2022) 444 ITR 1 (SC). 4. That the impugned Order had been passed in gross violation of the principle of natural justice and without allowing reasonable

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

250 of the Income Tax Act and deleted the addition of Rs.9,65,71,414/-. Similarly, in Ground No. 5, the assessee has pleaded that CIT(A) has rightly deleted addition made under Section 68 read with Section 115BBE amounting to the tune of Rs.9,65,71,414/-. In other words, both the grounds are in support

M/S V.K. SOOD ENGINEERS & CONTRACTORS,PANCHKULA vs. DCIT, CIRCLE, PANCHKULA

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

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

section 250 of the Income Tax Act, 1961 passed by the Ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi in Appeal No. ITBA/NFAC/S/250/2024- 25/1066009272(1) is contrary to law and facts of the case. 2(a). That in the facts and circumstances of the case, Ld. Commissioner of Income Tax (Appeals), gravelly erred in upholding

HITESH SHARMA,KANGRA, HIMACHAL PRADESH vs. INCOME TAX OFFICER, WARD-PALAMPUR , PALAMPUR

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

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. MANOJ KUMAR AGGARWAL (Accountant Member)

section 250 of the Income-tax Act, 1961 is illegal, arbitrary, and void ab initio, having been passed ex-parte without adjudicating the appeal on merits which is arbitrary and unjustified. 2. That the Id. CIT(A) erred in ignoring the adjournment filed on 22.09.2025 and submissions filed on 29.09.2025 and that the appellant had duly filed the statement