SHRI DINESH SETHI,LUDHIANA vs. ITO, LUDHIANA

The appeals are dismissed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 376/Chd/2014 & "नधा"रण वष" / Assessment Year : 2006-07 Shri Janesh Sethi, Legal Heir Of बनाम The Ito, Late Shri Dinesh Sethi, Ward – 1(1), Vs Prop. M/S R.S. Trading Corp., Ludhiana. C-434, Urban Estate Focal Point, Ludhiana. "थायी लेखा सं./Pan /Tan No: Aaqpk1200Q अपीलाथ"/Appellant ""यथ"/Respondent "नधा"रती क" ओर से/Assessee By : Shri Sudhir Sehgal, Advocate राज"व क" ओर से/ Revenue By : Shri Manav Bansal, Cit Dr तार"ख/Date Of Hearing : 23.06.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 04.8.2025

271(1)(c) vide order dated 25.06.2009 against whom appeal has been dismissed by the CIT (Appeals) by way of the impugned order). 2. It has been brought to our notice that assessee Shri Dinesh Sethi has died on 14.02.2024. Death Certificate of the assessee has been annexed by the ld. counsel for the assessee. He has left behind

SUBHASH CHANDER GUPTA, H.NO. 16528 VISHNU COLONY, RALIWAY ROAD, KURUKSHETRA,HARYANA vs. JOINT COMMISSIONER OF INCOME TAX, KURUKSHETRA

In the result, both appeals of the assessee are

Bench: Shri Rajpal Yadav & Shri Krinwant Sahay

reassess total income of such other person of such assessment year in the manner provided in section 153-A." 10. A bare perusal of this Section would reveal that it starts with a non obstante clause “not withstanding anything contained in Section” meaning thereby this Section has an over-riding effect over other Sections namely

SUBHASH CHANDER GUPTA, H.NO. 1652 8 VISHNU COLONY, RAILWAY ROAD, KURUKSHETRA,HARYANA vs. ITO WARD-3, KURUKSHETRA, HARYANA

In the result, both appeals of the assessee are

Bench: Shri Rajpal Yadav & Shri Krinwant Sahay

reassess total income of such other person of such assessment year in the manner provided in section 153-A." 10. A bare perusal of this Section would reveal that it starts with a non obstante clause “not withstanding anything contained in Section” meaning thereby this Section has an over-riding effect over other Sections namely

M/S PNG TRADING PRIVATE LIMITED,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

In the result, all four appeals are allowed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwal

271(1)(c)]. 2. First we take ITA 238/CHD/2015 in assessment year 2005-06. The assessee has raised six grounds of appeal, out of which Ground Nos. 1, 4, 5 and 6 are general grounds which do not call for recording of any specific finding. The assessee has taken additional ground of appeal by way of a letter dated

M/S PNG TRADING PRIVATE LIMITED,CHANDIGARH vs. DCIT, CHANDIGARH

In the result, all four appeals are allowed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwal

271(1)(c)]. 2. First we take ITA 238/CHD/2015 in assessment year 2005-06. The assessee has raised six grounds of appeal, out of which Ground Nos. 1, 4, 5 and 6 are general grounds which do not call for recording of any specific finding. The assessee has taken additional ground of appeal by way of a letter dated

M/S PNG TRADING PRIVATE LIMITED,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

In the result, all four appeals are allowed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwal

271(1)(c)]. 2. First we take ITA 238/CHD/2015 in assessment year 2005-06. The assessee has raised six grounds of appeal, out of which Ground Nos. 1, 4, 5 and 6 are general grounds which do not call for recording of any specific finding. The assessee has taken additional ground of appeal by way of a letter dated

M/S PNG TRADING PRIVATE LIMITED,CHANDIGARH vs. DCIT, CHANDIGARH

In the result, all four appeals are allowed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwal

271(1)(c)]. 2. First we take ITA 238/CHD/2015 in assessment year 2005-06. The assessee has raised six grounds of appeal, out of which Ground Nos. 1, 4, 5 and 6 are general grounds which do not call for recording of any specific finding. The assessee has taken additional ground of appeal by way of a letter dated

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)

271(1)(c) of the Act for A.Y 2009-10. 2. All these cases are heard together and are being disposed off by this consolidated order. With the consent of both the parties, appeal in ITA No. 126/Asr/2019 for A.Y 2008-09 was taken as a lead case wherein the assessee has taken the following grounds of appeal: 1. “That

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)

271(1)(c) of the Act for A.Y 2009-10. 2. All these cases are heard together and are being disposed off by this consolidated order. With the consent of both the parties, appeal in ITA No. 126/Asr/2019 for A.Y 2008-09 was taken as a lead case wherein the assessee has taken the following grounds of appeal: 1. “That

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)

271(1)(c) of the Act for A.Y 2009-10. 2. All these cases are heard together and are being disposed off by this consolidated order. With the consent of both the parties, appeal in ITA No. 126/Asr/2019 for A.Y 2008-09 was taken as a lead case wherein the assessee has taken the following grounds of appeal: 1. “That

INCOME TAX OFFIER, WARD 6(1), LUDHIANA vs. BALPREET SINGH, LUDHIANA

In the result, the appeal of the Revenue is allowed for statistical purposes

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

reassessment proceedings, the jurisdictional Assessing Officer as well as the FAU issued several statutory notices under section 142(1) and a show-cause notice under section 144 through electronic mode as well as by speed post. However, the assessee remained completely non-compliant and failed to respond to any of the notices or furnish the requisite details and explanations regarding

SH. S.L. ARORA,MOHALI vs. DCIT, CHANDIGARH

In the result, the appeals of the assessee bearing

Bench: Shri Sanjay Garg & Shri Vikram Singh Yadav

271(1)(c) of the Act, levied pursuant to the aforesaid quantum additions. I.T.A. No.1325,1326,1421/CHANDI/2010 I.T.A. No.274,275/CHANDI/2014 Shri Rajiv Kumar Shri Sohan Lal Arora Assessment Year: 2006-07 2. So far as the appeal agitating the quantum additions are concerned, the assessees apart from contesting the additions on merits, have taken the following additional grounds in both

SH. RAJIV KUMAR,MOHALI vs. DCIT, CHANDIGARH

In the result, the appeals of the assessee bearing

Bench: Shri Sanjay Garg & Shri Vikram Singh Yadav

271(1)(c) of the Act, levied pursuant to the aforesaid quantum additions. I.T.A. No.1325,1326,1421/CHANDI/2010 I.T.A. No.274,275/CHANDI/2014 Shri Rajiv Kumar Shri Sohan Lal Arora Assessment Year: 2006-07 2. So far as the appeal agitating the quantum additions are concerned, the assessees apart from contesting the additions on merits, have taken the following additional grounds in both

DCIT, CHANDIGARH vs. SH. S.L. ARORA, MOHALI

In the result, the appeals of the assessee bearing

Bench: Shri Sanjay Garg & Shri Vikram Singh Yadav

271(1)(c) of the Act, levied pursuant to the aforesaid quantum additions. I.T.A. No.1325,1326,1421/CHANDI/2010 I.T.A. No.274,275/CHANDI/2014 Shri Rajiv Kumar Shri Sohan Lal Arora Assessment Year: 2006-07 2. So far as the appeal agitating the quantum additions are concerned, the assessees apart from contesting the additions on merits, have taken the following additional grounds in both

SH. RAJIV KUMAR,MOHALI vs. ACIT, CHANDIGARH

In the result, the appeals of the assessee bearing

Bench: Shri Sanjay Garg & Shri Vikram Singh Yadav

271(1)(c) of the Act, levied pursuant to the aforesaid quantum additions. I.T.A. No.1325,1326,1421/CHANDI/2010 I.T.A. No.274,275/CHANDI/2014 Shri Rajiv Kumar Shri Sohan Lal Arora Assessment Year: 2006-07 2. So far as the appeal agitating the quantum additions are concerned, the assessees apart from contesting the additions on merits, have taken the following additional grounds in both

SH.SOHAN LAL ARORA,MOHALI vs. ACIT, CHANDIGARH

In the result, the appeals of the assessee bearing

Bench: Shri Sanjay Garg & Shri Vikram Singh Yadav

271(1)(c) of the Act, levied pursuant to the aforesaid quantum additions. I.T.A. No.1325,1326,1421/CHANDI/2010 I.T.A. No.274,275/CHANDI/2014 Shri Rajiv Kumar Shri Sohan Lal Arora Assessment Year: 2006-07 2. So far as the appeal agitating the quantum additions are concerned, the assessees apart from contesting the additions on merits, have taken the following additional grounds in both

IPF VIKRAM INDIA PRIVATE LIMITED,CHANDIGARH vs. DY. COMMISSIONER OF INCOME TAX, CIRCLE, PANCHKULA, PANCHKULA

In the result, appeal of the Assessee is allowed for statistical purposes

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

1)(va). The total income was reassessed at Rs. 6,27,43,248/-, interest was charged under sections 234A, 234B, 234C, and 234D, and penalty proceedings under section 271

THE SHAHABAD COOP. SUGAR MILLS,SHAHABAD vs. ACIT, CIRCLE, KURUKSHETRA

Bench: Us In Terms Of Section 253 Of The Income Tax Act, 1961. 2. The Assessee Being Aggrieved By The Order Of Ld. Cit(A) Dt. 11/03/2018 Which Is Hereinafter Referred To As The Impugned Order, Before This Tribunal In Form No. 36 Has Interalia Raised The Following Grounds Of Appeal:

reassess under section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under section 154, for any assessment year beginning on or before the 1st day of April, 2001. Explanation. For the removal of doubts, it is hereby clarified that notwith- standing anything to the contrary contained