SHRI SATISH SOIN,LUDHIANA vs. ACIT, CC-II, LUDHIANA

In the result, appeal of the assessee is allowed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 303/Chd/2019 "नधा"रण वष" / Assessment Year : 2012-13 Shri Satish Soin, बनाम The Acit, House No.31, Garden Enclave, Central Circle-2, Vs South City-Ii, Ludhiana. Ludhiana. "थायी लेखा सं./Pan /Tan No: Advps6254N अपीलाथ"/Appellant ""यथ"/Respondent "नधा"रती क" ओर से/Assessee By : Shri Ashwani Kumar & Ms. Muskan Garg, Cas राज"व क" ओर से/ Revenue By : Smt. Kusum Bansal, Cit Dr तार"ख/Date Of Hearing : 26.05.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 23.07.2025 Hybrid Hearing आदेश/Order Per Rajpal Yadav, Vp

short ‘the CIT (A)’] dated 28.11.2018 passed for assessment year 2012-13. ITA-303/CHD/2019 A.Y. 2012-13 2 2. The assessee has taken three grounds of appeal out of which Ground Nos. 1 and 3 are general in nature which do not call for recording of any specific finding. 3. In Ground No.2, assessee has pleaded that

AMARJIT SINGH,LUDHIANA vs. INCOME TAX OFFICER,WARD 6(1) LUDHIANA, LUDHIANA

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

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 1171 /Chd/2024 निर्धारण वर्ष / Assessment Year : 2017-18 Shri Amarjit Singh बनाम The ITO C/o V V Bhalla & Company Ward 6(1) SCF-39, Rishi Nagar Main Market, Ludhiana Adjoining Subway, Ludhiana-141001, Punjab स्थायी लेखा सं./PAN NO: ABTPS8558B अपीलार्थी/Appellant प्रत्यर्थी/Respondent निर्धारिती की ओर से / Assessee by : Shri Pankaj Bhalla, C.A राजस्व की ओर से/ Revenue by : Shri Vivek Vardhan, Addl. CIT, Sr

reassessment proceedings under section 148 read with section 144A, and defective approval under section 151. The assessee also disputed the addition of Rs 17,41,400/- under the head “Short Term Capital Gain

PAWAN GARG,PANCHKULA vs. ITO WARD 5((5) CHANDIGARH, CHANDIGARH

In the result, appeal of the assessee is allowed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 1218/Chd/2024 "नधा"रण वष" / Assessment Year: 2014-15 Shri Pawan Garg, The Ito, House No. 766, Sector 16, Vs Ward 5(5), Panchkula. Chandigarh. "थायी लेखा सं./Pan No: Abmpg4243N अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ajay Jain, Ca Revenue By : Dr. Ranjit Kaur, Addl. Cit Sr.Dr Date Of Hearing : 27.01.2026 Date Of Pronouncement : 02.02.2026

short ‘the CIT (A)’] dated 04.12.2024 passed for assessment year 2014-15. 2. Though assessee has taken seven grounds of appeal, but his grievance revolves around two issues, namely; A.Y.2014-15 2 a) Ld. ld.CIT (Appeals) has erred in confirming the re- opening of assessment by issuance of a notice u/s 148 dated 30.06.2021. b) Ld. CIT (Appeals) has erred

SH. BALJINDER KUMAR AGGARWAL 171, MODEL TOWN LUDHIANA,PUNJAB vs. JATIN ABBI THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1 LUDHIANA, PUNJAB

In the result, appeal of the Assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 689/Chd/2024 िनधा"रण वष" / Assessment Year : 2012-13 बनाम Shri Baljinder Kumar Aggarwal, The Acit, 171, Model Town, Circle-1, Vs Ludhiana. Ludhiana. "थायी लेखा सं./Pan /Tan No: Bmcpk7473A अपीलाथ"/Appellant ""यथ"/Respondent िनधा"रती क" ओर से/Assessee By : Shri Sudhir Sehgal, Advocate राज"व क" ओर से/ Revenue By : Shri Manav Bansal, Cit, Dr तारीख/Date Of Hearing : 21.08.2025 उदघोषणा क" तारीख/Date Of Pronouncement : 17.09.2025

short ‘the CIT (A)’] dated 25.04.2024 passed for assessment year 2012-13. 2. The assessee has taken six grounds of appeal alongwith sub-grounds (a) (b) (c) and (d) under Ground No.1. However, ITA 689/CHD/2024 A.Y. 2012-13 2 perusal of these grounds would reveal that grievance of the assessee revolves around two-fold, namely

NEERU ARORA,CHANDIGARH vs. CIRCLE-1, INTERNATIONAL TAXATION, CHANDIGARH

In the result, the appeal of the assessee is partly allowed in terms indicated above

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

reassessment proceedings, notices under section 142(1), along with questionnaires, were issued by the AO seeking specific details regarding the said transaction. 4. The AO noted that despite repeated opportunities, no credible explanation or evidence for cost of acquisition of the property was furnished. Therefore, vide show cause notice dated 17.02.2023, the AO proposed to treat the full amount

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

short term capital gains. An Assessing Officer\nfunctioning under the statute cannot employ jugglery of words in\nnotices of the kind and let the assessee keep guessing why is his\nassessment being re-opened. The order clearly sets out that the\nAssessees have already disclosed the said transactions in the Return,\n\n18\nthough arguably they could have been taxed

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

short term capital gains. An Assessing Officer\nfunctioning under the statute cannot employ jugglery of words in\nnotices of the kind and let the assessee keep guessing why is his\nassessment being re-opened. The order clearly sets out that the\nAssessees have already disclosed the said transactions in the Return,\nthough arguably they could have been taxed differently

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

short term capital gains. An Assessing Officer\nfunctioning under the statute cannot employ jugglery of words in\nnotices of the kind and let the assessee keep guessing why is his\nassessment being re-opened. The order clearly sets out that the\nAssessees have already disclosed the said transactions in the Return,\n18\nthough arguably they could have been taxed differently

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

short term capital gains. An Assessing Officer\nfunctioning under the statute cannot employ jugglery of words in\nnotices of the kind and let the assessee keep guessing why is his\nassessment being re-opened. The order clearly sets out that the\nAssessees have already disclosed the said transactions in the Return,\n18\nthough arguably they could have been taxed differently

RAVI KAKKAR,MOHALI vs. INCOME TAX OFFICER NATIONAL FACELESS ASSESSMENT CENTRE, DELHI

In the result, both the appeals of the Assessee are allowed for statistical purposes

Bench: Us, At The Outset, Both The Parties Submitted That The Issues Raised In Both The Appeals Were Identical. In View Of The Aforesaid

reassessment for the financial year 2012-13. 6. During the course of the assessment proceedings, the Assessing Officer (AO) issued notices under Section 142(1) of the Act on 16.10.2019 and 14.12.2019, which remained uncomplied with by the assessee. Consequently, the AO completed the assessment ex-parte under Section 144 of the Act on 18.12.2019, determining the total income

RAVI KAKKAR,MOHALI vs. INCOME TAX OFFICER, MOHALI

In the result, both the appeals of the Assessee are allowed for statistical purposes

Bench: Us, At The Outset, Both The Parties Submitted That The Issues Raised In Both The Appeals Were Identical. In View Of The Aforesaid

reassessment for the financial year 2012-13. 6. During the course of the assessment proceedings, the Assessing Officer (AO) issued notices under Section 142(1) of the Act on 16.10.2019 and 14.12.2019, which remained uncomplied with by the assessee. Consequently, the AO completed the assessment ex-parte under Section 144 of the Act on 18.12.2019, determining the total income

RAM NIWAS,FATEHABAD vs. INCOME TAX OFFICER, INCOME TAX OFFICE, SIRSA ROAD, INDUSTRIAL AREA, FATEHABAD

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

KARTAR SINGH, FATEHABAD vs. PR. COMMISSIONER OF INCOME TAX, ROHTAK

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

PARVEEN KUMAR,229,VILLAGE MANAKPUR-II,TEHSIL JAGADHRI,HARYANA vs. PRABHJOT KAUR,PCIT PANCHKULA, 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

MANINDER JEET SINGH V.P.O. UDHAMGARH,JAGADHRI,HARYANA vs. PRABHJOT KAUR,PCIT, PANCHKULA

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

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

ANIL TUTEJA,FATEHABAD vs. PR. COMMISSIONER OF INCOME TAX, ROHTAK, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

Bench: BEFORE: 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

SH. RAM LAL,FATEHABAD vs. PR.CIT, ROHTAK

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

RAKESH KUMAR,JAGADHRI vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, PANCHKULA

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