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

192.\nb) Winsome Textile Industries Vs. Union of India 278 ITR 470.\nc) Navkar share and stock brokers Vs. ACIT 390 ITR 362 &\nd) Haryana Acrylics Manufacturing company Vs. CIT 308 ITR 38\nii) That it is relevant to point out that after initiation of the reassessment\nproceedings, a notice was issued U/s 142(1) was issued on 4th July

DCIT, CENTRAL CIRCLE II, CHANDIGARH vs. M/S SAB UDYOG LIMITED, CHANDIGARH

In the result, both the appeals of the Revenue are hereby dismissed

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

147 on that very ground would mean nothing else but the abuse of process of law. Hence, the contention of the learned DR that as the return was processed u/s. 143(1) and it was a mere intimation hence, the AO had reason to believe that income had escaped assessment and it was open to the AO to reassess

DCIT, CENTRAL CIRCLE II, CHANDIGARH vs. M/S SAB UDYOG LIMITED, CHANDIGARH

In the result, both the appeals of the Revenue are hereby dismissed

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

147 on that very ground would mean nothing else but the abuse of process of law. Hence, the contention of the learned DR that as the return was processed u/s. 143(1) and it was a mere intimation hence, the AO had reason to believe that income had escaped assessment and it was open to the AO to reassess

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)

u/s 143(3) as find mention in the order so passed by the AO itself and our reference was drawn to the copy of the assessment order passed under section 143(3) dt. 30/03/2015 placed as part of the assessee’s paper book. It was further submitted that notice under section 148 was issued on 11/03/2019 and before that

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)

u/s 147 of the Act and the law in this regard is well settled. 9. As observed by the Hon’ble Supreme Court in the case of ACIT & Anr. Vs. Hotel Blue Moon (2010) 321 ITR 362 (SC), the omission on the part of the assessing authority to issue notice under Sec. 143(2) cannot be held

INCOME TAX OFFICER, MOHALI PUNJAB vs. TAJ LAND DEVELOPEFRS AND PROMOTERS PRIVATE LIMITED , SECTOR MOHALI PUNJAB

In the result, appeal is dismissed

reassessment.\"\n\n13. After going through the above said facts of the case and the settled legal\nposition and the said judgments of Jurisdictional Bench of the ITAT, Chandigarh\nBench, Chandigarh and others and particularly the fact that the Assessing\nOfficer was not justified in assuming the proceedings u/s 148 on the basis of\nwrong/incorrect facts and, thus

INDER KAUR,SIRSA vs. PR.CIT, 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)

192) (SC), wherein it was held that “On the other hand, if two reasonable constructions of a taxing provision are possible that construction which favours the assessee must be adopted. This is a well ’accepted rule of construction recognised by this Court in several of its decisions.” (Copy appended at page 77-81 of AJC). But above clearly shows that

KARAN PRATAP SINGH,SIRSA, HARYANA vs. ITO, WARD-1, SIRSA, HARYANA

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)

192) (SC), wherein it was held that “On the other hand, if two reasonable constructions of a taxing provision are possible that construction which favours the assessee must be adopted. This is a well ’accepted rule of construction recognised by this Court in several of its decisions.” (Copy appended at page 77-81 of AJC). But above clearly shows that

SH. AMARJEET SINGH,SIRSA vs. PR.CIT, 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)

192) (SC), wherein it was held that “On the other hand, if two reasonable constructions of a taxing provision are possible that construction which favours the assessee must be adopted. This is a well ’accepted rule of construction recognised by this Court in several of its decisions.” (Copy appended at page 77-81 of AJC). But above clearly shows that

MANINDER JEET SINGH V.P.O. UDHAMGARH,JAGADHRI,HARYANA vs. PRABHJOT KAUR,PCIT, PANCHKULA

In the result, all the above appeals filed by the respective assessee’s are dismissed

192) (SC), wherein it was held that “On the other hand, if two reasonable constructions of a taxing provision are possible that construction which favours the assessee must be adopted. This is a well ’accepted rule of construction recognised by this Court in several of its decisions.” (Copy appended at page 77-81 of AJC). But above clearly shows that

ANIL TUTEJA,FATEHABAD vs. PR. COMMISSIONER OF INCOME TAX, ROHTAK, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

192) (SC), wherein it was held that “On the other hand, if two reasonable constructions of a taxing provision are possible that construction which favours the assessee must be adopted. This is a well ’accepted rule of construction recognised by this Court in several of its decisions.” (Copy appended at page 77-81 of AJC). But above clearly shows that

RAKESH KUMAR,JAGADHRI vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, PANCHKULA

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)

192) (SC), wherein it was held that “On the other hand, if two reasonable constructions of a taxing provision are possible that construction which favours the assessee must be adopted. This is a well ’accepted rule of construction recognised by this Court in several of its decisions.” (Copy appended at page 77-81 of AJC). But above clearly shows that

BIMLA DEVI,JAGADHRI vs. PR.CIT, 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)

192) (SC), wherein it was held that “On the other hand, if two reasonable constructions of a taxing provision are possible that construction which favours the assessee must be adopted. This is a well ’accepted rule of construction recognised by this Court in several of its decisions.” (Copy appended at page 77-81 of AJC). But above clearly shows that

PARAMJIT SINGH,SIRSA vs. PR.CIT, 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)

192) (SC), wherein it was held that “On the other hand, if two reasonable constructions of a taxing provision are possible that construction which favours the assessee must be adopted. This is a well ’accepted rule of construction recognised by this Court in several of its decisions.” (Copy appended at page 77-81 of AJC). But above clearly shows that

RAM NIWAS,FATEHABAD vs. INCOME TAX OFFICER, INCOME TAX OFFICE, SIRSA ROAD, INDUSTRIAL AREA, FATEHABAD

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)

192) (SC), wherein it was held that “On the other hand, if two reasonable constructions of a taxing provision are possible that construction which favours the assessee must be adopted. This is a well ’accepted rule of construction recognised by this Court in several of its decisions.” (Copy appended at page 77-81 of AJC). But above clearly shows that

SH. RAM LAL,FATEHABAD vs. PR.CIT, 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)

192) (SC), wherein it was held that “On the other hand, if two reasonable constructions of a taxing provision are possible that construction which favours the assessee must be adopted. This is a well ’accepted rule of construction recognised by this Court in several of its decisions.” (Copy appended at page 77-81 of AJC). But above clearly shows that

ASHOK KUMAR THAKRAL,JAGADHRI vs. PRINCIPAL COMMISSIONER OF INCOME TAX, PANCHKULA , PANCHKULA

In the result, all the above appeals filed by the respective assessee’s are dismissed

Bench: the Tribunal as pointed out by the Registry. Considering that the issue involved is purely legal in nature, and respectfully following the ratio laid down by the Hon'ble Supreme Court in Collector, Land Acquisition v. Mst. Katiji & Others [(1987) 167 ITR 471 (SC)], which emphasizes that substantial justice should prevail over technical considerations, we condone the delay in filing these appeals.3. We shall take appeal of the assessee in ITA No. 167/Chd/2023 for A.Y 2018-19 as a lead case f

192) (SC), wherein it was held that “On the other hand, if two reasonable constructions of a taxing provision are possible that construction which favours the assessee must be adopted. This is a well ’accepted rule of construction recognised by this Court in several of its decisions.” (Copy appended at page 77-81 of AJC). But above clearly shows that

MUNISH KUMAR LEGAL HEIR LATE SH GURDEEP SINGH,VILL MANAKPUR, YAMUNANAGAR vs. ITO, WARD 5, YAMUNANAGAR

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)

192) (SC), wherein it was held that “On the other hand, if two reasonable constructions of a taxing provision are possible that construction which favours the assessee must be adopted. This is a well ’accepted rule of construction recognised by this Court in several of its decisions.” (Copy appended at page 77-81 of AJC). But above clearly shows that

PARVEEN KUMAR,229,VILLAGE MANAKPUR-II,TEHSIL JAGADHRI,HARYANA vs. PRABHJOT KAUR,PCIT PANCHKULA, CHANDIGARH

In the result, all the above appeals filed by the respective assessee’s are dismissed

Bench: the Tribunal as pointed out by the Registry. Considering that the issue involved is purely legal in nature, and respectfully following the ratio laid down by the Hon'ble Supreme Court in Collector, Land Acquisition v. Mst. Katiji & Others [(1987) 167 ITR 471 (SC)], which emphasizes that substantial justice should prevail over technical considerations, we condone the delay in filing these appeals.3. We shall take appeal of the assessee in ITA No. 167/Chd/2023 for A.Y 2018-19 as a lead case f

192) (SC), wherein it was held that “On the other hand, if two reasonable constructions of a taxing provision are possible that construction which favours the assessee must be adopted. This is a well ’accepted rule of construction recognised by this Court in several of its decisions.” (Copy appended at page 77-81 of AJC). But above clearly shows that