DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, LUDHIANA , LUDHIANA vs. HOMELIFE BUILDCON PVT. LTD., LUDHIANA

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

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 880/Chd/2024 निर्धारण वर्ष / Assessment Year : 2021-22 Homelife Buildcon Private Limited Sunview Enclave, Ayali Kalan, Ludhiana, Punjab-142027 स्थायी लेखा सं./PAN NO: AABCH5690M अपीलार्थी/Appellant The DCIT Central Circle-1 Ludhiana, Punjab प्रत्यर्थी/Respondent आयकर अपील सं. / ITA No. 1036/Chd/2024 निर्धारण वर्ष / Assessment Year : 2021-22 Homelife Buildcon Private Limited Sunview Enclave, Ayali Kalan, Lu

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 25 shows that it was obtained in reference

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)

253 of the Income Tax Act, 1961. Revenue is aggrieved by the order no. ITBA/FAC/250/2022- 23/1044150537(1) dt. 22/07/2022 of the Ld. CIT(A) passed under section 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

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

253 contemplates that the Tribunal may admit an appeal or permit filing of memorandum of cross- objections after expiry of relevant period, if it is satisfied that there was a sufficient cause for not presenting it within that period. This expression sufficient cause employed in the section has also been used identically in sub-section 3 of section

SMT. GINNY SOIN,LUDHIANA vs. ACIT, CC-II, LUDHIANA

The appeals are partly allowed

253 contemplates that the\nTribunal may admit an appeal or permit filing of\nmemorandum of cross- objections after expiry of relevant\nperiod, if it is satisfied that there was a sufficient cause for\nnot presenting it within that period. This expression\nsufficient cause employed in the section has also been used\nidentically in sub-section 3 of section

SH. DINESH SOIN,LUDHIANA vs. ACIT, LUDHIANA

The appeals are partly allowed

253 contemplates that the\nTribunal may admit an appeal or permit filing of\nmemorandum of cross- objections after expiry of relevant\nperiod, if it is satisfied that there was a sufficient cause for\nnot presenting it within that period. This expression\nsufficient cause employed in the section has also been used\nidentically in sub-section 3 of section

SMT. GINNY SOIN,LUDHIANA vs. ACIT, CC-II, LUDHIANA

The appeals are partly allowed

253 contemplates that the\nTribunal may admit an appeal or permit filing of\nmemorandum of cross- objections after expiry of relevant\nperiod, if it is satisfied that there was a sufficient cause for\nnot presenting it within that period. This expression\nsufficient cause employed in the section has also been used\nidentically in sub-section 3 of section

J. K. EDUCATIONAL SOCIETY,JAMMU vs. DCIT, CIRCLE-1, CHANDIGARH

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

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

reassessment proceedings, the deposit of cash was found to be explained by the AO. At the same time, it was noticed by the AO that the assessee society had made security deposit of Rs. 21.49 lacs with a closely related family trust i.e; Lala Daswandi Ram Family Trust. The assessee society was thereafter called upon to explain

J.K.EDUCATIONAL SOCIETY,JAMMU vs. INCOME TAX OFFICER (EXEMPTION), CHANDIGARH

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

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

reassessment proceedings, the deposit of cash was found to be explained by the AO. At the same time, it was noticed by the AO that the assessee society had made security deposit of Rs. 21.49 lacs with a closely related family trust i.e; Lala Daswandi Ram Family Trust. The assessee society was thereafter called upon to explain

J.K. EDUCATIONAL SOCIETY,JAMMU & KASHMIR vs. DCIT (EXEMPTION)-CIRCLE-1,, CHANDIGARH

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

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

reassessment proceedings, the deposit of cash was found to be explained by the AO. At the same time, it was noticed by the AO that the assessee society had made security deposit of Rs. 21.49 lacs with a closely related family trust i.e; Lala Daswandi Ram Family Trust. The assessee society was thereafter called upon to explain

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)

253(4) of the Act. 36. Now, reverting to levy of interest u/s 234B of the Act, during the course of hearing, the Ld. AR submitted that the assessee entered into APA with CBDT on 06/02/2017 in relation to the covered international transaction with AE as stated in the said agreement. It was submitted that the said agreement was entered

EXOTIC REALTORS AND DEVELOPERS,CHANDIGARH vs. PR.CIT-1, CHANDIGARH

In the result, appeal of the assessee is allowed

Bench: SHRI. KRINWANT SAHAY (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

253 of the Income Tax Act, 1961. The assessee is aggrieved by the order passed under Section 263 of the Act, bearing order no. ITBA/REV/F/REV5/2022 dt. 27/03/2023 which is hereinafter referred to as the impugned order. The impugned order has revised the AO’s order no. ITBA/AST/S/143(3) 2020-21/1027309634(1) dt. 12/06/2020 which is hereinafter referred

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

253 contemplates that the Tribunal may admit an appeal or permit filing of memorandum of cross- objections after expiry of relevant period, if it is satisfied that there was a sufficient cause for not presenting it within that period. This expression sufficient cause employed in the section has also been used identically in sub-section 3 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

253 contemplates that the Tribunal\nmay admit an appeal or permit filing of memorandum of cross-\nobjections after expiry of relevant period, if it is satisfied that there\nwas a sufficient cause for not presenting it within that period. This\nexpression sufficient cause employed in the section has also been\nused identically in sub-section 3 of 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

253 contemplates that the\nTribunal may admit an appeal or permit filing of memorandum\nof cross- objections after expiry of relevant period, if it is\nsatisfied that there was a sufficient cause for not presenting\nit within that period. This expression sufficient cause\nemployed in the section has also been used identically in sub-\nsection 3 of 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

253 contemplates that the\nTribunal may admit an appeal or permit filing of memorandum\nof cross- objections after expiry of relevant period, if it is\nsatisfied that there was a sufficient cause for not presenting\nit within that period. This expression sufficient cause\nemployed in the section has also been used identically in sub-\nsection 3 of section

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

253 contemplates that the\nTribunal may admit an appeal or permit filing of memorandum\nof cross- objections after expiry of relevant period, if it is\nsatisfied that there was a sufficient cause for not presenting\nit within that period. This expression sufficient cause\nemployed in the section has also been used identically in sub-\nsection 3 of section

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

253 contemplates that the\nTribunal may admit an appeal or permit filing of memorandum\nof cross- objections after expiry of relevant period, if it is\nsatisfied that there was a sufficient cause for not presenting\nit within that period. This expression sufficient cause\nemployed in the section has also been used identically in sub-\nsection 3 of section

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, LUDHIANA vs. MALBROS INTERNATIONAL PVT LTD, FARIDKOT

In the result, both the appeals and the Cross Objections are dismissed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 992 & 993/Chd/2024 "नधा"रण वष" / Assessment Years: 2017-18, 2016-17 The Dcit, Vs Malbros International Pvt. Ltd., Central Circle-2, Village – Mansoorwal, Teh-Zira, Ludhiana. Head Offices Old Cantt. Road, Faridkot. "थायी लेखा सं./Pan No: Aadcm7203R अपीलाथ"/Appellant ""यथ"/Respondent & C.O. Nos. 46 & 45/Chd/2024 In आयकर अपील सं./ Ita Nos. 992 & 993/Chd/2024 "नधा"रण वष" / Assessment Year: 2017-18, 2016-17 Malbros International Pvt. Ltd., The Dcit, Village – Mansoorwal, Teh-Zira, Vs Central Circle-2, Head Offices Old Cantt. Road, Ludhiana. Faridkot. "थायी लेखा सं./Pan No: Aadcm7203R अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Sudhir Sehgal, Advocate Revenue By : Smt. Kusum Bansal, Cit Dr Date Of Hearing : 14.05.2025 Date Of Pronouncement : 25.06.2025

253 contemplates that the Tribunal may admit an appeal or permit filing of memorandum of cross- objections after expiry of relevant period, if it is satisfied that there was a sufficient cause for not presenting ITA No.992 & 993/CHD/2024 & CO 46 & 45/CHD/2024 A.Y.2017-18 & 2016-17 3 it within that period. This expression sufficient cause employed in the section has also been

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)

253 of the Income Tax Act, 1961 as and by way of second appeal under the Act. The assessee is aggrieved by order dt. 01/05/2023 passed in first appeal bearing No. 10408/2012-13/IT/CIT(A)- 5/Ldh/2021-22 of Ld. CIT(A) under section 250(6) of the Act, which is hereinafter referred to as the “impugned order”. FACTUAL MATRIX 2. The assessee