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)

37(1) of the Act. 26. Thus, expenditure is even otherwise allowable as business loss / expense in terms of section 28/37 of the Act. 27. Accordingly, the reassessment

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)

37. It was submitted that the liability to pay interest arises on the ground of failure to pay advance tax and in the instant case, it was submitted that the assessee had no occasion to pre-empt and make the estimate of income for payment of advance tax during F.Y. in respect of additional income pursuant to the advance comprising

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)

37 Days 2010 Apparels Pvt. Ltd. M/s Oswal Fab A.Y. 2010- 119/CHANDI/2025 (D) 40 Days 2011 Knits Limited A.Y. 2010- 120/CHANDI/2025 (D) 40 Days M/s Oswal 2011 trend (P) Limited M/s Apparels A.Y. 2010- 121/CHANDI/2025 (D) 61 Days 2011 Pvt. Ltd. M/s Oswal A.Y. 2010- 122/CHANDI/2025 (D) 61 Days 2011 Apparels Pvt. Ltd. 3. The Ld. DR for the Revenue

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2, LUDHIANA vs. AB ALCOBEV PRIVATE LIMITED, DELHI

In the result, appeals of Revenue are dismissed, Cross\nObjections of the assessee for

37 of the Indian\nIncome-tax Act, 1922 or under sub-section (1) of Section 131 of the\nIncome-tax Act, 1961, or a notice under sub-section (4) of Section\n22 of the Indian Income-tax Act, 1922 or under sub-section (1) of\nSection 142 of the Income-tax Act, 1961 is issued to Ajay Kumar\nBindal

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2, LUDHIANA , LUDHIANA vs. AB ALCOBEV PRIVATE LIMITED, DELHI

In the result, appeals of Revenue are dismissed, Cross\nObjections of the assessee for

37 of the Indian\nIncome-tax Act, 1922 or under sub-section (1) of Section 131 of the\nIncome-tax Act, 1961, or a notice under sub-section (4) of Section\n22 of the Indian Income-tax Act, 1922 or under sub-section (1) of\nSection 142 of the Income-tax Act, 1961 is issued to Ajay Kumar\nBindal

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2,, LUDHIANA vs. AB ALCOBEV PRIVATE LIMITED, DELHI

In the result, appeals of Revenue are dismissed, Cross\nObjections of the assessee for

37 of the Indian\nIncome-tax Act, 1922 or under sub-section (1) of Section 131 of the\nIncome-tax Act, 1961, or a notice under sub-section (4) of Section\n22 of the Indian Income-tax Act, 1922 or under sub-section (1) of\nSection 142 of the Income-tax Act, 1961 is issued to Ajay Kumar\nBindal

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2 LUDHIANA, LUDHIANA vs. AB ALCOBEV PRIVATE LIMITED , DELHI

In the result, appeals of Revenue are dismissed, Cross\nObjections of the assessee for

37 of the Indian\nIncome-tax Act, 1922 or under sub-section (1) of Section 131 of the\nIncome-tax Act, 1961, or a notice under sub-section (4) of Section\n22 of the Indian Income-tax Act, 1922 or under sub-section (1) of\nSection 142 of the Income-tax Act, 1961 is issued to Ajay Kumar\nBindal

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

37. On a conspectus of Section 153A(1) of the Act, read with the provisos thereto, and in the light of the law explained in the aforementioned decisions, the legal position that emerges is as under: i. Once a search takes place under Section 132 of the Act, notice under Section 153 A (1) will have to be mandatorily issued

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

37. On a conspectus of Section 153A(1) of the Act, read with the provisos thereto, and in the light of the law explained in the aforementioned decisions, the legal position that emerges is as under: i. Once a search takes place under Section 132 of the Act, notice under Section 153 A (1) will have to be mandatorily issued

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

37. On a conspectus of Section 153A(1) of the Act, read with the provisos thereto, and in the light of the law explained in the aforementioned decisions, the legal position that emerges is as under: i. Once a search takes place under Section 132 of the Act, notice under Section 153 A (1) will have to be mandatorily issued

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

37. On a conspectus of Section 153A(1) of the Act, read with the provisos thereto, and in the light of the law explained in the aforementioned decisions, the legal position that emerges is as under: i. Once a search takes place under Section 132 of the Act, notice under Section 153 A (1) will have to be mandatorily issued

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)

reassessment u/s 147 r.w.s 144B of the Act in according permission to re-verify and re-examine the matters in reference being the question of the proportion of deduction (viz. 25% versus 100%) u/s 80IC of the Act and the consequent assessability and chargeability to tax of any additional incomes in the hands of the assessee. This is because prior

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)

reassessment proceedings, the deposit of cash was found to be explained by the AO. At the same time, it was noticed by the AO that the assessee society had made security deposit of Rs. 21.49 lacs with a closely related family trust i.e; Lala Daswandi Ram Family Trust. The assessee society was thereafter called upon to explain

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)

reassessment proceedings, the deposit of cash was found to be explained by the AO. At the same time, it was noticed by the AO that the assessee society had made security deposit of Rs. 21.49 lacs with a closely related family trust i.e; Lala Daswandi Ram Family Trust. The assessee society was thereafter called upon to explain

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)

reassessment proceedings, the deposit of cash was found to be explained by the AO. At the same time, it was noticed by the AO that the assessee society had made security deposit of Rs. 21.49 lacs with a closely related family trust i.e; Lala Daswandi Ram Family Trust. The assessee society was thereafter called upon to explain

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, LUDHIANA , LUDHIANA vs. AVINASH SINGLA, KHANNA

In the result, all the appeals of the Revenue are dismissed

Bench: Shri Rajpal Yaday & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 814 & 815/Chd/2023 "नधा"रण वष" / Assessment Years :2013-14 & 2014-15 Dcit, Vs. Avinash Singla, Central Circle-1, बनाम C-47, C.O Avinash Ludhiana Industries, Focal Point, Khanna "थायी लेखा सं./Pan No. Acypk9591N अपीलाथ"/Appellant ""यथ"/Respondent & आयकर अपील सं./ Ita No. 15/Chd/2024 "नधा"रण वष" / Assessment Year : 2014-15 Dcit, Vs. Meenu Singla, बनाम Central Circle-1, C-47, C.O Avinash Ludhiana Industries, Focal Point, Khanna "थायी लेखा सं./Pan No.Afips6556G अपीलाथ"/Appellant ""यथ"/Respondent

37. On a conspectus of Section 153A(1) of the Act, read with the provisos thereto, and in the light of the law explained in the aforementioned decisions, the legal position that emerges is as under: i. Once a search takes place under Section 132 of the Act, notice under Section 153 A (1) will have to be mandatorily issued

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)

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