ITO, WARD, SIRHIND vs. SH. KESAR SINGH, SIRHIND

The appeals of the Revenue is allowed whereas Cross

Bench: Smt. Diva Singh & Dr. B.R.R. Kumar

reassessment or re-computation, as the case may be, shall, after the exclusion of the period under subsection (4) of section 245HA, be not less than one year; and where such period of limitation is less than one year, it shall be deemed to have been extended to one year; and for the purposes of determining the period of limitation

ITO, WARD, SIRHIND vs. SH. HARJIT SINGH, SIRHIND

The appeals of the Revenue is allowed whereas Cross

Bench: Smt. Diva Singh & Dr. B.R.R. Kumar

reassessment or re-computation, as the case may be, shall, after the exclusion of the period under subsection (4) of section 245HA, be not less than one year; and where such period of limitation is less than one year, it shall be deemed to have been extended to one year; and for the purposes of determining the period of limitation

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 notice was issued to the Assessee company. This is more or less admitted position in the instant case [ Note 26 on page 22 of paper book and para 2 & 3 on page 61 of Paper book]. There was no fresh tangible material at all with Revenue for 147/148 proceedings; after original assessment proceedings dt. 30/11/2017 were over. Even

ANIL KUMAR,UNA vs. INCOME TAX OFFICER, WARD, UNA, UNA

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Krinwant Sahay, Am M.A. No. 121/Chandi/2025 [In Ita No.25/Chandi/2022] (िनधा"रणवष" / Assessment Year: 2010-11) Dcit, Central Circle-1, M/S Oswal Apparels Pvt. Ltd., बनाम/ Vs. Ludhiana Ludhiana "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaaco-9177-H (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Gaurav Sharma (Ca) ""थ"कीओरसे/Respondent By : Dr. Ranjit Kaur (Addl. Cit) Sr. Dr (Virtual)

254(2). This argument was negated by this Court on the ground that the aforesaid decision did not apply to the facts of the case because the time to file the Miscellaneous Application seeking rectification expired on 31st May 2022. There was no argument canvassed in this matter, and nor was it the assessee’s case that its Miscellaneous Application

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)

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 Officer shall serve

DCIT,CIRCLE-1(EXEMPTION), CHANDIGARH vs. M/S MANAV MANGAL SCHOOL( MANAV MANGAL SOCIETY), CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

254 ITR 377 (Del) opined- 2.3 Further, the Hon'ble SC in CIT vs. Delhi Safe Deposits Co. Ltd. [1982] 133 ITR 756 (SC), gave a view that- 2.4 Taking in consideration the ratio laid down by the Hon’ble SC, the appellant wishes to apply the same to its own case. The Learned AO, in the impugned order made

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

254 ITR 377 (Del) opined- 2.3 Further, the Hon'ble SC in CIT vs. Delhi Safe Deposits Co. Ltd. [1982] 133 ITR 756 (SC), gave a view that- 2.4 Taking in consideration the ratio laid down by the Hon’ble SC, the appellant wishes to apply the same to its own case. The Learned AO, in the impugned order made

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

254 ITR 377 (Del) opined- 2.3 Further, the Hon'ble SC in CIT vs. Delhi Safe Deposits Co. Ltd. [1982] 133 ITR 756 (SC), gave a view that- 2.4 Taking in consideration the ratio laid down by the Hon’ble SC, the appellant wishes to apply the same to its own case. The Learned AO, in the impugned order made

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

254 ITR 377 (Del) opined- 2.3 Further, the Hon'ble SC in CIT vs. Delhi Safe Deposits Co. Ltd. [1982] 133 ITR 756 (SC), gave a view that- 2.4 Taking in consideration the ratio laid down by the Hon’ble SC, the appellant wishes to apply the same to its own case. The Learned AO, in the impugned order made

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

254 ITR 377 (Del) opined- 2.3 Further, the Hon'ble SC in CIT vs. Delhi Safe Deposits Co. Ltd. [1982] 133 ITR 756 (SC), gave a view that- 2.4 Taking in consideration the ratio laid down by the Hon’ble SC, the appellant wishes to apply the same to its own case. The Learned AO, in the impugned order made

M/S MANAV MANGAL SOCIETY,CHANDIGARH vs. DCIT, C-1, (E), CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

254 ITR 377 (Del) opined- 2.3 Further, the Hon'ble SC in CIT vs. Delhi Safe Deposits Co. Ltd. [1982] 133 ITR 756 (SC), gave a view that- 2.4 Taking in consideration the ratio laid down by the Hon’ble SC, the appellant wishes to apply the same to its own case. The Learned AO, in the impugned order made

M/S MANAV MANGAL SOCIETY,CHANDIGARH vs. DCIT, C-1, (E), CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

254 ITR 377 (Del) opined- 2.3 Further, the Hon'ble SC in CIT vs. Delhi Safe Deposits Co. Ltd. [1982] 133 ITR 756 (SC), gave a view that- 2.4 Taking in consideration the ratio laid down by the Hon’ble SC, the appellant wishes to apply the same to its own case. The Learned AO, in the impugned order made

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

254 ITR 377 (Del) opined- 2.3 Further, the Hon'ble SC in CIT vs. Delhi Safe Deposits Co. Ltd. [1982] 133 ITR 756 (SC), gave a view that- 2.4 Taking in consideration the ratio laid down by the Hon’ble SC, the appellant wishes to apply the same to its own case. The Learned AO, in the impugned order made

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

PUNJAB BEVERAGES PVT. LTD.,PATIALA vs. DCIT, CIRCLE, PATIALA

Bench: Shri Sanjay Garg & Smt.Annapurna Guptaआयकर अपील सं./ Ita No.438/Chd/2018 "नधा"रण वष" / Assessment Year : 2001-02

reassessment order dated 28.03.2014 u/s!43(3)/254 of the Act was passed giving effect to the set aside proceedings.” 7. The Ld. counsel for assessee further stated that even before the I.T.A.T. the Ld.CIT DR, during the course of hearing, had filed a report of the A.O. dated 14.8.2018 (inadvertently typed as 14.8.2017) stating so. Our attention was drawn

DCIT, CIRCLE, PATIALA vs. M/S PUNJAB BEVERAGES PVT. LTD., PATIALA

Bench: Shri Sanjay Garg & Smt.Annapurna Guptaआयकर अपील सं./ Ita No.438/Chd/2018 "नधा"रण वष" / Assessment Year : 2001-02

reassessment order dated 28.03.2014 u/s!43(3)/254 of the Act was passed giving effect to the set aside proceedings.” 7. The Ld. counsel for assessee further stated that even before the I.T.A.T. the Ld.CIT DR, during the course of hearing, had filed a report of the A.O. dated 14.8.2018 (inadvertently typed as 14.8.2017) stating so. Our attention was drawn

SH. SANJAY SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

1) will have to be mandatorily issued to the person searched requiring him to file returns for six AYs immediately preceding the previous year relevant to the AY in which the search takes place. ii. Assessments and reassessments pending on the date of the search shall abate. The total income for such AYs will have to be computed