DHARAMVIR SINGH ,VILLAGE THAMBER vs. ITO WARD 1 , AMBALA

In the result, the impugned order and the proceedings are unsustainable in law

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

money added supra, therefore penalty u/s.271(1)(c) of the Act is proposed to be initiated separatelyfor concealment of income.(Addition u/s 69A for Rs.41,45,150/- ) . ii) Since the assessee has offered total interest income of Rs.1,37,363/- (Saving as well as FDR interest) and rental income of Rs.50,820/- in his return of income which filed u/s.148

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

JOINT COMMISSIONER OF INCOME TAX (IN SITU) CIRCLE-I, , LUDHIANA vs. KAPIL THAPAR, LUDHIANA

In the result, appeal of the Department is dismissed and Cross

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

money received over and above the sale value of property, without considering the facts and circumstances of the case that there was sufficient incriminating maerial in the form of loose papers found during the search proceedings to establish that the assessee has received cash over and above the value as per the sale deed. 2. Whether on the facts

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

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)

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

KWALITY OVERSEAS PRIVATE LIMITED,LUDHIANA vs. DEPUTY COMMISSIONER OF INCOME TAX, LUDHIANA

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

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 553/Chd/2024 निर्धारण वर्ष / Assessment Years : 2012-13 Kwality Overseas Private Limited 863, Industrial Area-A, Ludhiana बनाम The DCIT Ludhiana स्थायी लेखा सं./ PAN NO: AABCK6381J अपीलार्थी/Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से/Assessee by : Shri Ashwani Kumar, C.A राजस्व की ओर से / Revenue by : Shri Manav Bansal, CIT, DR सुनवाई की तारीख / Date of Hearing : 07/08/2025 उदघोषणा की तारीख/Date

reassessment proceedings under Section 147 of the Income Tax Act, 1961, after recording reasons and obtaining approval. Despite repeated statutory notices issued under Sections 148, 142(1), and 143(2), the assessee failed to furnish requisite details or explanations regarding the undervaluation of imports and the source of bank deposits. A show-cause notice dated 23.11.2019 was also issued proposing

AMIT ANAND,CHANDIGARH vs. INCOME TAX OFFICER WARD 2(1), CHANDIGARH, CHANDIGARH

The appeal stand allowed

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं. / Ita No.1246/Chandi/2024 (िनधा"रणवष" / Assessment Year: 2013-14) Shri Amit Anand Ito H.No.2175/A, Sector 38-C Ward 2(1) बनाम/ Vs. Chandigarh. Chandigarh-160017. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Agbpa-0901-D (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh Vineet Krishan (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Sh. Vivek Vardhan (Addl. Cit) – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 21-05-2025 घोषणाकीतारीख /Date Of Pronouncement : 22-05-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2013-14 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Cit(A)] Dated 28-12-2024 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S. 144B R.W.S. 147 Of The Act On 16-09.2021. Having Heard Rival Submissions & Upon Perusal Of Case Records, The Appeal Is Disposed-Off As Under.

unexplained money u/s 69A. The Ld. CIT(A) confirmed the same against which the assessee is in further appeal before us. 3. Upon perusal of ITR-4 as filed by the assessee on 31-03-2014, it could be seen that the assessee has reflected loans (assets) for Rs.5 Lacs in the return of income. Similar amount has been reflected

RAM SINGH,DISTRICT KAITHAL, HARYANA vs. INCOME TAX OFFICER, WARD-1, KAITHAL, INCOME TAX OFFICE, AMBALA ROAD, KAITHAL

The appeal of the assessee is dismissed

Bench: The Appeal Is Finally Heard Or Disposed Of.

reassessment was completed u/s 143(3) r.w.s. 147 on 27.12.2019 assessing the income at Rs. 1,60,79,020/- after making an addition of Rs. 1,58,84,450 /- u/s 69 for unexplained cash deposits. 4. The assessee has challenged the reopening on the ground that the AO acted mechanically and did not form an independent belief. The Ld. Counsel

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

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)

unexplained money under section 69A of the Act. 3. The Ld. CIT(A) upheld the action of the Assessing Officer by observing that the assessee had failed to properly comply with the notices issued during the assessment proceedings and no satisfactory explanation with evidences was furnished to substantiate the source of cash deposits. 4. Aggrieved, the assessee has raised multiple

MOHINDER SINGH,ROPAR,PUNJAB vs. ITO WARD-2(2), PUNJAB

In the result, the appeal of the assessee is allowed

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

reassessment proceedings initiated u/s 147, the Assessing Officer noticed that the assessee had deposited cash of Rs. 20,64,000/- in his bank account during the demonetization period. 3.1 The Assessing Officer observed that out of the said deposits, an amount of Rs. 12,99,000/- represented deposits in old currency on three dates

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)

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 grounds are without prejudice to each other. 3. Briefly the facts of the case

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

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

reassessment proceedings, the Assessing Officer noticed that the total credits in the said bank account aggregated to Rs.34,68,87,240/-, which, according to him, were not commensurate with the income and turnover disclosed by the assessee. The Assessing Officer was of the view that the assessee failed to satisfactorily explain the nature and source of these credits. Accordingly

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, LUDHIANA vs. RAMAN SETH, LUDHIANA

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

unexplained money? 3. Whether upon facts and circumstances of the case, the Ld. CIT(A) has erred on facts and law, by ignoring the test of human probabilities as upheld by Hon'ble Supreme Court in the case of CIT vs. Durga Prasad More (1971) 82 ITR 540 (SC) and Sumati Dayal vs. Commissioner of Income

SAUGAAT,AMBALA CANTT vs. ITO, WARD 4, AMBALA CANTT. (ASSESSMENT UNIT), AMBALA CANTT

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

unexplained money under Section 69A of the Income Tax Act, 1961 whereas the same pertain to Sh. Hemant Batra proprietor of M/s Saugaat and not to the appellant firm. 6 That in the facts and circumstances of the case, the Ld. Commissioner of Income Tax (Appeals) gravelly erred in not appreciating the fact that the appellant partnership firm was dissolved

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

AMAN FEED INDUSTRIES,KHANNA vs. DEPUTY COMMISSIONER OF INCOME TAX, CC-1, , LUDHIANA

In the result, appeals of the assessee for A

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 1252, 1253,1254,1255/Chd/2024 "नधा"रण वष" / A.Y.: 2015-16, 2017-18, 2018-19,2019-20 M/S Aman Feed Industries, The Dcit, E-2, Focal Point, Vs Central Circle-1, Khanna. Ludhiana. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent आयकर अपील सं./ Ita Nos. 116,181,457/Chd/2025 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 The Dcit, Vs M/S Aman Feed Industries, Central Circle-1, E-2, Focal Point, Ludhiana. Khanna. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ashwani Kumar, Shri Kulbhushan Goyal & Ms, Deepali Aggarwal, Cas Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 28.07.2025 Date Of Pronouncement : 16.10.2025

money by resort to provisions of Section 69A of the Act and taxed u/s 115BBE. 4. That he was further not justified to uphold the action of the Learned Assessing Officer in arbitrarily making an addition of Rs. 1.00 crore being stock allegedly found in excess during the course of search. 5. That he was further not justified to uphold

DY. COMMISSIONER OF INCOME TAX, CC-1, , LUDHIANA vs. M/S AMAN FEED INDUSTRIES, KHANNA

In the result, appeals of the assessee for A

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 1252, 1253,1254,1255/Chd/2024 "नधा"रण वष" / A.Y.: 2015-16, 2017-18, 2018-19,2019-20 M/S Aman Feed Industries, The Dcit, E-2, Focal Point, Vs Central Circle-1, Khanna. Ludhiana. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent आयकर अपील सं./ Ita Nos. 116,181,457/Chd/2025 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 The Dcit, Vs M/S Aman Feed Industries, Central Circle-1, E-2, Focal Point, Ludhiana. Khanna. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ashwani Kumar, Shri Kulbhushan Goyal & Ms, Deepali Aggarwal, Cas Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 28.07.2025 Date Of Pronouncement : 16.10.2025

money by resort to provisions of Section 69A of the Act and taxed u/s 115BBE. 4. That he was further not justified to uphold the action of the Learned Assessing Officer in arbitrarily making an addition of Rs. 1.00 crore being stock allegedly found in excess during the course of search. 5. That he was further not justified to uphold

AMAN FEED INDUSTRIES,KHANNA vs. DEPUTY COMMISSIONER OF INCOME TAX, CC-1, , LUDHIANA

In the result, appeals of the assessee for A

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 1252, 1253,1254,1255/Chd/2024 "नधा"रण वष" / A.Y.: 2015-16, 2017-18, 2018-19,2019-20 M/S Aman Feed Industries, The Dcit, E-2, Focal Point, Vs Central Circle-1, Khanna. Ludhiana. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent आयकर अपील सं./ Ita Nos. 116,181,457/Chd/2025 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 The Dcit, Vs M/S Aman Feed Industries, Central Circle-1, E-2, Focal Point, Ludhiana. Khanna. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ashwani Kumar, Shri Kulbhushan Goyal & Ms, Deepali Aggarwal, Cas Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 28.07.2025 Date Of Pronouncement : 16.10.2025

money by resort to provisions of Section 69A of the Act and taxed u/s 115BBE. 4. That he was further not justified to uphold the action of the Learned Assessing Officer in arbitrarily making an addition of Rs. 1.00 crore being stock allegedly found in excess during the course of search. 5. That he was further not justified to uphold