DCIT, CC-I, LUDHIANA vs. OSWAL POLYCOT (INDIA) PVT. LTD., LUDHIANA

In the result, the appeal of the assessee in ITA No

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

153C as amended by Finance (No. 2) Act 2014 w.e.f 01/10/2014 as relevant for the impugned assessment year read as under: “1. Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153 where the AO is satisfied that any money, bullion, jewellery or other valuable article or things or books of account

OSWAL POLYCOT (INDIA) PVT. LTD.,LUDHIANA vs. DCIT, CC-I, LUDHIANA

In the result, the appeal of the assessee in ITA No

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

153C as amended by Finance (No. 2) Act 2014 w.e.f 01/10/2014 as relevant for the impugned assessment year read as under: “1. Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153 where the AO is satisfied that any money, bullion, jewellery or other valuable article or things or books of account

OSWAL POLYCOT (INDIA) PVT. LTD.,LUDHIANA vs. DCIT, CC-I, LUDHIANA

In the result, the appeal of the assessee in ITA No

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

153C as amended by Finance (No. 2) Act 2014 w.e.f 01/10/2014 as relevant for the impugned assessment year read as under: “1. Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153 where the AO is satisfied that any money, bullion, jewellery or other valuable article or things or books of account

DCIT, CC-I, LUDHIANA vs. OSWAL POLYCOT (INDIA) PVT. LTD., LUDHIANA

In the result, the appeal of the assessee in ITA No

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

153C as amended by Finance (No. 2) Act 2014 w.e.f 01/10/2014 as relevant for the impugned assessment year read as under: “1. Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153 where the AO is satisfied that any money, bullion, jewellery or other valuable article or things or books of account

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 as amended by Finance Act, 2021 read with explanation 2 of section 148 thereto. The relevant extract of explanation 2 is reproduced below “Explanation 2.—For the purposes of this section, where, — (i) a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under section 132A, on or after

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 as amended by Finance Act, 2021 read with explanation 2 of section 148 thereto. The relevant extract of explanation 2 is reproduced below “Explanation 2.—For the purposes of this section, where, — (i) a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under section 132A, on or after

SHRI RAKESH KUMAR KATARIA,CHANDIGARH vs. DCIT-CC-1, CHANDIGARH

In the result, appeal is allowed as indicated

Bench: Shri A.D. Jain & Shri Vikram Singh Yadavआयकर अपील सं./ Ita No. 159/Chd/2020 "नधा"रण वष" / Assessment Year : 2012-13 Shri Rakesh Kumar Kataria Vs. The Dcit, Central Circle, बनाम Chandigarh Sco 862, Prop. Subhinfra, Ist Floor, Nac, Manimajra, Chandigarh "थायी लेखा सं./Pan No: Aespk5238A अपीलाथ"/Appellant ""यथ"/Respondent "नधा"रती क" ओर से/Assessee By : Sh. Parikshit Aggarwal, Ca राज"व क" ओर से/ Revenue By : Shri Dharamvir, Jcit, Sr. Dr सुनवाई क" तार"ख/Date Of Hearing : 05.03.2024 उदघोषणा क" तार"ख/Date Of Pronouncement : 15.04.2024 आदेश/Order

reassessment, if any, has been made. 5.2 The ld. DR has further contended that in this case, the Assessee filed his return of income on 18.03.2013 and notice u/s 143(2) of the Act was issued on 07.08.2013, and that therefore, notice u/s 153C of the Act was neither called for, nor issued. 5.3 The ld. DR has further contended

SCOTT EDIL PHARMACIA LTD.,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

2. This position has been reiterated by Hon’ble Delhi High Court in the case of “Pr. CIT\nVs. Best Infrastructure(India) Pvt. Ltd.”, 397 ITR 182 (Delhi.), by observing in para 38\nof the said order that statements recorded under Section 132(4) of the Act of the Act do\nnot by themselves constitute incriminating material as has been

SCOTT EDIL PHARMACIA LTD.,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

2. This position has been reiterated by Hon’ble Delhi High Court in the case of “Pr. CIT\nVs. Best Infrastructure(India) Pvt. Ltd.”, 397 ITR 182 (Delhi.), by observing in para 38\nof the said order that statements recorded under Section 132(4) of the Act of the Act do\nnot by themselves constitute incriminating material as has been

SCOTT EDIL PHARMACIA LTD.,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

2. This position has been reiterated by Hon’ble Delhi High Court in the case of “Pr. CIT\nVs. Best Infrastructure(India) Pvt. Ltd.”, 397 ITR 182 (Delhi.), by observing in para 38\nof the said order that statements recorded under Section 132(4) of the Act of the Act do\nnot by themselves constitute incriminating material as has been

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-I, CHANDIGARH , CHANDIGARH vs. MS SCOTT EDIL ADVANCE RESEARCH LABORATOTRIES AND EDUCATION LTD., , CHANDIGARH

2. This position has been reiterated by Hon’ble Delhi High Court in the case of “Pr. CIT\nVs. Best Infrastructure(India) Pvt. Ltd.”, 397 ITR 182 (Delhi.), by observing in para 38\nof the said order that statements recorded under Section 132(4) of the Act of the Act do\nnot by themselves constitute incriminating material as has been

SHRI BALRAM KRISHAN,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH, 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

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

2. This position has been reiterated by Hon’ble Delhi High Court in the case of “Pr. CIT\nVs. Best Infrastructure(India) Pvt. Ltd.”, 397 ITR 182 (Delhi.), by observing in para 38\nof the said order that statements recorded under Section 132(4) of the Act of the Act do\nnot by themselves constitute incriminating material as has been

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

SCOTT EDIL PHARMACIA LTD.,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

SHRI BALRAM KRISHAN,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH, CHANDIGARH

2. This position has been reiterated by Hon’ble Delhi High Court in the case of “Pr. CIT\nVs. Best Infrastructure(India) Pvt. Ltd.”, 397 ITR 182 (Delhi.), by observing in para 38\nof the said order that statements recorded under Section 132(4) of the Act of the Act do\nnot by themselves constitute incriminating material as has been

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

2. This position has been reiterated by Hon’ble Delhi High Court in the case of “Pr. CIT\nVs. Best Infrastructure(India) Pvt. Ltd.”, 397 ITR 182 (Delhi.), by observing in para 38\nof the said order that statements recorded under Section 132(4) of the Act of the Act do\nnot by themselves constitute incriminating material as has been

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

2. This position has been reiterated by Hon’ble Delhi High Court in the case of “Pr. CIT\nVs. Best Infrastructure(India) Pvt. Ltd.”, 397 ITR 182 (Delhi.), by observing in para 38\nof the said order that statements recorded under Section 132(4) of the Act of the Act do\nnot by themselves constitute incriminating material as has been

SHRI BALRAM KRISHAN,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH, CHANDIGARH

2. This position has been reiterated by Hon’ble Delhi High Court in the case of “Pr. CIT\nVs. Best Infrastructure(India) Pvt. Ltd.”, 397 ITR 182 (Delhi.), by observing in para 38\nof the said order that statements recorded under Section 132(4) of the Act of the Act do\nnot by themselves constitute incriminating material as has been