MALKIAT AGRO INDUSTRIES 01, CANTT ROAD, NABHA 147201, PUNJAB,PUNJAB vs. LOVISH SHELLEY THE DCIT CIRCLE MANDIGOBIND GARH JAO INCOME TAX OFFICER NABHA, PUNJAB

In the result, assessee’s appeal is allowed

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

unexplained credit'. 12. Notwithstanding the above said ground of appeal, the addition of Rs. 12,39,90,680 on account of cash deposits is not justified at all because such amount having been recorded already in the turnover of the assessee towards credit side of Manufacturing 8t Trading Account and further making the addition on account of 'cash deposits' would

SKYCITY BUILDERS AND PROMOTERS PRIVATE LIMITED, ,KHARAR, RUPNAGAR vs. DCIT WARD 6(1), CHANDIGARH JAO ITO 6(1) MOHALI, CHANDIGARH

In the result, the corresponding grounds as raised by the revenue stand dismissed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No.1066/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2012-13) M/S Skycity Builders & Promoters Pvt. Ltd. Dcit Ward 6(1) बनाम/ Room No.3, 1St Floor Sco-90, City Heart Kharar-Chandigarh Road, Livestock Complex Vs. Kharar, Rupnagar (Punjab) - 140301 Sector – 68, Mohali -160062 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aapcs-2435-R (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकर अपील सं./ Ita No.1217/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2012-13) Dcit Ward 6(1) M/S Skycity Builders & Promoters Pvt. Ltd. बनाम/ Room No.3, 1St Floor Sco-90, City Heart Livestock Complex Kharar-Chandigarh Road, Vs. Sector – 68, Mohali -160062 Kharar, Rupnagar (Punjab) - 140301 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aapcs-2435-R (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Sudhir Sehgal (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Ms. Yamini (Cit) - Ld. Dr (Virtual) सुनवाईकीतारीख/Date Of Hearing : 05.02.2026 घोषणाकीतारीख /Date Of Pronouncement : 16.03.2026

unexplained expenditure and the assessment was framed which was subjected to assessee’s further challenge in first appeal wherein the assessee challenged the reopening of the assessment on legal grounds and also challenged quantum additions on merits. Appellate Proceedings 3.1 On legal ground assailing reopening of the assessment, the assessee contended that the findings of Ld. AO were

INCOME TAX OFFICER WARD 6 (1), MOHALI vs. SKYCITY BUILDERS AND PROMOTERS PRIVATE LIMITED, KHRAR PUNJAB

In the result, the corresponding grounds as raised by the revenue stand dismissed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No.1066/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2012-13) M/S Skycity Builders & Promoters Pvt. Ltd. Dcit Ward 6(1) बनाम/ Room No.3, 1St Floor Sco-90, City Heart Kharar-Chandigarh Road, Livestock Complex Vs. Kharar, Rupnagar (Punjab) - 140301 Sector – 68, Mohali -160062 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aapcs-2435-R (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकर अपील सं./ Ita No.1217/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2012-13) Dcit Ward 6(1) M/S Skycity Builders & Promoters Pvt. Ltd. बनाम/ Room No.3, 1St Floor Sco-90, City Heart Livestock Complex Kharar-Chandigarh Road, Vs. Sector – 68, Mohali -160062 Kharar, Rupnagar (Punjab) - 140301 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aapcs-2435-R (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Sudhir Sehgal (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Ms. Yamini (Cit) - Ld. Dr (Virtual) सुनवाईकीतारीख/Date Of Hearing : 05.02.2026 घोषणाकीतारीख /Date Of Pronouncement : 16.03.2026

unexplained expenditure and the assessment was framed which was subjected to assessee’s further challenge in first appeal wherein the assessee challenged the reopening of the assessment on legal grounds and also challenged quantum additions on merits. Appellate Proceedings 3.1 On legal ground assailing reopening of the assessment, the assessee contended that the findings of Ld. AO were

ACIT, CC-2, CHANDIGARH vs. M/S TJR PROPERTIES PVT. LTD., CHANDIGARH

Bench: SHRI A.D.JAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)

cash by the appellant without any justification. 8. That the learned CIT(A) has wrongly upheld addition of Rs. 14,20,000/- u/s 68 of the Act on surmises and conjectures. 9. That the learned CIT(A) has wrongly upheld disallowance of loss of Rs.50,231/- without discussing the same in the impugned order. 10. That the learned

M/S TJR PROPERTIES PVT. LTD.,CHANDIGARH vs. ACIT, CC-2, CHANDIGARH

Bench: SHRI A.D.JAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)

cash by the appellant without any justification. 8. That the learned CIT(A) has wrongly upheld addition of Rs. 14,20,000/- u/s 68 of the Act on surmises and conjectures. 9. That the learned CIT(A) has wrongly upheld disallowance of loss of Rs.50,231/- without discussing the same in the impugned order. 10. That the learned

ASSISTANT COMMISSIONER OF INCOME TAX, PANCHKULA CIRCLE, PANCHKULA, PANCHKULA vs. KONARK RAJHANS ESTATE PRIVATE LIMITED, PANCHKULA

In the result, the appeal of the revenue stands dismissed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No. 805/Chandi/2024 (िनधा"रणवष" / Assessment Year: 2011-12 Acit M/S Konark Rajhans Estate Private Limited Panchkula Circle बनाम/ Vs. Nh 73, Village Kot Extension-Ii, Sector 14, Panchkula. Panchkula. "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aaeck-2405-Q (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Manav Bansal (Cit) – Ld. Dr ""थ"कीओरसे/Respondent By : Sh. Parikshit Aggarwal (Ca)-Ld. Ar सुनवाईकीतारीख/Date Of Hearing : 20-08-2025 घोषणाकीतारीख /Date Of Pronouncement : 13/11/2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1.1 Aforesaid Appeal By The Revenue For Assessment Year (Ay) 2011- 12 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Cit(A)] Dated 27-05-2024 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S. 143(3) R.W.S. 147 Of The Act On 29-12-2018. The Revenue Is Aggrieved By Deletion Of Twin Quantum Additions Of Rs.40.85 Lacs & Rs.707.75 Lacs As Made By Ld. Ao In The Assessment Order. The Grounds Of Appeal Read As Under: -

unexplained cash credit u/s 68 and the assessment was framed. Appellate Proceedings 3.1 The assessee, in its submissions, assailed the reopening of the assessment on legal grounds. It was contended that the recording of reasons was solely derived on suspicion formed merely on the basis of information as available with the department without there being any fresh tangible material

JAMYANG KHYENTSE YESHI,KANGRA, HIMACHAL PRADESH vs. ACIT, DCIT, C.R. BUILDING, CHANDIGARH

The appeal of the assessee is partly allowed

Bench: The Ld. Cit(A). The Ld. Cit(A), After Calling For A Remand Report Under Rule 46A, Recorded The Following Findings (Para 5.1 To 5.5 Of The Appellate Order):

reassessment proceedings on the basis of information received by the Assessing Officer that cash deposits and credit-card payments aggregating to Rs. 42,57,319 were made in his Indian bank account during the relevant year. 2.1 The Assessing Officer reopened the case u/s 147 and made an addition of Rs. 42,57,319/-—comprising (i) cash deposits

INCOME TAX OFFICER, WARD 2(1),, CHANDIGARH vs. HARI KRISHAN GUPTA, CHANDIGARH

In the result, the appeal of the Revenue is dismissed

Bench: Or At The Time Of Hearing Of Appeal.

reassessment proceedings u/s 147 were initiated. 3.1 The AO observed that despite issuance of notices u/ss 142(1) and 143(2), the assessee failed to furnish satisfactory explanation along with supporting evidence. The explanation offered—that the cash represented festival season sales duly recorded in the books—was rejected by applying the theory of human probability. Relying on Sumati Dayal

SAWASTIKA PRINTING & PACKAGING,KALA MAB vs. ASSESSING OFFICER, NAHAN

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

Bench: the Hon'ble CIT(A)(NFAC) that assessee is having business turnover of Rs 16,77,30,943/-. While upholding the additions of Rs 20,81,000/- the Hon'ble CIT(A) (NFAC) has observed in last para of his order as under:-

credits in the absence of concrete evidence indicating accommodation entries or fictitious transactions. 4.2 However, the Ld. CIT(A) made a distinction between the sources claimed by the assessee. With regard to the cash deposits aggregating to Rs.61,93,000/-, it was held that the assessee had reasonably explained the source through opening cash balance and cash withdrawals reflected

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2 LUDHIANA, LUDHIANA vs. AMARJIT SINGH , BATHINDA

In the result, Cross Objections of the assessee

Bench: Shri Rajpal Yadav & Shri Krinwant Sahay

cash credit. In fact, in case if the part transactions are wrong, there is no reason to make impugned addition of other part (i.e. the opening balance) which is unsubstantiated in absence of any corroborative evidence. Since part of the transaction has been accepted as not related to the assessee then the same logic should have been applied to other

M/S TJR PROPERTIES PVT. LTD.,CHANDIGARH vs. ACIT, CC-2, CHANDIGARH

Bench: SHRI A.D.JAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)

cash without any justification. 12. That the learned CIT(A) has wrongly upheld addition of Rs. 45,00,000/- u/s 68 of the Act on surmises and conjectures. 13. That the learned CIT(A) has wrongly upheld disallowance of loss of Rs. 2,97,834/- without any justification. 14. That the learned CIT(A) has wrongly upheld disallowance of depreciation

ACIT, CC-2, CHANDIGARH vs. M/S TJR PROPERTIES PVT. LTD., CHANDIGARH

Bench: SHRI A.D.JAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)

cash without any justification. 12. That the learned CIT(A) has wrongly upheld addition of Rs. 45,00,000/- u/s 68 of the Act on surmises and conjectures. 13. That the learned CIT(A) has wrongly upheld disallowance of loss of Rs. 2,97,834/- without any justification. 14. That the learned CIT(A) has wrongly upheld disallowance of depreciation

SH. SATNAM SINGH,MOHALI vs. ITO, WARD 6(1), MOHALI

In the result, both the appeals of the Assessee are allowed

Bench: Shri Mahavir Singh & Shri Krinwant Sahay

cash deposit and unexplained cheque deposit in his bank account maintained with UCO bank. The Assessing Officer also added the interest earned on this bank account of Rs. 1,54,895/- by treating the same as ‘income from other sources’. Accordingly, assessment was framed. Aggrieved, Assessee preferred appeal before the CIT(A) . The CIT(A) simplicitor confirmed the action

SH. SATNAM SINGH,MOHALI vs. ITO, WARD 6(4), MOHALI

In the result, both the appeals of the Assessee are allowed

Bench: Shri Mahavir Singh & Shri Krinwant Sahay

cash deposit and unexplained cheque deposit in his bank account maintained with UCO bank. The Assessing Officer also added the interest earned on this bank account of Rs. 1,54,895/- by treating the same as ‘income from other sources’. Accordingly, assessment was framed. Aggrieved, Assessee preferred appeal before the CIT(A) . The CIT(A) simplicitor confirmed the action

M/S SEO LEHENGA HOUSE,JAGRAON vs. DCIT, CENTRAL CIRCLE -3, LUDHIANA

In the result, ground no. 3,4,5 & 6(a) are dismissed as not pressed and ground no

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

reassessment was completed under section 153A r.w.s 143(3) dt. 27/12/2019 at an assessed income of Rs. 2,26,35,818/- by making addition under section 69C towards unexplained expenditure amounting to Rs. 5,31,795/- and another addition of Rs. 1,28,09,583/- towards unexplained investment in respect of unaccounted purchases under section

SEO BRIDAL STUDIO PVT LTD,LUDHIANA vs. DCIT CENTRAL CIRCLE(3), LUDHIANA

In the result, ground no. 3,4,5 & 6(a) are dismissed as not pressed and ground no

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

reassessment was completed under section 153A r.w.s 143(3) dt. 27/12/2019 at an assessed income of Rs. 2,26,35,818/- by making addition under section 69C towards unexplained expenditure amounting to Rs. 5,31,795/- and another addition of Rs. 1,28,09,583/- towards unexplained investment in respect of unaccounted purchases under section

M/S SEO LEHENGA HOUSE,JAGRAON vs. DCIT-CENTRAL CIRCLE-3, LUDHIANA

In the result, ground no. 3,4,5 & 6(a) are dismissed as not pressed and ground no

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

reassessment was completed under section 153A r.w.s 143(3) dt. 27/12/2019 at an assessed income of Rs. 2,26,35,818/- by making addition under section 69C towards unexplained expenditure amounting to Rs. 5,31,795/- and another addition of Rs. 1,28,09,583/- towards unexplained investment in respect of unaccounted purchases under section

M/S SEO LEHENGA HOUSE,JAGRAON vs. DCIT, CENTRAL CIRCLE-3, LUDHIANA

In the result, ground no. 3,4,5 & 6(a) are dismissed as not pressed and ground no

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

reassessment was completed under section 153A r.w.s 143(3) dt. 27/12/2019 at an assessed income of Rs. 2,26,35,818/- by making addition under section 69C towards unexplained expenditure amounting to Rs. 5,31,795/- and another addition of Rs. 1,28,09,583/- towards unexplained investment in respect of unaccounted purchases under section

M/S SEO LEHENGA HOUSE,JAGRAON vs. DCIT, CENTRAL CIRCLE-3, LUDHIANA

In the result, ground no. 3,4,5 & 6(a) are dismissed as not pressed and ground no

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

reassessment was completed under section 153A r.w.s 143(3) dt. 27/12/2019 at an assessed income of Rs. 2,26,35,818/- by making addition under section 69C towards unexplained expenditure amounting to Rs. 5,31,795/- and another addition of Rs. 1,28,09,583/- towards unexplained investment in respect of unaccounted purchases under section