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)

147. 10. It was argued before us that in reply to notice u/s 133(6) the source of bank deposit was shown out of cash sales and receipt of sundry debtors. No further query was made and the AO had merely relied upon the information available with him, which was not valid in view of the judgment

PARVEEN KUMAR MITTAL,YAMUNA NAGAR vs. PR.CIT, PANCHKULA

The appeal of the assessee is allowed in above terms

Bench: Us Raising The Following Grounds:

cash deposits which he had failed to explain before the AO, NMS, was sufficient to form belief of escapement of income. A.Y. 2011-12 Page 8 of 22 9. To this the Ld.Counsel for the assessee responded by stating that the assessee was not required to file any explanation to the AO, NMS. Ld.Counsel for the assessee explained that

GURDISH KAUR KHULAR,JALANDHAR vs. ACIT( INTERNATIONAL TAXATION), CIRCLE, CHANDIGARH

In the result, appeal of the assessee is allowed

cash deposit of Rs.35,01,000/- has escaped assessment. Sir, it is settled law that "reason to believe" forms the foundation for assuming jurisdiction u/s 147. It is also settled law that "reason to believe" is not just an idle formality and it has not to be mere pretence. If there is no material or even if there is material

INDO PACIFIC FINLEASE LTD,CHANDIGARH vs. PCIT- CHANDIGARH 1, CHANDIGARH

In the result, both the appeals are filed by the\nassessee are allowed

reassessment order, then the assessee has to step in and\nprotect its interests and the liberty to question even the validity of the\nreassessment proceedings ought to be given to it......." (emphasis\nsupplied) 8. 8. Similar view was taken in another decision of the Tribunal\nin the case of Dhiraj Suri vs ACIT 98 ITD 87 (Del). In the said

INDO PACIFIC FINLEASE LTD,CHANDIGARH vs. PCIT CHANDIGARH 1, CHANDIGARH

In the result, both the appeals are filed by the\nassessee are allowed

reassessment order, then the assessee has to step in and\nprotect its interests and the liberty to question even the validity of the\nreassessment proceedings ought to be given to it......." (emphasis\nsupplied) 8. 8. Similar view was taken in another decision of the Tribunal\nin the case of Dhiraj Suri vs ACIT 98 ITD 87 (Del). In the said

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):

u/s 147 r.w.s. 144 of the Income-tax Act, 1961 (“the Act”). 2. Briefly, the facts of the case are that the assessee, a non-resident individual, was subjected to reassessment proceedings on the basis of information received by the Assessing Officer that cash deposits

MADAN LAL,FATEHABAD vs. ITO, WARD-1, FATEHABAD

In the result, Assessee’s appeal stands allowed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 190/Chd/2024 "नधा"रण वष" / Assessment Year : 2017-18 Madan Lal, The Ito, Ganaga Pipe Ind, बनाम Ward-1, G.T.Road, Fatehabad Vs. Village Dhangar, Fatehbad 125050 "थायी लेखा सं./Pan No: Acapl2915R अपीलाथ"/Appellant ""यथ"/Respondent ( Hybrid Mode ) "नधा"रती क" ओर से/Assessee By : Sh. Suraj Bhan Nain, Advocate (Virtual) राज"व क" ओर से/ Revenue By : Dr. Ranjit Kaur, Addl. Cit, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 30.07.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 13.10.2025 आदेश/Order Per Krinwant Sahay, Am: Appeal In This Case Has Been Filed By The Assessee Against The Order Dated 28.12.2023 Of Cit(A), National Faceless Appeal Centre (Nfac), Delhi For The A.Y. 2017- 18. 2. Grounds Of Appeal Are As Under: -

deposited cash of Rs. 190-Chd-2024 Madan Lal, Fatehabad 4 16,82,000/- during 09.11.2016 to 30.12.2016 in his bank account No. 20638854926 maintained with Allahabad Bank. 4. Subsequently, the Ld. Assessing Officer initiated reassessment proceedings u/s 147

WINSOME TEXTILE INDUSTRIES LIMITED,CHANDIGARH vs. ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-4(1), CHANDIGARH, CHANDIGARH

In the result, the appeal of the assessee is partly allowed and the appeal of the Revenue is dismissed

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

147 is attracted. The reasons to believe ought to also paraphrase any investigation report which may form the basis of the reasons and any enquiry conducted by the AO on the same and if so, the conclusions thereof; (iii) where the reasons make a reference to another document, whether as a letter or report, such document and/ or relevant portions

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.

deposited Rs.1,11,67,000/- in cash in his bank account during the demonetization period (09.11.2016 to 30.12.2016), reassessment proceedings u/s 147

SOCIETY FOR EDUCATION AND RESEARCH,JAGADHRI, YAMUNANGAR vs. DCIT(E) (CIRCLE-2), CHANDIGARH

In the result, ground no. 2 of the assessee’s appeal is allowed

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

reassessment proceedings have been initiated by issuance of notice u/s 148 on 11/03/2019 after the expiry of fours years from the end of the impugned assessment year 2012-13 and coupled with the fact that the original proceedings have been completed u/s 143(3), the condition specified in the proviso to section 147 also need to be satisfied before

SH. RAM LAL,ROPAR vs. PR. C.I.T. -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)

u/s 147 to verify the cash deposit of Rs 10.50 lacs in the bank account maintained by the assessee. In the proceedings so followed, the AO has enquired about the cash so found deposited in the bank account and the assessee in turn has filed his explanation and necessary documentation in support thereof. Thereafter, the AO in the reassessment

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

GEETA SHARMA,SUNAM vs. ITO, SUNAM

In the result, appeal of the assessee is allowed

reassessment proceedings ought to be\ngiven to it......." (emphasis supplied) 8. 8. Similar view was\ntaken in another decision of the Tribunal in the case of Dhiraj\nSuri vs ACIT 98 1TD 87 (Del). In the said case, appeal was filed\nby the assessee before the Tribunal against the levy of penalty.\nIn the appeal challenging the penalty order

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)

deposited in 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

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)

deposited in 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

MOHIT KAPOOR LUDHIANA,PUNJAB vs. JAO THE INCOME TAX OFFICR WARD 2(1), LUDHIANA, PUNJAB

In the result, the appeal is allowed for statistical purposes

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

reassessment u/s 147, the service of notice, and the addition of Rs.10,77,850/- u/s 69A on account of alleged unexplained cash deposits

VIPAN KUMAR THAMMAN,DERABASSI vs. INCOME TAX OFFICER, WARD-2(5),CHANDIGARH, CHANDIGARH

The appeal stands partly allowed for statistical purposes

Bench: SHRI RAJPAL YADAV (Vice President), SHRI MANOJ KUMAR AGGARWAL (Accountant Member)

147 r.w.s.143(3) of the Act on 22-12-2016. The sole grievance of the assessee is confirmation of addition of Rs.109.50 Lacs. The Ld. AR advanced arguments on legal grounds as well as on merits supporting the case of the assessee. The Ld. Sr. DR also advanced arguments supporting the orders of lower authorities. Having heard rival submissions

SHRI RAVINDER SINGH,PANCHKULA vs. ITO, W-3, PANCHKULA

In the result appeal filed by the Assessee is allowed

cash amounting to Rs. 32,80,000/-. Since the assessee had not filed his return of income, A.O. issued notice to the assessee under section 148 of the Act. However, the AO did not receive any response to the said Shri Ravinder Singh 2 notice. Thereafter the A.O. issued notice under section 142(1) of the Act. Again, the assessee

VANEET GUPTA, S.O. SH. CHATTUR BHUJ GUPTA, #214, SECTOR-06,PANCHKULA vs. PCIT PANCHKULA JURISDICTIONAL ASSESSING OFFICER ITO WARD 5, PANCHKULA , PANCHKULA

In the result, Assessee’s appeal is allowed

Bench: Shri Rajpal Yadav & Dr Krinwant Sahayआयकर अपील सं./ Ita No. 560/Chd/2024 "नधा"रण वष" / Assessment Year : 2011-12 Vaneet Gupta, Vs. The Ito, बनाम S.O. Shri Chattur Bhuj Ward 5, Gupta, Panchkula # 214, Sector 6, Panchkula "थायी लेखा सं./Pan No: Aphpg0692N अपीलाथ"/ Appellant ""यथ"/ Repsondent ( Hybrid Hearing ) "नधा"रती क" ओर से/Assessee By : Shri Sudhir Sehgal, Advocate राज"व क" ओर से/ Revenue By : Smt. Kusum Bansal, Cit Dr सुनवाई क" तार"ख/Date Of Hearing : 04.12.2024 उदघोषणा क" तार"ख/Date Of Pronouncement : 20.01.2025 आदेश/Order Per Krinwant Sahay, A.M.:

147 of the income tax, dated 24.10.2018 and holding the same as erroneous, in so far as, prejudicial to the interest of revenue. 2. That the Ld. PCIT has failed to appreciate that the assessment was framed by the Ld. Assessing Officer vide order, dated 24.10.2018 after due application of mind relating to investment in immoveable property and also credits