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 148 of the I.T. Act on 10.02.2020. Thus, the notice was issued by the AO within four years from the end of the relevant assessment year and, therefore, the first Proviso to section 147 of the I.T. Act is not attracted in this case. 5.8 Section 147 of the Income Tax Act is reproduced as under:- Income escaping assessment

DEPUTY COMMISSIONER OF INCOME TAX, CHANDIGARH vs. WINSOME TEXTILE INDUSTRIES LTD, CHANDIGARH

reassessment proceedings under section 147 vide letter dt.\n19/12/2018 which were disposed off by the AO by passing a separate order dt.\n19/12/2018. Thereafter, after issuance of notice under section 143(2) and 142(1)\nand after calling for necessary information and documentation as well as issue\nof specific show cause notice, the AO made an addition of Rs.82

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

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

In the result, the ground no

Bench: SHRI. SANJAY GARG (Judicial Member), 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

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)

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

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)

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

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)

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

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)

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

EXOTIC REALTORS AND DEVELOPERS,CHANDIGARH vs. PR.CIT-1, CHANDIGARH

In the result, appeal of the assessee is allowed

Bench: SHRI. KRINWANT SAHAY (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

u/s. 263 of the Act issued by the Pr. CIT is vague and only for making deeper enquiry and re-considering the evidences already on record duly considered during assessment proceedings based on purported proposal that fresh facts have been emerged subsequent to the order of assessment which is factually incorrect and untenable and the conditions or the factors enabling

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

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

section 263 for the first time in the above order.\nOtherwise also the adequate inquiry/Verifications have\nbeen made as required for reassessment u/s 147 of the\nIT Act. Hence the order of PCIT should be set aside.\n7.\nWithout prejudice to above ground of appeal, that\nhaving regard to facts & circumstances of the case. Ld.\nPr.CIT has erred

S.P. SINGLA CONSTRUCTION PRIVATE LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CHANDIGARH

In the result, the appeal is allowed

Bench: SHRI MAHAVIR SINGH (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

u/s 148 is being obtained separately from the Pr. Commissioner of Income tax-8, New Delhi as per the provisions of the section 151(2) of the Income Tax Act, 1961.” 9. In view of the above reasons, ld. Counsel for the assessee stated that the only charge of the AO in the reasons recorded is that the assessee

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

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

section 263 for the first time in the above order. Otherwise also the adequate inquiry/Verifications have been made as required for reassessment u/s 147 of the IT Act. Hence the order of PCIT should be set aside.\n\n7.\nWithout prejudice to above ground of appeal, that having regard to facts & circumstances of the case. Ld. Pr.CIT has erred

SHRI DINESH SETHI,LUDHIANA vs. ITO, LUDHIANA

The appeals are dismissed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 376/Chd/2014 & "नधा"रण वष" / Assessment Year : 2006-07 Shri Janesh Sethi, Legal Heir Of बनाम The Ito, Late Shri Dinesh Sethi, Ward – 1(1), Vs Prop. M/S R.S. Trading Corp., Ludhiana. C-434, Urban Estate Focal Point, Ludhiana. "थायी लेखा सं./Pan /Tan No: Aaqpk1200Q 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 तार"ख/Date Of Hearing : 23.06.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 04.8.2025

147(a) of the Act. 3.8 Keeping in view the aforesaid facts and circumstances of the case the AO was fully justified in issuing notice u/s 148. These grounds of appeal are accordingly dismissed.” 7.1 The ld. counsel for the assessee has filed a brief synopsis apart from advancing arguments in the Court. His brief synopsis read as under: “1

SH. DINESH SETHI,LUDHIANA vs. ITO, LUDHIANA

The appeals are dismissed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 376/Chd/2014 & "नधा"रण वष" / Assessment Year : 2006-07 Shri Janesh Sethi, Legal Heir Of बनाम The Ito, Late Shri Dinesh Sethi, Ward – 1(1), Vs Prop. M/S R.S. Trading Corp., Ludhiana. C-434, Urban Estate Focal Point, Ludhiana. "थायी लेखा सं./Pan /Tan No: Aaqpk1200Q 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 तार"ख/Date Of Hearing : 23.06.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 04.8.2025

147(a) of the Act. 3.8 Keeping in view the aforesaid facts and circumstances of the case the AO was fully justified in issuing notice u/s 148. These grounds of appeal are accordingly dismissed.” 7.1 The ld. counsel for the assessee has filed a brief synopsis apart from advancing arguments in the Court. His brief synopsis read as under: “1

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 order so passed u/s 147 r/w 144B read as under: "1. The case has been re-opened on the issue for verification of the claim of deduction u/s 80IC of the IT act 1961 of @100%. Notice u/s 148 of the I. T. Act dated 30/03/2021 has been issued and served to the assessee. The assessee has filed return

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2,, LUDHIANA vs. AB ALCOBEV PRIVATE LIMITED, DELHI

In the result, appeals of Revenue are dismissed, Cross\nObjections of the assessee for

142(1) of I.T. Act.\n12. 28.09.2021\nShow Cause for proposed addition vide order sheet dt. 28/09/20211\n13. 30.09.2021\nReply filed and inter-alia stated that to confront the relevant documents\nfor proposed addition.\n14. 30.09.2021\nApproval u/s 153D granted by the JCIT.\n15. 30.09.2021\nAssessment order framed u/s 153A r.w.s.144 of LT. Act, without\nconfronting any material for proposed

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2, LUDHIANA , LUDHIANA vs. AB ALCOBEV PRIVATE LIMITED, DELHI

In the result, appeals of Revenue are dismissed, Cross\nObjections of the assessee for

142(1) of I.T. Act.\n12. 28.09.2021\nShow Cause for proposed addition vide order sheet dt. 28/09/20211\n13. 30.09.2021\nReply filed and inter-alia stated that to confront the relevant documents\nfor proposed addition.\n14. 30.09.2021\nApproval u/s 153D granted by the JCIT.\n15. 30.09.2021\nAssessment order framed u/s 153A r.w.s.144 of LT. Act, without\nconfronting any material for proposed

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2, LUDHIANA vs. AB ALCOBEV PRIVATE LIMITED, DELHI

In the result, appeals of Revenue are dismissed, Cross\nObjections of the assessee for

142(1) of I.T. Act.\n13. 30.09.2021\nShow Cause for proposed addition vide order sheet dt. 28/09/20211\n14. 30.09.2021\nReply filed and inter-alia stated that to confront the relevant documents\nfor proposed addition.\n15. 30.09.2021\nApproval u/s 153D granted by the JCIT.\n16. 30.09.2021\nAssessment order framed u/s 153A r.w.s.144 of LT. Act, without\nconfronting any material for proposed

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2 LUDHIANA, LUDHIANA vs. AB ALCOBEV PRIVATE LIMITED , DELHI

In the result, appeals of Revenue are dismissed, Cross\nObjections of the assessee for

142(1) of I.T. Act.\n12. 28.09.2021\nShow Cause for proposed addition vide order sheet dt. 28/09/20211\n13. 30.09.2021\nReply filed and inter-alia stated that to confront the relevant documents\nfor proposed addition.\n14. 30.09.2021\nApproval u/s 153D granted by the JCIT.\n15. 30.09.2021\nAssessment order framed u/s 153A r.w.s.144 of LT. Act, without\nconfronting any material for proposed