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

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

section 250(6) of the Income Tax Act, 1961. The appeal, filed with a delay of 34 days, raised several issues including dismissal by Ld. CIT(A) without proper notice, invalid initiation of reassessment

KISSAN FATS LTD.,BATHINDA vs. DCIT, CC-1, LUDHIANA

In the result, the appeal of the assessee is allowed

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

250(6) of the Act, which is hereinafter referred to as the “impugned order”. FACTUAL MATRIX 2. The assessee is a company under the Companies Act, 1956/2013. The assessee is into the business of manufacturing vanaspati ghee and refined oil and had filed return of income at rs. 2,07,78,950/- on 30/09/2013. 3. The assessee maintains audited books

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

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

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

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)

section 250 on various dates. As recorded in the appellate order, no submissions were filed by the assessee, and the appeal was dismissed by the Ld. CIT(A) vide order dated 07.10.2024, primarily on the ground of non-prosecution, while also affirming the action of the Assessing Officer on merits. 5. Against the order

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

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

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

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

WARYAM STEEL CASTINGS PRIVATE LIMITED,LUDHIANA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-4, LUDHIANA

In the result, appeal of the assessee is allowed and the Cross appeal of the Revenue is dismissed

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

reassessment proceedings have not been provided. 2. That the order dated 10.05.2024 passed u/s 250 of the Act by the National faceless Appeal Centre (NFAC). Delhi is against law and (acts on the (lie in as much as he was not justified to uphold the action of the Ld. Assessing Officer. Assessment Unit. Income Tax Department in restricting the addition

ASTT. COMMISSIONER OF INCOME TAX, CIRCLE-4, LUDHIANA, AAYAKAR BHAWAN vs. WARYAM STEEL CASTING PRIVATE LIMITED, KANGANWAL ROAD

In the result, appeal of the assessee is allowed and the Cross appeal of the Revenue is dismissed

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

reassessment proceedings have not been provided. 2. That the order dated 10.05.2024 passed u/s 250 of the Act by the National faceless Appeal Centre (NFAC). Delhi is against law and (acts on the (lie in as much as he was not justified to uphold the action of the Ld. Assessing Officer. Assessment Unit. Income Tax Department in restricting the addition

ANISH GARG,PATIALA vs. ACIT/ DCIT CEN CIR,, PATIALA

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

Bench: Shri Laliet Kumarआयकर अपील सं./ Ita Nos. 280 To 284/Chd/2025 "नधा"रण वष" / Assessment Years : 2013-14 To 2017-18 Anish Garg, The Acit / Dcit, बनाम 102, Central Circle, New Colony Patiala Vs. Sular, Patiala "थायी लेखा सं./ Pan No: Aocpg6331A अपीलाथ"/Appellant ""यथ"/Respondent ( Virtual Mode ) "नधा"रती क" ओर से/Assessee By : Sh. Rajiv Saldi, Ca राज"व क" ओर से/ Revenue By : Smt. Surinder Kaur Waraich, Addl. Cit,Sr.Sr सुनवाई क" तार"ख/Date Of Hearing : 27.08.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 27.08.2025 आदेश/Order

250(6) of the Income Tax Act, 1961 (hereinafter referred to as “the Act”). 2. The Assessee has preferred identical grounds of appeal in these appeals. So, these were heard together and are being disposed off by this common and consolidated order. We shall take ITA No. 280/Chd/2025 for assessment year 2013-14, as a lead case, wherein following grounds

ANISH GARG,PATIALA vs. ACIT/ DCIT CEN CIR, PATIALA

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

Bench: Shri Laliet Kumarआयकर अपील सं./ Ita Nos. 280 To 284/Chd/2025 "नधा"रण वष" / Assessment Years : 2013-14 To 2017-18 Anish Garg, The Acit / Dcit, बनाम 102, Central Circle, New Colony Patiala Vs. Sular, Patiala "थायी लेखा सं./ Pan No: Aocpg6331A अपीलाथ"/Appellant ""यथ"/Respondent ( Virtual Mode ) "नधा"रती क" ओर से/Assessee By : Sh. Rajiv Saldi, Ca राज"व क" ओर से/ Revenue By : Smt. Surinder Kaur Waraich, Addl. Cit,Sr.Sr सुनवाई क" तार"ख/Date Of Hearing : 27.08.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 27.08.2025 आदेश/Order

250(6) of the Income Tax Act, 1961 (hereinafter referred to as “the Act”). 2. The Assessee has preferred identical grounds of appeal in these appeals. So, these were heard together and are being disposed off by this common and consolidated order. We shall take ITA No. 280/Chd/2025 for assessment year 2013-14, as a lead case, wherein following grounds

ANISH GARG,PATIALA vs. ACIT/ DCIT CEN CIR, PATIALA

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

Bench: Shri Laliet Kumarआयकर अपील सं./ Ita Nos. 280 To 284/Chd/2025 "नधा"रण वष" / Assessment Years : 2013-14 To 2017-18 Anish Garg, The Acit / Dcit, बनाम 102, Central Circle, New Colony Patiala Vs. Sular, Patiala "थायी लेखा सं./ Pan No: Aocpg6331A अपीलाथ"/Appellant ""यथ"/Respondent ( Virtual Mode ) "नधा"रती क" ओर से/Assessee By : Sh. Rajiv Saldi, Ca राज"व क" ओर से/ Revenue By : Smt. Surinder Kaur Waraich, Addl. Cit,Sr.Sr सुनवाई क" तार"ख/Date Of Hearing : 27.08.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 27.08.2025 आदेश/Order

250(6) of the Income Tax Act, 1961 (hereinafter referred to as “the Act”). 2. The Assessee has preferred identical grounds of appeal in these appeals. So, these were heard together and are being disposed off by this common and consolidated order. We shall take ITA No. 280/Chd/2025 for assessment year 2013-14, as a lead case, wherein following grounds

ANISH GARG,PATIALA vs. ACIT/ DCIT CEN CIR, PATIALA

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

Bench: Shri Laliet Kumarआयकर अपील सं./ Ita Nos. 280 To 284/Chd/2025 "नधा"रण वष" / Assessment Years : 2013-14 To 2017-18 Anish Garg, The Acit / Dcit, बनाम 102, Central Circle, New Colony Patiala Vs. Sular, Patiala "थायी लेखा सं./ Pan No: Aocpg6331A अपीलाथ"/Appellant ""यथ"/Respondent ( Virtual Mode ) "नधा"रती क" ओर से/Assessee By : Sh. Rajiv Saldi, Ca राज"व क" ओर से/ Revenue By : Smt. Surinder Kaur Waraich, Addl. Cit,Sr.Sr सुनवाई क" तार"ख/Date Of Hearing : 27.08.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 27.08.2025 आदेश/Order

250(6) of the Income Tax Act, 1961 (hereinafter referred to as “the Act”). 2. The Assessee has preferred identical grounds of appeal in these appeals. So, these were heard together and are being disposed off by this common and consolidated order. We shall take ITA No. 280/Chd/2025 for assessment year 2013-14, as a lead case, wherein following grounds