SH. AKHIL JAIN,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the ground no

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

penny Stocks and LTCG earned thereon were bogus in nature. 4.9 Regarding assessee’s contention that no incriminating material was found during the course of search, the AO stated that the said contention is not tenable as the perusal of the contents mentioned at page no. 1 to 182 of Annexure - A seized from Locker no. 194, HDFC Bank shows

SH. ASHISH JAIN,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the ground no

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

penny Stocks and LTCG earned thereon were bogus in nature. 4.9 Regarding assessee’s contention that no incriminating material was found during the course of search, the AO stated that the said contention is not tenable as the perusal of the contents mentioned at page no. 1 to 182 of Annexure - A seized from Locker no. 194, HDFC Bank shows

SH. ASHISH JAIN,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the ground no

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

penny Stocks and LTCG earned thereon were bogus in nature. 4.9 Regarding assessee’s contention that no incriminating material was found during the course of search, the AO stated that the said contention is not tenable as the perusal of the contents mentioned at page no. 1 to 182 of Annexure - A seized from Locker no. 194, HDFC Bank shows

SH. BIPAN JAIN,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the ground no

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

penny Stocks and LTCG earned thereon were bogus in nature. 4.9 Regarding assessee’s contention that no incriminating material was found during the course of search, the AO stated that the said contention is not tenable as the perusal of the contents mentioned at page no. 1 to 182 of Annexure - A seized from Locker no. 194, HDFC Bank shows

SH. SANJAY SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-

reassessment, if any, relating to any assessment year falling within the period of six assessment years referred to in this section i.e. section 153A(1) pending on the date of initiation of search under section 132 or making of requisition under section 132A as the case may be, shall abate. It is further observed that apart from present nine appeals

SH. SANJAY SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-

reassessment, if any, relating to any assessment year falling within the period of six assessment years referred to in this section i.e. section 153A(1) pending on the date of initiation of search under section 132 or making of requisition under section 132A as the case may be, shall abate. It is further observed that apart from present nine appeals

SMT. AARTI SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-

reassessment, if any, relating to any assessment year falling within the period of six assessment years referred to in this section i.e. section 153A(1) pending on the date of initiation of search under section 132 or making of requisition under section 132A as the case may be, shall abate. It is further observed that apart from present nine appeals

SMT. AARTI SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-

reassessment, if any, relating to any assessment year falling within the period of six assessment years referred to in this section i.e. section 153A(1) pending on the date of initiation of search under section 132 or making of requisition under section 132A as the case may be, shall abate. It is further observed that apart from present nine appeals

SMT. AARTI SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-

reassessment, if any, relating to any assessment year falling within the period of six assessment years referred to in this section i.e. section 153A(1) pending on the date of initiation of search under section 132 or making of requisition under section 132A as the case may be, shall abate. It is further observed that apart from present nine appeals

SH. ANIKET SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-

reassessment, if any, relating to any assessment year falling within the period of six assessment years referred to in this section i.e. section 153A(1) pending on the date of initiation of search under section 132 or making of requisition under section 132A as the case may be, shall abate. It is further observed that apart from present nine appeals

SH. ANIKET SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-

reassessment, if any, relating to any assessment year falling within the period of six assessment years referred to in this section i.e. section 153A(1) pending on the date of initiation of search under section 132 or making of requisition under section 132A as the case may be, shall abate. It is further observed that apart from present nine appeals

SH. SANJAY SINGAL HUF,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-

reassessment, if any, relating to any assessment year falling within the period of six assessment years referred to in this section i.e. section 153A(1) pending on the date of initiation of search under section 132 or making of requisition under section 132A as the case may be, shall abate. It is further observed that apart from present nine appeals

SH. SANJAY SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-

reassessment, if any, relating to any assessment year falling within the period of six assessment years referred to in this section i.e. section 153A(1) pending on the date of initiation of search under section 132 or making of requisition under section 132A as the case may be, shall abate. It is further observed that apart from present nine appeals

RADHIKA GOEL,PARWANOO vs. DCIT, CC-II, CHANDIGARH

In the result, appeals of the assessee are allowed

reassess the total income of six assessment year in which such search was conducted or requisition was made. Further, reliance is placed on the case of CIT vs Sun Engg Works Ltd 198 ITR 297(SC), wherein the Hon'ble Apex Court has held that the proceedings u/s 147 are for the benefit of the revenue and not for benefit

RADHIKA GOEL,PARWANOO vs. DCIT, CC-II, CHANDIGARH

In the result, appeals of the assessee are allowed

reassess the total income of six assessment year in which such search was conducted or requisition was made. Further, reliance is placed on the case of CIT vs Sun Engg Works Ltd 198 ITR 297(SC), wherein the Hon'ble Apex Court has held that the proceedings u/s 147 are for the benefit of the revenue and not for benefit

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

penny stock and its claim for exemption of the Long Term Capital Gain is not a genuine one. The AO, accordingly, reopened the assessment. ITA 689/CHD/2024 A.Y. 2012-13 3 4. A perusal of the record would reveal that on 04.08.2009, assessee has purchased 2700 shares of Sarathi Dealers Pvt. Ltd. (SDPL) for a total consideration of Rs.10

ASTT. COMMISSIONER OF INCOME TAX, CIRCLE-4, LUDHIANA, AAYAKAR BHAWAN vs. WARYAM STEEL CASTING PRIVATE LIMITED, KANGANWAL ROAD

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

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

147, computing the total income at Rs. 4,73,64,687/- by disallowing purchases deemed bogus. 3.1 The AO found that M/s Gauri Shankar Trading Co. (GSTC) was a fraudulent entity with no actual business, based on investigations by the DGGI, GST Intelligence, Delhi Zone, and the Income Tax Department’s Investigation Wing. Rahul Pratap Singh, the proprietor of GSTC

WARYAM STEEL CASTINGS PRIVATE LIMITED,LUDHIANA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-4, LUDHIANA

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

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

147, computing the total income at Rs. 4,73,64,687/- by disallowing purchases deemed bogus. 3.1 The AO found that M/s Gauri Shankar Trading Co. (GSTC) was a fraudulent entity with no actual business, based on investigations by the DGGI, GST Intelligence, Delhi Zone, and the Income Tax Department’s Investigation Wing. Rahul Pratap Singh, the proprietor of GSTC