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 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

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

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

255 (SO, in which, it has been held as under: 'Section 10(23C) of the Income-tax Act, 1961- Educational institution (profit motive) - Assessment Years 2000-2001 and 2001-2002 - Whether where a surplus was made by educational institution which was ploughed back for educational purposes, said institution was to be held to be existed society for educational purpose

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

255 (SO, in which, it has been held as under: 'Section 10(23C) of the Income-tax Act, 1961- Educational institution (profit motive) - Assessment Years 2000-2001 and 2001-2002 - Whether where a surplus was made by educational institution which was ploughed back for educational purposes, said institution was to be held to be existed society for educational purpose

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

255 (SO, in which, it has been held as under: 'Section 10(23C) of the Income-tax Act, 1961- Educational institution (profit motive) - Assessment Years 2000-2001 and 2001-2002 - Whether where a surplus was made by educational institution which was ploughed back for educational purposes, said institution was to be held to be existed society for educational purpose

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

255 (SO, in which, it has been held as under: 'Section 10(23C) of the Income-tax Act, 1961- Educational institution (profit motive) - Assessment Years 2000-2001 and 2001-2002 - Whether where a surplus was made by educational institution which was ploughed back for educational purposes, said institution was to be held to be existed society for educational purpose

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

255 (SO, in which, it has been held as under: 'Section 10(23C) of the Income-tax Act, 1961- Educational institution (profit motive) - Assessment Years 2000-2001 and 2001-2002 - Whether where a surplus was made by educational institution which was ploughed back for educational purposes, said institution was to be held to be existed society for educational purpose

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

255 (SO, in which, it has been held as under: 'Section 10(23C) of the Income-tax Act, 1961- Educational institution (profit motive) - Assessment Years 2000-2001 and 2001-2002 - Whether where a surplus was made by educational institution which was ploughed back for educational purposes, said institution was to be held to be existed society for educational purpose

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

255 (SO, in which, it has been held as under: 'Section 10(23C) of the Income-tax Act, 1961- Educational institution (profit motive) - Assessment Years 2000-2001 and 2001-2002 - Whether where a surplus was made by educational institution which was ploughed back for educational purposes, said institution was to be held to be existed society for educational purpose

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

255 (SO, in which, it has been held as under: 'Section 10(23C) of the Income-tax Act, 1961- Educational institution (profit motive) - Assessment Years 2000-2001 and 2001-2002 - Whether where a surplus was made by educational institution which was ploughed back for educational purposes, said institution was to be held to be existed society for educational purpose

SBS BIOTECH UNIT II,SIRMOUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX-1, CHANDIGARH

In the result, the appeal of the assessee is allowed

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

255 (SC). 8. It was further submitted that where Assessing Officer having examined relevant material on record, passed the assessment order in case of assessee, the ld. Principal Commissioner without rejecting those documents could not pass a revisional order setting aside assessment as held by Hon'ble Rajasthan High Court in case of Deepak Real Estate Developers

ASHOK KUMAR THAKRAL,JAGADHRI vs. PRINCIPAL COMMISSIONER OF INCOME TAX, PANCHKULA , PANCHKULA

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

7,81,320/- and claiming exemption of Rs. 1,05,10,592/- being interest received on enhanced compensation of compulsory acquisition of agricultural land. (Copy appended at page 16-18 of APB).  During AY 2012-13 i.e. FY 2011-12, agriculture land of the “A” was acquired under Land Acquisition Act, 1894 by the Land Acquisition Authority, Pkl. Later

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)

7,81,320/- and claiming exemption of Rs. 1,05,10,592/- being interest received on enhanced compensation of compulsory acquisition of agricultural land. (Copy appended at page 16-18 of APB).  During AY 2012-13 i.e. FY 2011-12, agriculture land of the “A” was acquired under Land Acquisition Act, 1894 by the Land Acquisition Authority, Pkl. Later

ANIL TUTEJA,FATEHABAD vs. PR. COMMISSIONER OF INCOME TAX, ROHTAK, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

7,81,320/- and claiming exemption of Rs. 1,05,10,592/- being interest received on enhanced compensation of compulsory acquisition of agricultural land. (Copy appended at page 16-18 of APB).  During AY 2012-13 i.e. FY 2011-12, agriculture land of the “A” was acquired under Land Acquisition Act, 1894 by the Land Acquisition Authority, Pkl. Later

KARAN PRATAP SINGH,SIRSA, HARYANA vs. ITO, WARD-1, SIRSA, HARYANA

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)

7,81,320/- and claiming exemption of Rs. 1,05,10,592/- being interest received on enhanced compensation of compulsory acquisition of agricultural land. (Copy appended at page 16-18 of APB).  During AY 2012-13 i.e. FY 2011-12, agriculture land of the “A” was acquired under Land Acquisition Act, 1894 by the Land Acquisition Authority, Pkl. Later

RAKESH KUMAR,JAGADHRI vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, PANCHKULA

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)

7,81,320/- and claiming exemption of Rs. 1,05,10,592/- being interest received on enhanced compensation of compulsory acquisition of agricultural land. (Copy appended at page 16-18 of APB).  During AY 2012-13 i.e. FY 2011-12, agriculture land of the “A” was acquired under Land Acquisition Act, 1894 by the Land Acquisition Authority, Pkl. Later

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)

7,81,320/- and claiming exemption of Rs. 1,05,10,592/- being interest received on enhanced compensation of compulsory acquisition of agricultural land. (Copy appended at page 16-18 of APB).  During AY 2012-13 i.e. FY 2011-12, agriculture land of the “A” was acquired under Land Acquisition Act, 1894 by the Land Acquisition Authority, Pkl. Later

MANINDER JEET SINGH V.P.O. UDHAMGARH,JAGADHRI,HARYANA vs. PRABHJOT KAUR,PCIT, PANCHKULA

In the result, all the above appeals filed by the respective assessee’s are dismissed

7,81,320/- and claiming exemption of Rs. 1,05,10,592/- being interest received on enhanced compensation of compulsory acquisition of agricultural land. (Copy appended at page 16-18 of APB).  During AY 2012-13 i.e. FY 2011-12, agriculture land of the “A” was acquired under Land Acquisition Act, 1894 by the Land Acquisition Authority, Pkl. Later