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)

256/- New Service DRP allowed the claim of The Hon’ble agreement dated foreign travelling Chandigarh Bench of May 12, 2007 with expenditure in favour of the Tribunal vide order Fidelity the Respondent by dated May 30, 2019 Information directing the AO to allow directed to delete Services Inc. USA the claim after verifying disallowance of and dated whether foreign

DY. COMMISSIONER OF INCOME TAX, CIRCLE-4, AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

256 1,023,622 5,793,878 TOTAL 2,77,90,068 11373255 39,163,323 Misc. Expenses Ludhiana (37%) Haridwar (63%) Consolidated Legal, Prof & 5048D37 8595305 13643342 Consultation Charges Gen Admin Exp 3671861 6252087 9923948 Gen Exp Others 1797157 3060025 4857182 Domestic Traveling & 1829640 3115333 4944973 Convey-other Foreign Traveling exp-others 2143735 3650143 5793878 TOTAL 1

DY. COMMISSIONER OF INCOME TAX, CIRCLE-4, LUDHIANA, AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

256 1,023,622 5,793,878 TOTAL 2,77,90,068 11373255 39,163,323 Misc. Expenses Ludhiana (37%) Haridwar (63%) Consolidated Legal, Prof & 5048D37 8595305 13643342 Consultation Charges Gen Admin Exp 3671861 6252087 9923948 Gen Exp Others 1797157 3060025 4857182 Domestic Traveling & 1829640 3115333 4944973 Convey-other Foreign Traveling exp-others 2143735 3650143 5793878 TOTAL 1

DY. COMMISSIONER OF INCOME TAX, CIRCLE-4, , AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

256 1,023,622 5,793,878 TOTAL 2,77,90,068 11373255 39,163,323 Misc. Expenses Ludhiana (37%) Haridwar (63%) Consolidated Legal, Prof & 5048D37 8595305 13643342 Consultation Charges Gen Admin Exp 3671861 6252087 9923948 Gen Exp Others 1797157 3060025 4857182 Domestic Traveling & 1829640 3115333 4944973 Convey-other Foreign Traveling exp-others 2143735 3650143 5793878 TOTAL 1

DCIT CIRCLE-4, LUDHIANA, LUDHIANA vs. ROCKMAN INDUSTRIES LTD, LUDHIANA

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

256 1,023,622 5,793,878 TOTAL 2,77,90,068 11373255 39,163,323 Misc. Expenses Ludhiana (37%) Haridwar (63%) Consolidated Legal, Prof & 5048D37 8595305 13643342 Consultation Charges Gen Admin Exp 3671861 6252087 9923948 Gen Exp Others 1797157 3060025 4857182 Domestic Traveling & 1829640 3115333 4944973 Convey-other Foreign Traveling exp-others 2143735 3650143 5793878 TOTAL 1

DY. COMMISSIONER OF INCOME TAX, CIRCLE-4,, AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

256 1,023,622 5,793,878 TOTAL 2,77,90,068 11373255 39,163,323 Misc. Expenses Ludhiana (37%) Haridwar (63%) Consolidated Legal, Prof & 5048D37 8595305 13643342 Consultation Charges Gen Admin Exp 3671861 6252087 9923948 Gen Exp Others 1797157 3060025 4857182 Domestic Traveling & 1829640 3115333 4944973 Convey-other Foreign Traveling exp-others 2143735 3650143 5793878 TOTAL 1

DY. COMMISSIONER OF INCOME TAX, CIRCLE-4, LUDHIANA, - vs. ROCKMAN INDUSTRIES LTD, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

256 1,023,622 5,793,878 TOTAL 2,77,90,068 11373255 39,163,323 Misc. Expenses Ludhiana (37%) Haridwar (63%) Consolidated Legal, Prof & 5048D37 8595305 13643342 Consultation Charges Gen Admin Exp 3671861 6252087 9923948 Gen Exp Others 1797157 3060025 4857182 Domestic Traveling & 1829640 3115333 4944973 Convey-other Foreign Traveling exp-others 2143735 3650143 5793878 TOTAL 1

ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-4, AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

256 1,023,622 5,793,878 TOTAL 2,77,90,068 11373255 39,163,323 Misc. Expenses Ludhiana (37%) Haridwar (63%) Consolidated Legal, Prof & 5048D37 8595305 13643342 Consultation Charges Gen Admin Exp 3671861 6252087 9923948 Gen Exp Others 1797157 3060025 4857182 Domestic Traveling & 1829640 3115333 4944973 Convey-other Foreign Traveling exp-others 2143735 3650143 5793878 TOTAL 1

DY. COMMISSIONER OF INCOME TAX, AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, FOCAL POINT

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

256 1,023,622 5,793,878 TOTAL 2,77,90,068 11373255 39,163,323 Misc. Expenses Ludhiana (37%) Haridwar (63%) Consolidated Legal, Prof & 5048D37 8595305 13643342 Consultation Charges Gen Admin Exp 3671861 6252087 9923948 Gen Exp Others 1797157 3060025 4857182 Domestic Traveling & 1829640 3115333 4944973 Convey-other Foreign Traveling exp-others 2143735 3650143 5793878 TOTAL 1

HARYANA BUILDING AND OTHER CONSTRUCTION WORKERS WELFARE BOARD,PANCHKULA vs. DCIT, EXEMPTION, SECTOR 17

In the result, this appeal of the Assessee stands dismissed

1) dated\n13.10.2022, had furnished the nature of activities, sources of\nincome, copy of Rules of the assessee board, Copy of order of\nregistration under section 12AA, computation of income, audit\nreport containing Balance sheet, Income and expenditure\naccount, and receipts and payments account. The details\nfurnished by the assessee are perused.\nThe assessee's response has been examined

HARYANA BUILDING AND OTHER CONSTRUCTION WORKERS WELFARE BOARD,PANCHKULA vs. DCIT, EXEMPTION, CHANDIGARH

In the result, this appeal of the Assessee stands dismissed

1) dated\n13.10.2022, had furnished the nature of activities, sources of\nincome, copy of Rules of the assessee board, Copy of order of\nregistration under section 12AA, computation of income, audit\nreport containing Balance sheet, Income and expenditure\naccount, and receipts and payments account. The details\nfurnished by the assessee are perused.\nThe assessee's response has been examined

HARYANA BUILDING AND OTHER CONSTRUCTION WORKERS WELFARE BOARD,PANCHKULA vs. CIT(EXEMPTION), CHANDIGARH

In the result, this appeal of the Assessee stands dismissed

1) dated\n13.10.2022, had furnished the nature of activities, sources of\nincome, copy of Rules of the assessee board, Copy of order of\nregistration under section 12AA, computation of income, audit\nreport containing Balance sheet, Income and expenditure\naccount, and receipts and payments account. The details\nfurnished by the assessee are perused.\n\nThe assessee's response has been examined

THE DCIT, CIRCLE (INTERNATIONAL TAXATION), CHANDIGARH vs. SH. MANJEET SINGH, LUDHIANA

In the result, Revenue’s appeal is dismissed whereas, Cross

Bench: Shri A.D. Jain & Dr Krinwant Sahayआयकर अपील सं./ Ita No. 512/Chd/2022 "नधा"रण वष" / Assessment Year : 2012-13 The Dcit, Vs. Shri Manjeet Singh, बनाम Circle (International S/O Shri Harbir Singh Taxation), # 1460, Ward Number-8, Chandigarh Gahlewal, Ludhiana 141008 "थायी लेखा सं./Pan No: Cdeps4087A अपीलाथ"/ Appellant ""यथ"/ Repsondent & C.O. No. 13/Chd/2022 ( In आयकर अपील सं./ Ita No. 512/Chd/2022) "नधा"रण वष" / Assessment Year : 2012-13 Shri Manjeet Singh, Vs. The Dcit, बनाम S/O Shri Harbir Singh Circle (International # 1460, Ward Number-8, Taxation ), Gahlewal, Chandigarh Ludhiana 141008 "थायी लेखा सं./Pan No: Cdeps4087A अपीलाथ"/ Appellant ""यथ"/ Repsondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : Shri Sudhir Sehgal, Advocate राज"व क" ओर से/ Revenue By : Shri Dharamvir, Jcit, Sr. Dr सुनवाई क" तार"ख/Date Of Hearing : 04.09.2024 उदघोषणा क" तार"ख/Date Of Pronouncement : 15.10.2024

256 Taxman 59(SC) is also applicable since in this case order was already passed against the objections filed by the assessee. 2. Whether on the facts and circumstances of the case, Ld. CIT(A) has erred in law and facts by considering the approval given by the Pr. CIT was in a mechanical manner inspite of the facts that

HARYANA BUILDING AND OTHER CONSTRUCTION WORKERS WELFARE BOARD,PANCHKULA vs. DCIT, EXEMPTION, CHANDIGARH

In the result, this appeal of the Assessee stands dismissed

1) dated\n13.10.2022, had furnished the nature of activities, sources of\nincome, copy of Rules of the assessee board, Copy of order of\nregistration under section 12AA, computation of income, audit\nreport containing Balance sheet, Income and expenditure\naccount, and receipts and payments account. The details\nfurnished by the assessee are perused.\n\nThe assessee's response has been examined

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)

reassessment proceedings. SLP in Hon’ble Supreme Court of India on said matter was dismissed as reported at (2017) 84 Taxmann.com 300. The Ld. CIT(A) then has relied upon the following judgments of High Courts (i) Pushpa Uttam Chand Mehta Vs. ITO (2022) 139 taxmann.com 409 (Gujarat) (ii) Ankit Agrochem(P) Ltd. Vs. JCIT, Range-1, Bikaner

BANSAL RICE TRADERS,SANGRUR vs. ITO-WARD, SANGRUR

In the result, appeal of the assessee is allowed

256 ITR 360 (Guj) 5.2 The Ld. CIT asked the comment of the A.O. on the above submissions of the assessee. In response the A.O. submitted the report which reads as under: "Sub :- Comments and additional evidence under Rule 46A in the case of M/s Bansal Rice Traders, Balial Road, Bhawanigarh, Sangrur for the assessment year 2010-11-regarding Kindly

M/S BCL INDUSTRIES LTD.,BATHINDA vs. DCIT, CC-I, LUDHIANA

In the result, both appeals of the assessee are

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

reassessment was not valid and was liable to be quashed." 8.4 Likewise, in ‘Baba Kartar Singh Dukki Educational Trust’ (supra), it has been held as follows : HEAD NOTE: " Where Assessing Officer processed under section 143(1) returns of income filed by assessee for assessment years 2001-02 to 2003-04 and subsequently he reopened said assessments on sole basis that

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

In the result, both appeals of the assessee are

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

reassessment was not valid and was liable to be quashed." 8.4 Likewise, in ‘Baba Kartar Singh Dukki Educational Trust’ (supra), it has been held as follows : HEAD NOTE: " Where Assessing Officer processed under section 143(1) returns of income filed by assessee for assessment years 2001-02 to 2003-04 and subsequently he reopened said assessments on sole basis that

ETHIX HEALTHCARE,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE , PARWANOO

In the result, both on the exercise of jurisdiction u/s 147 and on merits of the case, the order of the AO as well as the ld CIT(A) is hereby set-aside and matter is decided in favour of the assessee

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

reassessment has been initiated were already available on record and considered at length by AO while framing the original assessment under section 143(3) of the Act. It was submitted that it is clearly a case of change of opinion which is not permissible for invocation of jurisdiction under section 147 of the Act and in support reliance was placed