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 passed\nu/s 147 r.w.s 144 r.w.s 1448 dated 26.03.2022 which\nis sought to be revised u/s 263 itself was invalid inter\nalia on various grounds as mentioned below and thus\nproceedings initiated u/s 263 against the invalid\nreassessment order is clearly bad in law, which were\nsummarily rejected. a) That notice_u/s 148 is timе\nbarred

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

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

144 r.w.s 1448 dated 26.03.2022 which is sought to be revised u/s 263 itself was invalid inter alia on various grounds as mentioned below and thus proceedings initiated u/s 263 against the invalid reassessment order is clearly bad in law, which were summarily rejected. a) That notice_u/s 148 is timе barred. b) The reason has been recorded on Incorrect

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

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

In the result, appeal of the assessee is allowed

section 144 r.w.s 147 of the Act and made the addition of Rs. 35,01,000/-. 5. Being aggrieved the assessee carried the matter to the Ld. CIT(A) and furnished the written submission which reads as under: This is the case of assessee, individual, NRI residing in Surrey, Canada. Case was reopened u/s 147 of the Act, notice

AJAY TANTA,SHIMLA vs. INCOME TAX OFFICER, SHIMLA

In the result, appeal of the assessee is allowed

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

147 r.w.s 144 of the Income tax Act and without complying with the mandatory conditions u/s 147/144 as envisaged under the Income Tax Act, 1961 3. That having regard to the facts and circumstances of the case, Hon'ble CIT (A) has erred in law and on facts in confirming the action of Ld. AO without considering the fact that

ABHIMANYU GUPTA ,PATIALA vs. DY. COMMISSIONER OF INCOME TAX, CIRCLE-PATIALA , PATIALA

In the result, the appeal of the assessee is allowed

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

144 read with section 144B of the Act without satisfying the statutory pre-conditions required for initiation of proceedings and upholding of assessment is illegal, arbitrary and unjustified. 3. That the learned Commissioner of Income Tax (Appeals) has failed to appreciate that there was no tangible material on record that income of the appellant had escaped assessment which is based

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)

144 (25% of 16,85,84,575)] is escaped income of the assessee. Further in case other unexplained income of the assessee comes to light during the course of assessment proceedings, then such unexplained income will be added to the total assessed income at the culmination of assessment proceedings. Considering the factual matrix, statutory provisions and legal principles, the undersigned

ANAND SAWROOP,HIMACHAL PRADESH vs. INCOME TAX OFFICER , NAHAN

In the result, the appeal of the assessee is partly allowed

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

reassessment order u/s 147 cannot be passed without compliance with the mandatory requirement of notice u/s 143(2) of the Act. No contrary authority including that of the jurisdictional Himachal Pradesh High Court has been brought to our notice. 10. Further, we agree with the contention of the ld AR that the provisions of section 292BB doesn’t come

SIKANDER SINGH MALUKA,MOHALI vs. ITO, MOHALI

In the result, the appeal of the assessee is allowed for

Bench: Shri Sanjay Garg & Ms. Annapurna Guptathe I.T.O., Vs. Sh.Sikandar Singh Maluka, Ward 5(1), # 1370, Sector 40-B, Chandigarh. Chandigarh Pan: Abzpm7206N & Sh.Sikandar Singh Maluka, Vs. The I.T.O., # 1370, Sector 40-B, Ward 5(2), Chandigarh. Chandigarh Pan: Abzpm7206N

144 ITD 528. 3. Aggrieved by the same, the assessee has come up in appeal before us in ITA No.633/Chd/2017 challenging the action of the Ld.CIT(Appeals) in upholding the validity of the assessment framed u/s 147 of the Act, raising the following grounds before us: ““1. That the order passed by the Learned CIT(A) is bad, against

SADHU RAM GUPTA,DHURI, SANGRUR vs. ITO, WARD-1, MALERKOTLA, PUNJAB

In the result, both the appeals are allowed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita Nos. 873 & 874/Chd/2025 "नधा"रण वष" / A.Y. : 2017-18 & 2020-21 Shri Sadhu Ram Gupta, The Ito, House No. 263, W.No. 15B, Vs Ward-1, Sangrur, Tehsil Mohalla Dhuri, Malerkotla. Sangrur. "थायी लेखा सं./Pan No: Addpg0223H अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Parikshit Aggarwal, Ca Revenue By : Dr. Ranjit Kaur, Addl. Cit Sr.Dr Date Of Hearing : 23.07.2025 & 21.07.2025 Date Of Pronouncement : 12.08.2025 Physical Hearing O R D E R Per Rajpal Yadav, Vp

144 read with Section 147 of the Income Tax Act. b) The ld. CIT (Appeals) has erred in confirming the addition of Rs.87,34,000/- and Rs.34,00,000/- in assessment year 2017-18 and 2020-21 respectively. 3. The facts on all vital points are common in both the years. For the facility of reference, we take the facts

SADHU RAM GUPTA,DHURI, SANGRUR vs. ITO, WARD-1, MALERKOTLA, PUNJAB

In the result, both the appeals are allowed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita Nos. 873 & 874/Chd/2025 "नधा"रण वष" / A.Y. : 2017-18 & 2020-21 Shri Sadhu Ram Gupta, The Ito, House No. 263, W.No. 15B, Vs Ward-1, Sangrur, Tehsil Mohalla Dhuri, Malerkotla. Sangrur. "थायी लेखा सं./Pan No: Addpg0223H अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Parikshit Aggarwal, Ca Revenue By : Dr. Ranjit Kaur, Addl. Cit Sr.Dr Date Of Hearing : 23.07.2025 & 21.07.2025 Date Of Pronouncement : 12.08.2025 Physical Hearing O R D E R Per Rajpal Yadav, Vp

144 read with Section 147 of the Income Tax Act. b) The ld. CIT (Appeals) has erred in confirming the addition of Rs.87,34,000/- and Rs.34,00,000/- in assessment year 2017-18 and 2020-21 respectively. 3. The facts on all vital points are common in both the years. For the facility of reference, we take the facts

SH. SATNAM SINGH,MOHALI vs. ITO, WARD 6(4), MOHALI

In the result, both the appeals of the Assessee are allowed

Bench: Shri Mahavir Singh & Shri Krinwant Sahay

144 read with section 147 of the Act dated 25.11.2019. The ld. Counsel for the Assessee stated once one live proceeding is pending for any relevant assessment year in consequent to reopening notice u/s 148 of the Act, a second reopening notice till that valid assessment is pending cannot be issued. This is invalid and illegal. For this

SH. SATNAM SINGH,MOHALI vs. ITO, WARD 6(1), MOHALI

In the result, both the appeals of the Assessee are allowed

Bench: Shri Mahavir Singh & Shri Krinwant Sahay

144 read with section 147 of the Act dated 25.11.2019. The ld. Counsel for the Assessee stated once one live proceeding is pending for any relevant assessment year in consequent to reopening notice u/s 148 of the Act, a second reopening notice till that valid assessment is pending cannot be issued. This is invalid and illegal. For this

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

In the result appeal filed by the Assessee is allowed

144 of the Act is not sustainable in law as the no notice under section 148 of the Act was served upon the assessee. However, the Ld. CIT(A) rejected the contention of the assessee and dismissed the appeal filed by the assessee. Against the said findings of the Ld. CIT(A) the assessee has preferred the present appeal

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)

section 147 of the Act. Further, he relied on the orders of the lower authorities. 9. We have heard the rival contentions and purused the material available on record. In the instant case, the action of the AO in acquiring jurisdiction u/s 147 has been challenged by the assessee on two counts. Firstly, it has been contended that

SH.RANDHIR SINGH,MOHALI vs. PR.CIT-1, CHANDIGARH

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

144 r.w.s 143(3) of the Income Tax Act, 1961 was completed on 06.12.2017 and income was assessed at Rs. 42,18,780/- by making an addition of Rs. 39,00,000/-. During appellate proceedings it has been claimed that the assessment framedby the Assessing Officer is erroneous in that notice u/s 143(2) has not been issued tothe assessee

INCOME TAX OFFIER, WARD 6(1), LUDHIANA vs. BALPREET SINGH, LUDHIANA

In the result, the appeal of the Revenue is allowed for statistical purposes

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

u/s 69A as the assessee had failed to furnish any explanation and prove the genuineness and credit worthiness of credits of Rs.33,07,37,215/- in bank accounts during the assessment proceedings. 5) That, reliance is placed on the judgement of Hon'ble High Court of Gujarat at Ahmedabad in the case of Principal Commissioner of Income

BANSAL RICE TRADERS,SANGRUR vs. ITO-WARD, SANGRUR

In the result, appeal of the assessee is allowed

144 of the Act. 6. Now the assessee is in appeal. 7. The Ld. Counsel for the assessee drew our attention towards page no. 4 of the assessee’s paper book which is the copy of the reason recorded by the A.O. for issuing the notice under section 148 of the Act and read as under: Reasons for issue notice

KUSUM MITTAL,SANGRUR vs. INCOME TAX OFFICER, WARD - SANGRUR, SANGRUR

In the result, the appeal of the assessee is allowed

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

144 of the Act without satisfying the statutory pre-conditions required for initiation of proceedings and completion of assessment and as such, the same are without jurisdiction and hence deserve to be quashed as such. 4. That the Ld. Commissioner of Income Tax (Appeals) has failed to appreciate that there was no tangible material on record to form a "reason