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

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

147 r.w.s 144B dated 26.03.2022 in the proceeding\nu/s 263 of the IT Act on the basis that explanation 2(a)\nto Section 203(1) supersede all other legal\nconsideration. no appeal against said order filed and\nany other statutory instrument or medium not\nundertaken and no objection raised earlier.\n3.\nThat having regard to the facts and circumstances

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

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

147 r.w.s 144B dated 26.03.2022 in the proceeding u/s 263 of the IT Act on the basis that explanation 2(a) to Section 203(1) supersede all other legal consideration. no appeal against said order filed and any other statutory instrument or medium not undertaken and no objection raised earlier.\n\n3.\nThat having regard to the facts and circumstances

JASPREET SINGH SIDHU,CHANDIGARH vs. PRINCIPAL COMMISSIONER OF INCOME TAX-1, CHANDIGARH

In the result, the appeal is allowed

Bench: Shri A.D. Jain & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 335/Chd/2024 "नधा"रण वष" / Assessment Year : 2016-17 Jaspreet Singh Sidhu, Vs. The Pcit-1, बनाम Cr Building, Sector 17, H. No. 1656, Sector 33-D, Chandigarh Chandigarh "थायी लेखा सं./Pan No: Bykps6091L अपीलाथ"/ Appellant ""यथ"/ Repsondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : Shri Parikshit Aggarwal, Ca राज"व क" ओर से/ Revenue By : Shri Rohit Sharma, Cit Dr

reassessment order. May I request your honour to kindly drop proceedings under section 263 of the act on this count itself. I would not like to burden record of your honour by submitting further judicial precedents, if your honour wishes, I would be pleased to. Please kindly convey. xvi. Further as the return of income filed by me the accepted

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

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)

144B of the Act. 4. Against the order of the AO the assessee went in appeal before the Ld. CIT(A), Before the Ld. CIT(A) the assessee contended that the addition was based on mere conjectures, third-party statements, and "dumb documents" seized from third parties without providing an opportunity for cross-examination. However, the Ld. CIT(A) upheld

MASTER TRUST LIMITED,LUDHIANA vs. ASSISTANT COMMISSIONER OF INCOME TAX, LUDHIANA

In the result, ground no. 1 of the assessee’s appeal is allowed

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

u/s 147 were thereafter initiated and notice under section 148 was issued on 30/03/2021 after seeking approval from JCIT Range-1, Ludhiana in terms of Section 151 of the Act. In response to the notice under section 148 dt. 30/03/2021, the assessee filed return of income on 28/04/2021 declaring total income of Rs. 54,81,240/- thereafter notice under section

INCOME TAX OFFICER, YAMUNA NAGAR vs. RAJESH KHANNA, YAMUNA NAGAR

In the result, the assessee's appeal in ITA

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

147 of the Act. Order under sub-section (d) of section 148A of the Act has been passed in such case vide DIN ITBA/AST/F/148A/2021-22/1042149336(1) dated 30/03/2022 and annexed herewith for reference. 2. I, therefore, propose to assess or reassess such income or recompute the loss or the depreciation allowance or any other, allowance or deduction for the Assessment Year

RAJESH KHANNA,NEELKANTH PLYWOOD, YAMUNANAGAR vs. INCOME TAX OFFICER, WARD-3, INCOME TAX OFFICER, YAMUNANAGAR

In the result, the assessee's appeal in ITA

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

147 of the Act. Order under sub-section (d) of section 148A of the Act has been passed in such case vide DIN ITBA/AST/F/148A/2021-22/1042149336(1) dated 30/03/2022 and annexed herewith for reference. 2. I, therefore, propose to assess or reassess such income or recompute the loss or the depreciation allowance or any other, allowance or deduction for the Assessment Year

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)

u/s 148 A were initiated is based only on borrowed information without application of mind much less independent application of mind and hence untenable. 8. That without prejudice to the above, the Ld. Commissioner of Income Tax(Appeals) has erred in upholding the addition of Rs.46.50,000- made on aecount of alleged absence of source of purchase of immovable property

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)

144B, thereby rendering the notices and proceedings issued by the Department illegal and unsustainable. 2. That the Worthy CIT (A-5), Ludhiana has rightly deleted the addition u/s 28 of the Income Tax Act, 1961 to the tune of Rs. 4,39,57,405/- on account of alleged Gross profit on alleged unaccounted sale. Further that the addition sustained

BHUSHAN KUMAR,KHANAURI vs. INCOME TAX OFFICER, SUNAM, SANGRUR

In the result, the appeal of the Assessee stands allowed for statistical purposes

144B without complying the specific provisions with regard to issue of show cause notice and draft order. No response to show cause considered during the assessment proceedings.\n5. That notice u/s 148 was wrongly issued with regard to quantum of escapement. The information received pertains to escapement amount of Rs.88

MANDEEP KAUR,FATEHABAD vs. ITO, WARD - 1, FATEHABAD

The appeal stand allowed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No.630/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2016-17) Ms. Mandeep Kaur Ito Ward -1 बनाम/ Vs. Vpo Museh Ali Hizrawan, Khurd, To Fatehabad Rohtak - 124001 Fatehabad, Haryana – 125050 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Datpk-9813-D (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Mukesh Kumar Jain (Ca) – Ld. Ar (Virtual) ""थ"कीओरसे/Respondent By : Sh. Dr. Ranjit Kaur (Addl. Cit) – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 10.02.2026 घोषणाकीतारीख /Date Of Pronouncement : 16.02.2026 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2016- 17 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), Nfac [Cit(A)] Dated 17-02-2025 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S 147 R.W.S. 144Of The Act On30-04-2023. 2. The Ld. Ar, At The Outset, Urged Legal Ground No.4 To Assail The Jurisdiction Of Ld. Ao. In This Ground Of Appeal, It Has Been Pleaded That The Order Passed U/S 148A(D) As Well As Issue Of Notice U/S 148

Section 151(ii) of the Act. We have noted that in the present case notice u/s 148 dated 16.07.2022 was issued with the prior approval of Pr. CIT. Accordingly, the impugned notice is not supported by authority of law and hence, hereby quashed. The consequent assessment order u/s 147 r.w.s. 144B dated 29.05.2023 would also not survive. The ground

ANUP KUMAR AGGARWAL,PANCHKULA vs. ACIT(CENTRAL) SHIMLA, SHIMLA

Appeal stand allowed in terms of our above order

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No.1019/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2021-22) Sh. Anup Kumar Aggarwal Acit (Central) बनाम/ Vs. House No.218,Sector-10 Shimla 171001 Panchkula – 134113 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Adjpk-5842-L (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Ajay Jain (Ca) A/W Shri Lovesh Bansal (Ca) – Ld. Ars ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 15-09-2025 घोषणाकीतारीख /Date Of Pronouncement : 24/11/2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2021-22 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals)-3, Gurgaon [Cit(A)] Dated 31-07-2025 In The Matter Of An Assessment Framed By Ld. Ao U/S 147 Of The Act On 12-03-2025. The Assessee Is Aggrieved By Confirmation Of Additions Of Rs.10.95 Lacs U/S 69 & Another Addition Of Rs.16.21 Lacs U/S 69A. The Additions Stem From Search Action By The Department On Assessee-Group On 04-

147 or for issuance of notice under section 148A and for conducting a prior enquiry by issuance of a show-cause notice or passing order under section 148A of the Act. The provisions is intended with an object of achieving efficiency, transparency and accountability inter alia by eliminating the interface between the income tax authority, optimizing utilization of the resources

ANUP KUMAR AGGARWAL,PANCHKULA vs. ACIT(CENTRAL) SHIMLA, SHIMLA

Appeal stand allowed in terms of our above order

Bench: SHRI RAJPAL YADAV (Vice President), SHRI MANOJ KUMAR AGGARWAL (Accountant Member)

147 or for issuance of notice under section 148A and for conducting a prior enquiry by issuance of a show-cause notice or passing order under section 148A of the Act. The provisions is intended with an object of achieving efficiency, transparency and accountability inter alia by eliminating the interface between the income tax authority, optimizing utilization of the resources

POOJA AGGARWAL,PANCHKULA vs. ACIT(CENTRAL) SHIMLA, SHIMLA

Appeal stand allowed in terms of our above order

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No.1026/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2021-22) Ms. Pooja Aggarwal Acit Central बनाम/ Vs. House No.218,Sector-10 Shimla 171001 Panchkula – 134113 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Abnpa-6660-N (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Ajay Jain (Ca)A/W Shri Lovesh Bansal (Ca) – Ld. Ars ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 15-09-2025 घोषणाकीतारीख /Date Of Pronouncement : 24/11/2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2021-22 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals)-3, Gurgaon [Cit(A)] Dated 31-07-2025 In The Matter Of An Assessment Framed By Ld. Ao U/S 147 Of The Act On 12-03-2025. The Assessee Is Aggrieved By Confirmation Of Substantive Addition Of Rs.16.21 Lacs & Protective Addition Of Rs.10.95 Lacs. The Additions Stem From Search Action By The Department On Assessee-Group On 04-

147 or for issuance of notice under section 148A and for conducting a prior enquiry by issuance of a show-cause notice or passing order under section 148A of the Act. The provisions is intended with an object of achieving efficiency, transparency and accountability inter alia by eliminating the interface between the income tax authority, optimizing utilization of the resources

DCIT, CIRCLE-I, LUDHIANA, LUDHIANA vs. FINDOC INVESTMENT PRIVATE LIMITED, LUDHIANA

In the result, appeal is dismissed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 863/Chd/2024 "नधा"रण वष" / Assessment Year: 2015-16 The Dcit, Vs M/S Findoc Investment Pvt.Ltd., Circle-1, 4Th Floor, Kartar Bhawan, Ludhiana. Ferozepur Road, Ludhiana. "थायी लेखा सं./Pan No: Aabcf8332L अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ashwani Kumar & Shri Aditya Kumar, Cas Revenue By : Shri Manav Bansal, Cit, Dr Date Of Hearing : 07.05.2025 Date Of Pronouncement : 23.06.2025 Physical Hearing O R D E R

u/s. 148 and re-assessment proceedings 7. In Ground of Appeal Nos. 1, 2, 3, 5 and the amended ground (in the place of Grounds No. 1 and 2), the appellant contended that the entire reopening and assessment process is against the provisions and intent of the law. According to the appellant, the impugned assessment was framed on wrong

GURJIT SINGH,ROPAR vs. INCOME TAX OFFICER, RUPNAGAR

Appeal stand allowed accordingly

Bench: Tribunal.

u/s 148 by Jurisdictional Assessing Officer (JAO) instead of Faceless Assessing Officer (FAO) would vitiate the entire assessment proceedings. The substantive portion of this decision read as under: - 15. From the perusal of Section 151A, it is quite evident that scheme of faceless assessment is applicable from the stage of show cause notice under Section 148 as well as 148A

SH. JAI PRAKASH,MORINDA vs. INCOME TAX OFFICER, WARD 2(2), ROPAR

In the result, the appeal is partly allowed, with the following directions:

Bench: SHRI. LALIET KUMAR (Judicial Member)

section 147. The Assessing Officer framed reassessment on 31.03.2022 u/s 147 r.w.s. 144B, making an addition of Rs.21,50,000 u/s

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