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

ASHISH SOOD,ZIRAKPUR vs. THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), CHANDIGARH, CHANDIGARH

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

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

67 and its accompaniments were on record even then no verification of its material particulars were done so, he too infact ignored it completely on the ground that taxes are paid in an alien nation, the particulars of which can never be verified by the Income tax Authorities and on other untenable grounds as recorded. These facts herein are very

ROSHA ALLOYS P LIMITED, AMLOH ROAD, VILLAGE TURAN, MANDI GOBINDGARH,PUNJAB vs. DCIT CENTRAL CIRCLE 1, LUDHIANA, PUNJAB

In the result, the appeals filed by the Revenue are dismissed,\nwhereas the appeals of the assessee are allowed

67 ITR 11 (SC)]. Therefore, section 148 would point out to\nconcrete information which could be facts which point out to a case\nof income having escaped assessment. [Para D(b)]\nOn a conjoint reading of section 147 and section 148, it is clear\nthat the escapement of income is a sine qua non for initiating\nproceedings under section

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, LUDHIANA , LUDHIANA vs. ROSHA ALLOYS PVT. LTD., MANDI GOBINDGARH

In the result, the appeals filed by the Revenue are dismissed,\nwhereas the appeals of the assessee are allowed

67 ITR 11 (SC)]. Therefore, section 148 would point out to\nconcrete information which could be facts which point out to a case\nof income having escaped assessment. [Para D(b)]\nOn a conjoint reading of section 147 and section 148, it is clear\nthat the escapement of income is a sine qua non for initiating\nproceedings under section

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, LUDHIANA , LUDHIANA vs. ROSHA ALLOYS PVT. LTD., MANDI GOBINDGARH

In the result, the appeals filed by the Revenue are dismissed,\nwhereas the appeals of the assessee are allowed

67 ITR 11 (SC)]. Therefore, section 148 would point out to\nconcrete information which could be facts which point out to a case\nof income having escaped assessment. [Para D(b)]\nOn a conjoint reading of section 147 and section 148, it is clear\nthat the escapement of income is a sine qua non for initiating\nproceedings under section

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, LUDHIANA , LUDHIANA vs. ROSHA ALLOYS PVT. LTD., MANDI GOBINDGARH

In the result, the appeals filed by the Revenue are dismissed,\nwhereas the appeals of the assessee are allowed

67 ITR 11 (SC)]. Therefore, section 148 would point out to\nconcrete information which could be facts which point out to a case\nof income having escaped assessment. [Para D(b)]\nOn a conjoint reading of section 147 and section 148, it is clear\nthat the escapement of income is a sine qua non for initiating\nproceedings under section

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)

67,637 New Service Foreign travelling The Hon'ble Tribunal agreement dated expenditure disallowed remanded the issue May 12, 2007 alleging that the back to the DRP to with Fidelity Respondent is pass a speaking Information not required to incur order after Services Inc., foreign travelling considering all the USA and dated expenses and that the evidences / November 1, Respondent

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

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)

reassessment was procedurally sound and legally valid. 37. In this regard, the Ld. Counsel for the Assessee has relied upon the written submissions filed before the Ld. CIT(A), appearing at pages 1-28of the assessee'spaper book, which are already on record. For the sake of brevity and as the same is part of the record

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)

reassessment was procedurally sound and legally valid. 37. In this regard, the Ld. Counsel for the Assessee has relied upon the written submissions filed before the Ld. CIT(A), appearing at pages 1-28of the assessee'spaper book, which are already on record. For the sake of brevity and as the same is part of the record

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)

reassessment was procedurally sound and legally valid. 37. In this regard, the Ld. Counsel for the Assessee has relied upon the written submissions filed before the Ld. CIT(A), appearing at pages 1-28of the assessee'spaper book, which are already on record. For the sake of brevity and as the same is part of the record

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)

reassessment was procedurally sound and legally valid. 37. In this regard, the Ld. Counsel for the Assessee has relied upon the written submissions filed before the Ld. CIT(A), appearing at pages 1-28of the assessee'spaper book, which are already on record. For the sake of brevity and as the same is part of the record

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)

reassessment was procedurally sound and legally valid. 37. In this regard, the Ld. Counsel for the Assessee has relied upon the written submissions filed before the Ld. CIT(A), appearing at pages 1-28of the assessee'spaper book, which are already on record. For the sake of brevity and as the same is part of the record

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)

reassessment was procedurally sound and legally valid. 37. In this regard, the Ld. Counsel for the Assessee has relied upon the written submissions filed before the Ld. CIT(A), appearing at pages 1-28of the assessee'spaper book, which are already on record. For the sake of brevity and as the same is part of the record

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)

reassessment was procedurally sound and legally valid. 37. In this regard, the Ld. Counsel for the Assessee has relied upon the written submissions filed before the Ld. CIT(A), appearing at pages 1-28of the assessee'spaper book, which are already on record. For the sake of brevity and as the same is part of the record

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)

reassessment was procedurally sound and legally valid. 37. In this regard, the Ld. Counsel for the Assessee has relied upon the written submissions filed before the Ld. CIT(A), appearing at pages 1-28of the assessee'spaper book, which are already on record. For the sake of brevity and as the same is part of the record

PUKHRAJ SINGH GUJRAL,CHANDIGARH vs. CPC, BENGALURU

In the result, the appeal of the assessee is allowed

Bench: Final Hearing

67 is a directory requirement, not mandatory, and a procedural lapse does not extinguish the substantive right to FTC, especially when the form was filed on 27.08.2022, well before the processing of the return on 26.10.2022. The amendment to Rule 128(9) effective from 01.04.2022, allowing filing until the end of the assessment year, further indicates a legislative intent