SHRI ABHISHEK SOIN,LUDHIANA vs. DCIT, CC-II, LUDHIANA

The appeals are partly allowed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 321 & 322/Chd/2019 "नधा"रण वष" / Assessment Year: 2010-11, 2011-12 Shri Abhishek Soin, The Dcit, C/O Sigma Cartons Pvt. Ltd., Vs Central Circle-Ii, Unit-Ii, Industrial Area-C, Ludhiana. Sua Road, Ludhiana. "थायी लेखा सं./Pan No: Anbps9446A अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Aditya Kumar, Ca Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 03.06.2025 Date Of Pronouncement : 29.07.2025 Hybrid Hearing O R D E R

255 Taxman 375. He drew our attention towards relevant paragraphs of the judgement which read as under : “11. The assessment order dated 24.12.2010 was passed under Section 153A read with Section 143(3) of the Act after obtaining approval under Section 153D of the Act. The approval was vide letter dated 24.12.2010. Thereafter the said order was taken

SHRI ABHISHEK SOIN,LUDHIANA vs. DCIT, CC-II, LUDHIANA

The appeals are partly allowed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 321 & 322/Chd/2019 "नधा"रण वष" / Assessment Year: 2010-11, 2011-12 Shri Abhishek Soin, The Dcit, C/O Sigma Cartons Pvt. Ltd., Vs Central Circle-Ii, Unit-Ii, Industrial Area-C, Ludhiana. Sua Road, Ludhiana. "थायी लेखा सं./Pan No: Anbps9446A अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Aditya Kumar, Ca Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 03.06.2025 Date Of Pronouncement : 29.07.2025 Hybrid Hearing O R D E R

255 Taxman 375. He drew our attention towards relevant paragraphs of the judgement which read as under : “11. The assessment order dated 24.12.2010 was passed under Section 153A read with Section 143(3) of the Act after obtaining approval under Section 153D of the Act. The approval was vide letter dated 24.12.2010. Thereafter the said order was taken

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

The appeals are partly allowed

255 Taxman 375. He drew our attention\ntowards relevant paragraphs of the judgement which read as\nunder :\n“11. The assessment order dated 24.12.2010 was passed under\nSection 153A read with Section 143(3) of the Act after obtaining\napproval under Section 153D of the Act. The approval was vide letter\ndated 24.12.2010. Thereafter the said order was taken

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)

4] Looking to the facts of the case and data made available on record, total income of the assessee for the year under consideration is computed as under:- 1. Total Income as per original return of Rs. 2,72,79,780/- income filed on 27.09.2018 2. Variation Rs. NIL 3. Total Income: Rs. 2,72,79,780/- [5] Assessed

SH. ARVAIL SINGH,SIRSA vs. PCIT, 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)

4. Before us, the assessee placed reliance on very many judgments including the Order of the ITAT in the case of J Kumar Infraprojects Ltd. v. DCIT [ITA No. 4147/Mum/2024 dated 3.7.2025. On the identical facts and circumstances of the matter we find that considering the approval not being signed by the concerned authority particularly the PCIT herein the reassessment

SURJEET SINGH,SIRSA vs. PCIT, ROHTAK, 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)

4. Before us, the assessee placed reliance on very many judgments including the Order of the ITAT in the case of J Kumar Infraprojects Ltd. v. DCIT [ITA No. 4147/Mum/2024 dated 3.7.2025. On the identical facts and circumstances of the matter we find that considering the approval not being signed by the concerned authority particularly the PCIT herein the reassessment

SH. PARAMJEET SINGH,SIRSA vs. PCIT, 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)

4. Before us, the assessee placed reliance on very many judgments including the Order of the ITAT in the case of J Kumar Infraprojects Ltd. v. DCIT [ITA No. 4147/Mum/2024 dated 3.7.2025. On the identical facts and circumstances of the matter we find that considering the approval not being signed by the concerned authority particularly the PCIT herein the reassessment

SH. RANDHIR SINGH,SIRSA vs. PCIT ROHTAK, 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)

4. Before us, the assessee placed reliance on very many judgments including the Order of the ITAT in the case of J Kumar Infraprojects Ltd. v. DCIT [ITA No. 4147/Mum/2024 dated 3.7.2025. On the identical facts and circumstances of the matter we find that considering the approval not being signed by the concerned authority particularly the PCIT herein the reassessment

DHUNI CHAND HUF,SIRSA vs. PCIT, 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)

4. Before us, the assessee placed reliance on very many judgments including the Order of the ITAT in the case of J Kumar Infraprojects Ltd. v. DCIT [ITA No. 4147/Mum/2024 dated 3.7.2025. On the identical facts and circumstances of the matter we find that considering the approval not being signed by the concerned authority particularly the PCIT herein the reassessment

SH. KASHMIR SINGH SANDHA,SIRSA vs. PCIT, 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)

4. Before us, the assessee placed reliance on very many judgments including the Order of the ITAT in the case of J Kumar Infraprojects Ltd. v. DCIT [ITA No. 4147/Mum/2024 dated 3.7.2025. On the identical facts and circumstances of the matter we find that considering the approval not being signed by the concerned authority particularly the PCIT herein the reassessment

M/S GANESH DASS HUF,SIRSA vs. PCIT, 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)

4. Before us, the assessee placed reliance on very many judgments including the Order of the ITAT in the case of J Kumar Infraprojects Ltd. v. DCIT [ITA No. 4147/Mum/2024 dated 3.7.2025. On the identical facts and circumstances of the matter we find that considering the approval not being signed by the concerned authority particularly the PCIT herein the reassessment

KARTAR SINGH, FATEHABAD vs. PR. COMMISSIONER OF INCOME TAX, 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)

reassessment. Aggrieved by this order passed u/s 263, the appellant is in appeal before Your Honour. Arguments before the Hon’ble ITAT: Issue 1: The issue of taxability of Interest on enhanced compensation was highly debatable when the Ld. AO passed order u/s 143(3) or even when the PCIT passed order u/s 263 and so, when the issue

MADHU GREWAL,CHANDIGARH vs. PRINCIPAL COMMISSIONER OF INCOME TAX, CHANDIGARH-1, 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

reassessment. Aggrieved by this order passed u/s 263, the appellant is in appeal before Your Honour. Arguments before the Hon’ble ITAT: Issue 1: The issue of taxability of Interest on enhanced compensation was highly debatable when the Ld. AO passed order u/s 143(3) or even when the PCIT passed order u/s 263 and so, when the issue

SH. BALJINDER SINGH,CHANDIGARH vs. PR.CIT, CHANDIGARH -1, CHANDIGARH

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)

reassessment. Aggrieved by this order passed u/s 263, the appellant is in appeal before Your Honour. Arguments before the Hon’ble ITAT: Issue 1: The issue of taxability of Interest on enhanced compensation was highly debatable when the Ld. AO passed order u/s 143(3) or even when the PCIT passed order u/s 263 and so, when the issue

SH. GURDEEP SINGH MAHAL,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)

reassessment. Aggrieved by this order passed u/s 263, the appellant is in appeal before Your Honour. Arguments before the Hon’ble ITAT: Issue 1: The issue of taxability of Interest on enhanced compensation was highly debatable when the Ld. AO passed order u/s 143(3) or even when the PCIT passed order u/s 263 and so, when the issue

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)

reassessment. Aggrieved by this order passed u/s 263, the appellant is in appeal before Your Honour. Arguments before the Hon’ble ITAT: Issue 1: The issue of taxability of Interest on enhanced compensation was highly debatable when the Ld. AO passed order u/s 143(3) or even when the PCIT passed order u/s 263 and so, when the issue

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)

reassessment. Aggrieved by this order passed u/s 263, the appellant is in appeal before Your Honour. Arguments before the Hon’ble ITAT: Issue 1: The issue of taxability of Interest on enhanced compensation was highly debatable when the Ld. AO passed order u/s 143(3) or even when the PCIT passed order u/s 263 and so, when the issue

PARAMJIT 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)

reassessment. Aggrieved by this order passed u/s 263, the appellant is in appeal before Your Honour. Arguments before the Hon’ble ITAT: Issue 1: The issue of taxability of Interest on enhanced compensation was highly debatable when the Ld. AO passed order u/s 143(3) or even when the PCIT passed order u/s 263 and so, when the issue

BIMLA DEVI,JAGADHRI 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)

reassessment. Aggrieved by this order passed u/s 263, the appellant is in appeal before Your Honour. Arguments before the Hon’ble ITAT: Issue 1: The issue of taxability of Interest on enhanced compensation was highly debatable when the Ld. AO passed order u/s 143(3) or even when the PCIT passed order u/s 263 and so, when the issue