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)

69A r.w.s.115BBE of the Income Tax Act, 1961. 3. That the Ld. CIT(A) has erred in dismissing the ground of appeal with regard to addition of Rs. 7,54,923/- as per para 5.4, page 27 of the order and has also erred in confirming the application of provisions of section 115BBE of the Income

INCOME TAX OFFICE, LUDHIANA vs. SRI GURU HARGOBIND EDUCATIONAL SOCIETY, LUDHIANA

In the result, appeal of the Revenue is dismissed

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

69A, under Section 270A for under-reporting of income, and under Section 272A(1)(d) for non-compliance with statutory notices. 4. Against the order of the AO the assessee went in appeal before the Ld. CIT(A). The learned CIT(A) examined the appeal filed against the reassessment

ARUN KUMAR,LUDHIANA vs. ITO WARD 6(1), LUDHIANA

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

69A of The Act on account of unexplained credit entries in the Bank A/C statements of the Assessee. 3. That the worthy Commissioner of Income Tax (Appeals) has erred in not considering the Plathora of documents and explanations filed by the Assessee during the course of Assessment and appellate proceedings. 2 4. That the worthy Commissioner of Income Tax (Appeals

INCOME TAX OFFICER WARD-5 YAMUNA NAGAR, YAMUNA NAGAR vs. SHIVALIK FILLING STATION, KHIZRABAD

In the result, appeal of the Assessee is dismissed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. MANOJ KUMAR AGGARWAL (Accountant Member)

reassessment was completed under section 147 r.w.s. 144, making the following additions: Rs. 60,435/- (being 8% of contract receipts of Rs.7,55,432/-) Rs.7,58,89,580/- as unexplained cash deposits under section 69A

ISHAN MARWAH,AMBALA CITY, HARYANA vs. INCOME TAX OFFICER, WARD-1, AMBALA, AMBALA HARYANA

In the result, the appeal of the assessee is allowed for statistical purposes and the matter is restored to the file of the Assessing Officer for fresh adjudication in the light of the above observ...

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. MANOJ KUMAR AGGARWAL (Accountant Member)

reassessment Notice u/s 148, and the consequential assessment order, which has been passed in violation of the statutory provisions of section 148, 149, 150, 151 of the Act and against the mandate of reopening, in the facts and the circumstances of the case. 6. That the appellant craves leave to add or amend the grounds of appeal before the appeal

VINEET KUMAR,DHARAMSHALA vs. INCOME TAX OFFICER, DHARMSHALA

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

Bench: SHRI. LALIET KUMAR (Judicial Member)

reassessment proceedings, invocation of section 144, violation of principles of natural justice, and also the addition made under section 69A

M/S CREDO ASSETS PVT. LTD.,RUPNAGAR PUNJAB vs. DCIT/ACIT(CEN)-1 CHD, CHANDIGARH

The appeals stand partly allowed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No.487/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2013-14) M/S Singla Builders & Promoters Ltd. Dcit / Acit Central-1 बनाम/ Plot No 1265, Sector 82, Industrial Area C.R. Building, Sector 17 Vs. Rupnagar (Punjab) 140308 Chandigarh-160017 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaocs-6503-M (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकर अपील सं. / Ita No.482/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2017-18) & 3. आयकर अपील सं. / Ita No.484/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2018-19) M/S Credo Assets Private Ltd. Dcit / Acit Central-1 बनाम/ Plot No 1265-C, Sector 82, Industrial Area C.R. Building, Sector 17 Vs. Rupnagar (Punjab) 140308 Chandigarh-160017 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aafcc-6400-L (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Parikshit Aggarwal (Ca) & Smt. Shruti Khandelwal (Ca) – Ld. Ars ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) & Shri Rajat Kumar Kureel (Cit) – Ld. Drs (Virtual) Date Of Final Hearing : 27-01-2026 Date Of Pronouncement : 03-02-2026

sections for completion of assessment or reassessment. These amendments were to take effect from 01-10-2014. It was thus stated that the legislature specifically laid out emphasis on the limitation period to file report by the DVO. In the present case, the report was never served upon the assessee by DVO and secondly, the report was furnished

M/S SINGLA BUILDERS AND PROMOTERS LIMITED,RUPNAGAR, PUNJAB vs. DCIT/ACIT(CEN)-1 CHD, CHANDIGARH

The appeals stand partly allowed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No.487/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2013-14) M/S Singla Builders & Promoters Ltd. Dcit / Acit Central-1 बनाम/ Plot No 1265, Sector 82, Industrial Area C.R. Building, Sector 17 Vs. Rupnagar (Punjab) 140308 Chandigarh-160017 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaocs-6503-M (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकर अपील सं. / Ita No.482/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2017-18) & 3. आयकर अपील सं. / Ita No.484/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2018-19) M/S Credo Assets Private Ltd. Dcit / Acit Central-1 बनाम/ Plot No 1265-C, Sector 82, Industrial Area C.R. Building, Sector 17 Vs. Rupnagar (Punjab) 140308 Chandigarh-160017 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aafcc-6400-L (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Parikshit Aggarwal (Ca) & Smt. Shruti Khandelwal (Ca) – Ld. Ars ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) & Shri Rajat Kumar Kureel (Cit) – Ld. Drs (Virtual) Date Of Final Hearing : 27-01-2026 Date Of Pronouncement : 03-02-2026

sections for completion of assessment or reassessment. These amendments were to take effect from 01-10-2014. It was thus stated that the legislature specifically laid out emphasis on the limitation period to file report by the DVO. In the present case, the report was never served upon the assessee by DVO and secondly, the report was furnished

M/S CREDO ASSETS PVT. LTD.,RUPNAGAR PUNJAB vs. DCIT/ACIT(CEN)-1 CHD, CHANDIGARH

The appeals stand partly allowed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No.487/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2013-14) M/S Singla Builders & Promoters Ltd. Dcit / Acit Central-1 बनाम/ Plot No 1265, Sector 82, Industrial Area C.R. Building, Sector 17 Vs. Rupnagar (Punjab) 140308 Chandigarh-160017 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaocs-6503-M (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकर अपील सं. / Ita No.482/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2017-18) & 3. आयकर अपील सं. / Ita No.484/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2018-19) M/S Credo Assets Private Ltd. Dcit / Acit Central-1 बनाम/ Plot No 1265-C, Sector 82, Industrial Area C.R. Building, Sector 17 Vs. Rupnagar (Punjab) 140308 Chandigarh-160017 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aafcc-6400-L (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Parikshit Aggarwal (Ca) & Smt. Shruti Khandelwal (Ca) – Ld. Ars ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) & Shri Rajat Kumar Kureel (Cit) – Ld. Drs (Virtual) Date Of Final Hearing : 27-01-2026 Date Of Pronouncement : 03-02-2026

sections for completion of assessment or reassessment. These amendments were to take effect from 01-10-2014. It was thus stated that the legislature specifically laid out emphasis on the limitation period to file report by the DVO. In the present case, the report was never served upon the assessee by DVO and secondly, the report was furnished

HARISH SHARMA PROPRIETOR,LUDHIANA vs. INCOME TAX OFFICER WARD 1(5), LUDHIANA, LUDHIANA

In the result, we find that there is no justifiable basis to invoke the deeming fiction to hold the bank deposits as unexplained

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

69A of the Act which on appeal has been confirmed by the Ld. CIT(A) and against the said findings, the assessee is in appeal before us. 4. In Ground No. 1 and 2, the assessee has challenged the assumption of jurisdiction by the AO under section 147 of the Act. In this regard, it was submitted that the reasons

HARISH SHARMA PROP.,LUDHIANA vs. THE INCOME TAX OFFICER WARD 1(5), LUDHIANA, LUDHIANA

In the result, we find that there is no justifiable basis to invoke the deeming fiction to hold the bank deposits as unexplained

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

69A of the Act which on appeal has been confirmed by the Ld. CIT(A) and against the said findings, the assessee is in appeal before us. 4. In Ground No. 1 and 2, the assessee has challenged the assumption of jurisdiction by the AO under section 147 of the Act. In this regard, it was submitted that the reasons

VIMAL ALLOYS PRIVATE LIMITED, MANDI GOBINDGARH,PUNJAB vs. JAO THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE, PATIALA, PUNJAB

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

section 69A of the Act. 4. Against the order of the AO the assessee went in appeal before the Ld.CIT(A). 5. The Ld. CIT(A) upheld the addition by observing that the excel sheet constituted incriminating material found during search, that the assessee failed to rebut the same, and that the reopening was validly initiated on the basis

BHUSHAN KUMAR,KHANAURI vs. INCOME TAX OFFICER, SUNAM, SANGRUR

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

reassessment.", "held": "The Tribunal held that the CIT(A) should have decided the appeal on merits even if the assessee did not comply with the notices, rather than dismissing it for non-prosecution. The CIT(A) had confirmed the Assessing Officer's order without independent adjudication.", "result": "Allowed", "sections": ["147", "148", "69A

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

reassessment under Sections 147 and 148 of the\nAct, the existence of information suggesting escapement of income\ncontinues to be a foundational jurisdictional requirement. The Hon'ble\nCourt clarified that the benchmark under the amended law remains\naligned with the earlier threshold of “reason to believe,” and that the\npower under Section 147 cannot be invoked in the absence

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

reassessment under Sections 147 and 148 of the\nAct, the existence of information suggesting escapement of income\n37\ncontinues to be a foundational jurisdictional requirement. The Hon'ble\nCourt clarified that the benchmark under the amended law remains\naligned with the earlier threshold of “reason to believe,” and that the\npower under Section 147 cannot be invoked in the absence

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

reassessment under Sections 147 and 148 of the\nAct, the existence of information suggesting escapement of income\n37\ncontinues to be a foundational jurisdictional requirement. The Hon'ble\nCourt clarified that the benchmark under the amended law remains\naligned with the earlier threshold of “reason to believe,” and that the\npower under Section 147 cannot be invoked in the absence

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

reassessment under Sections 147 and 148 of the\nAct, the existence of information suggesting escapement of income\n\n37\ncontinues to be a foundational jurisdictional requirement. The Hon'ble\nCourt clarified that the benchmark under the amended law remains\naligned with the earlier threshold of “reason to believe,” and that the\npower under Section 147 cannot be invoked

AJAY TANTA,SHIMLA vs. INCOME TAX OFFICER, SHIMLA

In the result, appeal of the assessee is allowed

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

69A of the Act, on account of cash deposits/credits in bank accounts treated as unexplained money, without 2 considering the facts of the case and without observing the principles of natural justice. 6. That the appellant craves the leave to add, modify, amend or delete any of the grounds of appeal at the time of hearing and all the above

CHUHAR SINGH,CHUHAR SINGH vs. INCOME TAX OFFICER WARD 5 CHANDIGARH, CHANDIGARH

In the result, the appeal of the assessee is allowed for statistical purposes subject to the above condition

Bench: Cit(A). 3. That Learned Cit(A)(Nfac) Has Erred In Law & On Facts In Not Providing Any Reasonable Opportunity Of Being Heard As No Notice Was Received On Email-Id Provided In Form 35 The Appeal Form Before Cita. 4. That Learned Cit(A)(Nfac) Has Erred In Law & On Facts In Confirming The Additions Of Rs. 2,43,60,035/- U/S 69A On Account Of Unaccounted Cash Credit.

reassessment proceedings. As per the assessment order, the assessee failed to comply with the notices and did not furnish satisfactory explanation regarding the source of the deposits. Consequently, the assessment was completed ex parte under section 144 read with section 147 and the entire amount of Rs.2,43,60,035/- was treated as unexplained money under section 69A