THE VED PRAKASH MUKAND LAL EDUCATIONAL SOCIETY,YAMUNANAGAR vs. DCIT, YAMUNANAGAR

In the result, the assessee’s appeals, for both the years, stand dismissed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.824/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 2. आयकर अपील सं. / Ita No.825/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) The Ved Prakash Mukand Lal Dcit Educational Society Circle Yamuna Nagar बनाम/ Vs. (Radaur, Yamuna Nagar) Haryana C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : & 3. आयकर अपील सं. / Ita No.833/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 4. आयकर अपील सं. / Ita No.832/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) Dcit The Ved Prakash Mukand Lal Circle Yamuna Nagar Educational Society बनाम/ Haryana (Radaur, Yamuna Nagar) Vs. C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Tejmohan Singh (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Yamini (Cit) - Ld. Dr (Virtual)

1) of the Act followed by assessment order under Section 143(3) of the Act dated 30.12.2008 accepting the returned income. Later on, the case was selected for reassessment under Section 147 of the Act. The AO found that out of the total receipt of Rs.9,94,56,533/-, only a sum of Rs.6,51,26,448/- (revenue expenditure

DCIT vs. M/S THE VED PARKASH MUKAND LAL, YAMUNANAGAR

In the result, the assessee’s appeals, for both the years, stand dismissed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.824/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 2. आयकर अपील सं. / Ita No.825/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) The Ved Prakash Mukand Lal Dcit Educational Society Circle Yamuna Nagar बनाम/ Vs. (Radaur, Yamuna Nagar) Haryana C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : & 3. आयकर अपील सं. / Ita No.833/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 4. आयकर अपील सं. / Ita No.832/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) Dcit The Ved Prakash Mukand Lal Circle Yamuna Nagar Educational Society बनाम/ Haryana (Radaur, Yamuna Nagar) Vs. C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Tejmohan Singh (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Yamini (Cit) - Ld. Dr (Virtual)

1) of the Act followed by assessment order under Section 143(3) of the Act dated 30.12.2008 accepting the returned income. Later on, the case was selected for reassessment under Section 147 of the Act. The AO found that out of the total receipt of Rs.9,94,56,533/-, only a sum of Rs.6,51,26,448/- (revenue expenditure

THE VED PRAKASH MUKAND LAL EDUCATIONAL SOCIETY,YAMUNANAGAR vs. DCIT, YAMUNANAGAR

In the result, the assessee’s appeals, for both the years, stand dismissed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.824/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 2. आयकर अपील सं. / Ita No.825/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) The Ved Prakash Mukand Lal Dcit Educational Society Circle Yamuna Nagar बनाम/ Vs. (Radaur, Yamuna Nagar) Haryana C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : & 3. आयकर अपील सं. / Ita No.833/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 4. आयकर अपील सं. / Ita No.832/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) Dcit The Ved Prakash Mukand Lal Circle Yamuna Nagar Educational Society बनाम/ Haryana (Radaur, Yamuna Nagar) Vs. C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Tejmohan Singh (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Yamini (Cit) - Ld. Dr (Virtual)

1) of the Act followed by assessment order under Section 143(3) of the Act dated 30.12.2008 accepting the returned income. Later on, the case was selected for reassessment under Section 147 of the Act. The AO found that out of the total receipt of Rs.9,94,56,533/-, only a sum of Rs.6,51,26,448/- (revenue expenditure

EXOTIC REALTORS AND DEVELOPERS,CHANDIGARH vs. PR.CIT-1, CHANDIGARH

In the result, appeal of the assessee is allowed

Bench: SHRI. KRINWANT SAHAY (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

72,79,780/- dt. 27/09/2018 . The said acceptance of returned income is arrived after a proper inquiry and verification because prior to thereto notices under section 143(2) and 142(1) were duly served to the assessee firm and that they were suitably replied with all material information so that computation of income is done in just and proper

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 for the reason that prior to the initiation of the revision proceedings, enquiries/examinations in the manners in which these ought to have

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\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\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

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\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

DCIT, CIRCLE, PATIALA vs. M/S PUNJAB STATE POWER CORPORATION LTD., PATIALA

In the result, ground no. 1 & 3 of the Revenue’s appeal is allowed and ground no

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

reassessment proceedings in favour of the assessee company in earlier years and subsequent year and since issue stands covered in favour of the assesee company in its own case for A.Y. 2011-12 , 2014-15 and 2018-19, the grounds of appeal so taken by the assessee was allowed. Again, we find that there is no finding on merits

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

SHRI ABHISHEK SOIN,LUDHIANA vs. DCIT, CC-II, LUDHIANA

The appeals are partly allowed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 321 & 322/Chd/2019 "नधा"रण वष" / Assessment Year: 2010-11, 2011-12 Shri Abhishek Soin, The Dcit, C/O Sigma Cartons Pvt. Ltd., Vs Central Circle-Ii, Unit-Ii, Industrial Area-C, Ludhiana. Sua Road, Ludhiana. "थायी लेखा सं./Pan No: Anbps9446A अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Aditya Kumar, Ca Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 03.06.2025 Date Of Pronouncement : 29.07.2025 Hybrid Hearing O R D E R

72,79,089/- and claimed exemption under Section 10(38) of the Income Tax Act. The AO, thereafter, made reference to a report of Director of Investigation, Calcutta. Such reference is of general term and we deem it appropriate to take note of this observation of the AO which is verbatim on all three assessment orders. It readd as under

SHRI ABHISHEK SOIN,LUDHIANA vs. DCIT, CC-II, LUDHIANA

The appeals are partly allowed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 321 & 322/Chd/2019 "नधा"रण वष" / Assessment Year: 2010-11, 2011-12 Shri Abhishek Soin, The Dcit, C/O Sigma Cartons Pvt. Ltd., Vs Central Circle-Ii, Unit-Ii, Industrial Area-C, Ludhiana. Sua Road, Ludhiana. "थायी लेखा सं./Pan No: Anbps9446A अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Aditya Kumar, Ca Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 03.06.2025 Date Of Pronouncement : 29.07.2025 Hybrid Hearing O R D E R

72,79,089/- and claimed exemption under Section 10(38) of the Income Tax Act. The AO, thereafter, made reference to a report of Director of Investigation, Calcutta. Such reference is of general term and we deem it appropriate to take note of this observation of the AO which is verbatim on all three assessment orders. It readd as under

DCIT CIRCLE-4, LUDHIANA, LUDHIANA vs. ROCKMAN INDUSTRIES LTD, LUDHIANA

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

72,893 – 1,13,73,255 = 1,32,99,638/- = 2,52,41,328 Total 2.15 The Ld. AO in para 5.5 of the assessment order dt. 30/12/2018 has finally held as under basis aforesaid:- “Therefore in pursuance of the directions of the Hon'ble ITAT. the common expenses allocated between the exempt and non-emept units have been examined

ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-4, AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

72,893 – 1,13,73,255 = 1,32,99,638/- = 2,52,41,328 Total 2.15 The Ld. AO in para 5.5 of the assessment order dt. 30/12/2018 has finally held as under basis aforesaid:- “Therefore in pursuance of the directions of the Hon'ble ITAT. the common expenses allocated between the exempt and non-emept units have been examined

DY. COMMISSIONER OF INCOME TAX, CIRCLE-4, LUDHIANA, - vs. ROCKMAN INDUSTRIES LTD, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

72,893 – 1,13,73,255 = 1,32,99,638/- = 2,52,41,328 Total 2.15 The Ld. AO in para 5.5 of the assessment order dt. 30/12/2018 has finally held as under basis aforesaid:- “Therefore in pursuance of the directions of the Hon'ble ITAT. the common expenses allocated between the exempt and non-emept units have been examined

DY. COMMISSIONER OF INCOME TAX, CIRCLE-4, , AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

72,893 – 1,13,73,255 = 1,32,99,638/- = 2,52,41,328 Total 2.15 The Ld. AO in para 5.5 of the assessment order dt. 30/12/2018 has finally held as under basis aforesaid:- “Therefore in pursuance of the directions of the Hon'ble ITAT. the common expenses allocated between the exempt and non-emept units have been examined

DY. COMMISSIONER OF INCOME TAX, CIRCLE-4, LUDHIANA, AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

72,893 – 1,13,73,255 = 1,32,99,638/- = 2,52,41,328 Total 2.15 The Ld. AO in para 5.5 of the assessment order dt. 30/12/2018 has finally held as under basis aforesaid:- “Therefore in pursuance of the directions of the Hon'ble ITAT. the common expenses allocated between the exempt and non-emept units have been examined

DY. COMMISSIONER OF INCOME TAX, AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, FOCAL POINT

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

72,893 – 1,13,73,255 = 1,32,99,638/- = 2,52,41,328 Total 2.15 The Ld. AO in para 5.5 of the assessment order dt. 30/12/2018 has finally held as under basis aforesaid:- “Therefore in pursuance of the directions of the Hon'ble ITAT. the common expenses allocated between the exempt and non-emept units have been examined