SH. ASHISH JAIN,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the ground no

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

47 shares of M/s Access Global Limited against 1 share of M/s Maple Goods (P) Ltd. and copy of the order of the Hon’ble Court approving the scheme of amalgamation was also placed on record. 5.3 It was further submitted that the shares of M/s Access Global Limited were traded on Calcutta Stock Exchange and the assessee sold part

SH. BIPAN JAIN,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the ground no

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

47 shares of M/s Access Global Limited against 1 share of M/s Maple Goods (P) Ltd. and copy of the order of the Hon’ble Court approving the scheme of amalgamation was also placed on record. 5.3 It was further submitted that the shares of M/s Access Global Limited were traded on Calcutta Stock Exchange and the assessee sold part

SH. ASHISH JAIN,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the ground no

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

47 shares of M/s Access Global Limited against 1 share of M/s Maple Goods (P) Ltd. and copy of the order of the Hon’ble Court approving the scheme of amalgamation was also placed on record. 5.3 It was further submitted that the shares of M/s Access Global Limited were traded on Calcutta Stock Exchange and the assessee sold part

WINSOME TEXTILE INDUSTRIES LIMITED,CHANDIGARH vs. ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-4(1), CHANDIGARH, CHANDIGARH

In the result, the appeal of the assessee is partly allowed and the appeal of the Revenue is dismissed

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

Section 147 is attracted. The reasons to believe ought to also paraphrase any investigation report which may form the basis of the reasons and any enquiry conducted by the AO on the same and if so, the conclusions thereof; (iii) where the reasons make a reference to another document, whether as a letter or report, such document and/ or relevant

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)

reassessment made thereon u/s 147 of the I.T. Act is bad in law and the appellant's appeal is allowed on this ground. 46. We hold that the Revenue has no jurisdiction in law under section 147/148 to reopen the closed assessment proceedings which happened on 30.11.2017 under section 143(3) of the Act when Ld. AO passed the assessment

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, LUDHIANA, LUDHIANA vs. M/S JAMNA DASS NIKKAMAL JAIN SARAF PVT. LTD., LUDHIANA

In the result, the appeal filed by Revenue is dismissed and the appeal filed by the Assessee is allowed

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

reassessment not only. procedurally defective but also without jurisdiction. 33. Even we find while framing the assessment under section 143(3), the Assessing Officer (AO) has, on the last page of the assessment order, referred to an approval obtained from the supervisory authority. However, a bare perusal of this approval shows that it was obtained in reference

JAMNA DASS NIKKAMAL JAIN SARAF PRIVATE LIMITED, LUDHIANA,LUDHIANA vs. THE DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 1, LUDHIANA, LUDHIANA

In the result, the appeal filed by Revenue is dismissed and the appeal filed by the Assessee is allowed

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

reassessment not only. procedurally defective but also without jurisdiction. 33. Even we find while framing the assessment under section 143(3), the Assessing Officer (AO) has, on the last page of the assessment order, referred to an approval obtained from the supervisory authority. However, a bare perusal of this approval shows that it was obtained in reference

S.P. SINGLA CONSTRUCTION PRIVATE LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CHANDIGARH

In the result, the appeal is allowed

Bench: SHRI MAHAVIR SINGH (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

reassessment shall be issued by the Assessing Officer for the relevant assessment year or years unless- (a) the assessing officer has in his possession books of account or other documents or evidence which reveal that the income, represented in the form of asset, which has escaped assessment amounts to or is likely to amount fifty lakh rupees or more

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)

reassessment or recomputation exceeds the tax on the total income determined under sub-section (1) of section 143 or on the basis of the regular assessment as referred to in sub-section(1), as the case may be.” 45. Further, useful reference can be drawn to the provisions of Sub-Section (4) which talks about the situation where subsequent

HOMELIFE BUILDCON PRIVATE LIMITED,SUNVIEW ENCLAVE, AYALI KALAN, LUDHIANA,PUNJAB vs. SMT. SAMANDEEP KAUR DCIT-CENTRAL CIRCLE-1, LUDHIANA, PUNJAB

In the result, Revenue appeal is dismissed and appeal filed by the assessee is allowed

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 880/Chd/2024 निर्धारण वर्ष / Assessment Year : 2021-22 Homelife Buildcon Private Limited Sunview Enclave, Ayali Kalan, Ludhiana, Punjab-142027 स्थायी लेखा सं./PAN NO: AABCH5690M अपीलार्थी/Appellant बनाम The DCIT Central Circle-1 Ludhiana, Punjab प्रत्यर्थी/Respondent आयकर अपील सं. / ITA No. 1036/Chd/2024 निर्धारण वर्ष / Assessment Year : 2021-22 बनाम Homelife Buildcon Private Limited Sunview Enclave, Ayali

reassessment not only. procedurally defective but also without jurisdiction. 33. Even we find while framing the assessment under section 143(3), the Assessing Officer (AO) has, on the last page of the assessment order, referred to an approval obtained from the supervisory authority. However, a bare perusal of this approval 25 shows that it was obtained in reference

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, LUDHIANA , LUDHIANA vs. HOMELIFE BUILDCON PVT. LTD., LUDHIANA

In the result, Revenue appeal is dismissed and appeal filed by the assessee is allowed

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 880/Chd/2024 निर्धारण वर्ष / Assessment Year : 2021-22 Homelife Buildcon Private Limited Sunview Enclave, Ayali Kalan, Ludhiana, Punjab-142027 स्थायी लेखा सं./PAN NO: AABCH5690M अपीलार्थी/Appellant The DCIT Central Circle-1 Ludhiana, Punjab प्रत्यर्थी/Respondent आयकर अपील सं. / ITA No. 1036/Chd/2024 निर्धारण वर्ष / Assessment Year : 2021-22 Homelife Buildcon Private Limited Sunview Enclave, Ayali Kalan, Lu

reassessment not only. procedurally defective but also without jurisdiction. 33. Even we find while framing the assessment under section 143(3), the Assessing Officer (AO) has, on the last page of the assessment order, referred to an approval obtained from the supervisory authority. However, a bare perusal of this approval 25 shows that it was obtained in reference

DHARAMPAL SAGHERA,CHANDIGARH vs. INCOME TAX OFFICER, WARD-1(4), CHANDIGARH , CHANDIGARH

In the result, the appeal of the assessee bearing ITA No

Bench: Sh. Laliet Kumar Hon’Ble & Sh. Manoj Kumar Aggarwal, Hon’Ble

reassessment, the AO held that since the assessee lacked legal ownership, the amount could not be treated as consideration for the transfer of a capital asset. The AO treated it the same as a gift under Section 56(2) and assessed it as “income from other sources”. 5. In appeal, the Ld. CIT(A) upheld the AO's action, observing

THE HARYANA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT,PANCHKULA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE, PANCHKULA

Appeal is allowed

Bench: SHRI. RAJPALYADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

47,178/- deduction under section 80P(2)(a)(i) for interest income from nationalized bank deposits, deeming it "income from other sources" as the banks are not cooperative society members. The Ld. CIT(A) upheld the finding of the AO on this ground. The assessee argued the interest from funds in regular accounts, is tied to the society’s operations

ASSISTANT COMMISSIONER OF INCOME TAX, PANCHKULA CIRCLE, PANCHKULA, PANCHKULA vs. THE HARYANA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT, PANCHKULA

Appeal is allowed

Bench: SHRI. RAJPALYADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

47,178/- deduction under section 80P(2)(a)(i) for interest income from nationalized bank deposits, deeming it "income from other sources" as the banks are not cooperative society members. The Ld. CIT(A) upheld the finding of the AO on this ground. The assessee argued the interest from funds in regular accounts, is tied to the society’s operations

ASSISTANT COMMISSIONER OF INCOME TAX, PANCHKULA CIRCLE, PANCHKULA, PANCHKULA vs. THE HARYANA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT, PANCHKULA

Appeal is allowed

Bench: BEFORE: SHRI. RAJPALYADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

47,178/- deduction under section 80P(2)(a)(i) for interest income from nationalized bank deposits, deeming it "income from other sources" as the banks are not cooperative society members. The Ld. CIT(A) upheld the finding of the AO on this ground. The assessee argued the interest from funds in regular accounts, is tied to the society’s operations

THE HARYANA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT,PANCHKULA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE,, PANCHKULA

Appeal is allowed

Bench: BEFORE: SHRI. RAJPALYADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

47,178/- deduction under section 80P(2)(a)(i) for interest income from nationalized bank deposits, deeming it "income from other sources" as the banks are not cooperative society members. The Ld. CIT(A) upheld the finding of the AO on this ground. The assessee argued the interest from funds in regular accounts, is tied to the society’s operations

ASSISTANT COMMISSIONER OF INCOME TAX, PANCHKULA CIRCLE, PANCHKULA, PANCHKULA vs. THE HARYANA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT, PANCHKULA

Appeal is allowed

Bench: SHRI. RAJPALYADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

47,178/- deduction under section 80P(2)(a)(i) for interest income from nationalized bank deposits, deeming it "income from other sources" as the banks are not cooperative society members. The Ld. CIT(A) upheld the finding of the AO on this ground. The assessee argued the interest from funds in regular accounts, is tied to the society’s operations

THE HARYANA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT,PANCHKULA vs. DCIT,CIRCLE, PANCHKULA, PANCHKULA

Appeal is allowed

Bench: BEFORE: SHRI. RAJPALYADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

47,178/- deduction under section 80P(2)(a)(i) for interest income from nationalized bank deposits, deeming it "income from other sources" as the banks are not cooperative society members. The Ld. CIT(A) upheld the finding of the AO on this ground. The assessee argued the interest from funds in regular accounts, is tied to the society’s operations