ACIT, CIRCLE 1(1), CHANDIGARH vs. M/S SML ISUZU LTD., CHANDIGARH

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

u/s 143(3) is not change of opinion and that assessment was opened validly. The jurisdictional High Court judgment in case of Ropar District, Cooperative Milk Producers Union Ltd. Vs. CIT = (2009) 311 ITR 42 (P&H) relied upon. It was also pleaded that even if for argument sake, it is accepted there was disclosure by the assessee in form

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

DCIT, CC-I, CHANDIGARH , CHANDIGARH vs. VALCO INDUSTRIES LTD., , CHANDIGARH

In the result, the appeal of the Revenue is dismissed

Bench: The Hon'Ble Punjab & Haryana High Court? Ii) Whether On The Facts & Circumstances Of The Case & In Law, Ld. Cit(A) Is Right Holding Such Consequential Order As Void An Initio Ignoring The Facts That Order Passed By Ld. Pcit (Central), Gurugram U/S 263 Has Not Attained Its Finality? Iii) Whether On The Facts & In Circumstances Of The Case & In Law, The Ld. Cit(A) Was Right In Holding That Consequential Order Passed U/S 147 R.W.S. 263 Of The Act As Void As Initio Without Giving Any Liberty To The Revenue To Revive The Proceedings Consequent To Any Directions Or Order

reassessment u/s 147 of the Act and the Ld.CIT(A) had dismissed the assessee's appeals. In assessment year 2012-13 also, the ITAT has categorically allowed the assessee's claim for deduction u/s 80IC of the Act @ 100% on account of substantial expansion vide order in ITA No.305/Chd/2021 dated 1 1.05.2022 and, the Coordinate Bench of the ITAT

SH. BALJINDER SINGH,CHANDIGARH vs. PR.CIT, CHANDIGARH -1, CHANDIGARH

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)

exemption u/s 10(37) of the Act. This admission clearly shows that the assumption made in the reasons recorded for reopening was not in accordance with the record.  Without prejudice to the above, it is submitted that after issuance of the notice u/s 148, reassessment proceedings were carried out in the normal course after obtaining the necessary approval

INDER KAUR,SIRSA 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)

exemption u/s 10(37) of the Act. This admission clearly shows that the assumption made in the reasons recorded for reopening was not in accordance with the record.  Without prejudice to the above, it is submitted that after issuance of the notice u/s 148, reassessment proceedings were carried out in the normal course after obtaining the necessary approval

PARAMJIT SINGH,SIRSA 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)

exemption u/s 10(37) of the Act. This admission clearly shows that the assumption made in the reasons recorded for reopening was not in accordance with the record.  Without prejudice to the above, it is submitted that after issuance of the notice u/s 148, reassessment proceedings were carried out in the normal course after obtaining the necessary approval

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)

exemption u/s 10(37) of the Act. This admission clearly shows that the assumption made in the reasons recorded for reopening was not in accordance with the record.  Without prejudice to the above, it is submitted that after issuance of the notice u/s 148, reassessment proceedings were carried out in the normal course after obtaining the necessary approval

SH. GURDEEP SINGH MAHAL,SIRSA 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)

exemption u/s 10(37) of the Act. This admission clearly shows that the assumption made in the reasons recorded for reopening was not in accordance with the record.  Without prejudice to the above, it is submitted that after issuance of the notice u/s 148, reassessment proceedings were carried out in the normal course after obtaining the necessary approval

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)

exemption u/s 10(37) of the Act. This admission clearly shows that the assumption made in the reasons recorded for reopening was not in accordance with the record.  Without prejudice to the above, it is submitted that after issuance of the notice u/s 148, reassessment proceedings were carried out in the normal course after obtaining the necessary approval

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)

exemption u/s 10(37) of the Act. This admission clearly shows that the assumption made in the reasons recorded for reopening was not in accordance with the record.  Without prejudice to the above, it is submitted that after issuance of the notice u/s 148, reassessment proceedings were carried out in the normal course after obtaining the necessary approval

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)

exemption u/s 10(37) of the Act. This admission clearly shows that the assumption made in the reasons recorded for reopening was not in accordance with the record.  Without prejudice to the above, it is submitted that after issuance of the notice u/s 148, reassessment proceedings were carried out in the normal course after obtaining the necessary approval

MADHU GREWAL,CHANDIGARH vs. PRINCIPAL COMMISSIONER OF INCOME TAX, CHANDIGARH-1, 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

exemption u/s 10(37) of the Act. This admission clearly shows that the assumption made in the reasons recorded for reopening was not in accordance with the record.  Without prejudice to the above, it is submitted that after issuance of the notice u/s 148, reassessment proceedings were carried out in the normal course after obtaining the necessary approval

ASHOK KUMAR THAKRAL,JAGADHRI vs. PRINCIPAL COMMISSIONER OF INCOME TAX, PANCHKULA , PANCHKULA

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

exemption u/s 10(37) of the Act. This admission clearly shows that the assumption made in the reasons recorded for reopening was not in accordance with the record.  Without prejudice to the above, it is submitted that after issuance of the notice u/s 148, reassessment proceedings were carried out in the normal course after obtaining the necessary approval

SH. DEVENDER KUMAR,YAMUNA NAGAR vs. ITO, WARD -1, YAMUNA NAGAR

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)

exemption u/s 10(37) of the Act. This admission clearly shows that the assumption made in the reasons recorded for reopening was not in accordance with the record.  Without prejudice to the above, it is submitted that after issuance of the notice u/s 148, reassessment proceedings were carried out in the normal course after obtaining the necessary approval

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

exemption u/s 10(37) of the Act. This admission clearly shows that the assumption made in the reasons recorded for reopening was not in accordance with the record.  Without prejudice to the above, it is submitted that after issuance of the notice u/s 148, reassessment proceedings were carried out in the normal course after obtaining the necessary approval

MUNISH KUMAR LEGAL HEIR LATE SH GURDEEP SINGH,VILL MANAKPUR, YAMUNANAGAR vs. ITO, WARD 5, YAMUNANAGAR

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)

exemption u/s 10(37) of the Act. This admission clearly shows that the assumption made in the reasons recorded for reopening was not in accordance with the record.  Without prejudice to the above, it is submitted that after issuance of the notice u/s 148, reassessment proceedings were carried out in the normal course after obtaining the necessary approval

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

exemption u/s 10(37) of the Act. This admission clearly shows that the assumption made in the reasons recorded for reopening was not in accordance with the record.  Without prejudice to the above, it is submitted that after issuance of the notice u/s 148, reassessment proceedings were carried out in the normal course after obtaining the necessary approval

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)

exemption u/s 10(37) of the Act. This admission clearly shows that the assumption made in the reasons recorded for reopening was not in accordance with the record.  Without prejudice to the above, it is submitted that after issuance of the notice u/s 148, reassessment proceedings were carried out in the normal course after obtaining the necessary approval

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)

exemption u/s 10(37) of the Act. This admission clearly shows that the assumption made in the reasons recorded for reopening was not in accordance with the record.  Without prejudice to the above, it is submitted that after issuance of the notice u/s 148, reassessment proceedings were carried out in the normal course after obtaining the necessary approval