DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, LUDHIANA , LUDHIANA vs. HOMELIFE BUILDCON PVT. LTD., LUDHIANA

In the result, Revenue appeal is dismissed and appeal filed by the assessee is allowed

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 880/Chd/2024 निर्धारण वर्ष / Assessment Year : 2021-22 Homelife Buildcon Private Limited Sunview Enclave, Ayali Kalan, Ludhiana, Punjab-142027 स्थायी लेखा सं./PAN NO: AABCH5690M अपीलार्थी/Appellant The DCIT Central Circle-1 Ludhiana, Punjab प्रत्यर्थी/Respondent आयकर अपील सं. / ITA No. 1036/Chd/2024 निर्धारण वर्ष / Assessment Year : 2021-22 Homelife Buildcon Private Limited Sunview Enclave, Ayali Kalan, Lu

147 would defeat the very purpose of the amendment and open the floodgates to arbitrary assessments. 26. The relevant extract Memorandum explaining the finance bill is reproduced as under:- ‘(ii) Assessments or reassessments or in re-computation in cases where search is initiated under section 132 or requisition is made under 132A, after 31st March 2021, shall be under

HOMELIFE BUILDCON PRIVATE LIMITED,SUNVIEW ENCLAVE, AYALI KALAN, LUDHIANA,PUNJAB vs. SMT. SAMANDEEP KAUR DCIT-CENTRAL CIRCLE-1, LUDHIANA, PUNJAB

In the result, Revenue appeal is dismissed and appeal filed by the assessee is allowed

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 880/Chd/2024 निर्धारण वर्ष / Assessment Year : 2021-22 Homelife Buildcon Private Limited Sunview Enclave, Ayali Kalan, Ludhiana, Punjab-142027 स्थायी लेखा सं./PAN NO: AABCH5690M अपीलार्थी/Appellant बनाम The DCIT Central Circle-1 Ludhiana, Punjab प्रत्यर्थी/Respondent आयकर अपील सं. / ITA No. 1036/Chd/2024 निर्धारण वर्ष / Assessment Year : 2021-22 बनाम Homelife Buildcon Private Limited Sunview Enclave, Ayali

147 would defeat the very purpose of the amendment and open the floodgates to arbitrary assessments. 26. The relevant extract Memorandum explaining the finance bill is reproduced as under:- ‘(ii) Assessments or reassessments or in re-computation in cases where search is initiated under section 132 or requisition is made under 132A, after 31st March 2021, shall be under

M/S JAIN AMAR CLOTHING PVT. LTD.,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)

147, Section 148, Section 149, Section 151 and Section 153, in the case of a person where a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under section 132-A after the 31st day of May, 2003, the Assessing Officer shall— (a) issue notice to such person requiring him to furnish

DCIT, CC-3, LUDHIANA, KITCHLU NAGAR vs. MANI RAM BALWANT RAI HUF, CIVIL LINES

The appeal of the Revenue is dismissed

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

131(1A) of the Act. 1.4 Consequent to the search, the case was centralized under section 127 of the Act with the DCIT, Central Circle-3, Ludhiana. 2. Assessment Proceedings 2.1 During assessment proceedings, various queries were raised and duly replied to by the assessee. However, the Ld. Assessing Officer completed the assessment under section 143(3) vide order dated

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)

reassessment proceedings under Sections 147 and 148 of the IT Act. However, as noted above, all contentions of all parties are kept open in this context." 18. It has been contended that the Assessing Officer has wrongly made addition u/s 153A(l)(b) r.w.s. 143(3) of the Act ITA 3 &144/CHD/2023 A.Y. 2014-15 15 on the direction

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)

reassessment proceedings under Sections 147 and 148 of the IT Act. However, as noted above, all contentions of all parties are kept open in this context." 18. It has been contended that the Assessing Officer has wrongly made addition u/s 153A(l)(b) r.w.s. 143(3) of the Act ITA 3 &144/CHD/2023 A.Y. 2014-15 15 on the direction

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

131 of the Act were issued to 20 such persons but none responded. The A.O. held that having confronted with the evidence indicating sham transaction, the burden of proof shifted back on the assessee and heavy onus was cast on him under section 68 of the Act to prove his case beyond doubt by producing so called investors

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

131 of the Act were issued to 20 such persons but none responded. The A.O. held that having confronted with the evidence indicating sham transaction, the burden of proof shifted back on the assessee and heavy onus was cast on him under section 68 of the Act to prove his case beyond doubt by producing so called investors

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

131 of the Act were issued to 20 such persons but none responded. The A.O. held that having confronted with the evidence indicating sham transaction, the burden of proof shifted back on the assessee and heavy onus was cast on him under section 68 of the Act to prove his case beyond doubt by producing so called investors

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

131 of the Act were issued to 20 such persons but none responded. The A.O. held that having confronted with the evidence indicating sham transaction, the burden of proof shifted back on the assessee and heavy onus was cast on him under section 68 of the Act to prove his case beyond doubt by producing so called investors

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

131 of the Act were issued to 20 such persons but none responded. The A.O. held that having confronted with the evidence indicating sham transaction, the burden of proof shifted back on the assessee and heavy onus was cast on him under section 68 of the Act to prove his case beyond doubt by producing so called investors

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

131 of the Act were issued to 20 such persons but none responded. The A.O. held that having confronted with the evidence indicating sham transaction, the burden of proof shifted back on the assessee and heavy onus was cast on him under section 68 of the Act to prove his case beyond doubt by producing so called investors

SCOTT EDIL ADVANCE RESEARCH LABORATORIES AND EDUCATION LIMITED,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

reassess the income of the\nother person in accordance with the provisions of section 153A, if, that Assessing Officer\nis satisfied that the books of account or documents or assets seized or requisitioned have\na bearing on the determination of the total income of such other person for six assessment\nyears immediately preceding the assessment year relevant to the previous

M/S GANESH DASS HUF,SIRSA vs. PCIT, 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)

u/s 263 of the Act it is noted as under: “5.1. I have carefully examined the facts of the case and It is evident that the assessee has received interest on enhanced compensation during the assessment year under consideration which ought to be treated as "income from other sources" and should have been taxed accordingly, under the head "income from

SH. KASHMIR SINGH SANDHA,SIRSA vs. PCIT, 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)

u/s 263 of the Act it is noted as under: “5.1. I have carefully examined the facts of the case and It is evident that the assessee has received interest on enhanced compensation during the assessment year under consideration which ought to be treated as "income from other sources" and should have been taxed accordingly, under the head "income from

DHUNI CHAND HUF,SIRSA vs. PCIT, 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)

u/s 263 of the Act it is noted as under: “5.1. I have carefully examined the facts of the case and It is evident that the assessee has received interest on enhanced compensation during the assessment year under consideration which ought to be treated as "income from other sources" and should have been taxed accordingly, under the head "income from

SH. ARVAIL SINGH,SIRSA vs. PCIT, 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)

u/s 263 of the Act it is noted as under: “5.1. I have carefully examined the facts of the case and It is evident that the assessee has received interest on enhanced compensation during the assessment year under consideration which ought to be treated as "income from other sources" and should have been taxed accordingly, under the head "income from

SURJEET SINGH,SIRSA vs. PCIT, ROHTAK, 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)

u/s 263 of the Act it is noted as under: “5.1. I have carefully examined the facts of the case and It is evident that the assessee has received interest on enhanced compensation during the assessment year under consideration which ought to be treated as "income from other sources" and should have been taxed accordingly, under the head "income from

SH. PARAMJEET SINGH,SIRSA vs. PCIT, 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)

u/s 263 of the Act it is noted as under: “5.1. I have carefully examined the facts of the case and It is evident that the assessee has received interest on enhanced compensation during the assessment year under consideration which ought to be treated as "income from other sources" and should have been taxed accordingly, under the head "income from