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

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

SANJEEV AGGARWAL,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

MAXPORT INDIA PRIVATE LIMITED,CHANDIGARH vs. DY. 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

KISSAN FATS LTD.,BATHINDA vs. DCIT, CC-1, LUDHIANA

In the result, the appeal of the assessee is allowed

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

250(6) of the Act, which is hereinafter referred to as the “impugned order”. FACTUAL MATRIX 2. The assessee is a company under the Companies Act, 1956/2013. The assessee is into the business of manufacturing vanaspati ghee and refined oil and had filed return of income at rs. 2,07,78,950/- on 30/09/2013. 3. The assessee maintains audited books

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)

250 of the Income Tax Act, 1961 by the Learned Commissioner of Income Tax (Appeals), NFAC, Delhi is against law and facts on the file in as much as he was not justified to uphold the action of the Learned Assessing Officer in initiating proceedings u/s 147. 2. That the Learned CIT (Appeals), NFAC, was not justified to arbitrarily uphold

AMARJIT SINGH,LUDHIANA vs. INCOME TAX OFFICER,WARD 6(1) LUDHIANA, LUDHIANA

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

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 1171 /Chd/2024 निर्धारण वर्ष / Assessment Year : 2017-18 Shri Amarjit Singh बनाम The ITO C/o V V Bhalla & Company Ward 6(1) SCF-39, Rishi Nagar Main Market, Ludhiana Adjoining Subway, Ludhiana-141001, Punjab स्थायी लेखा सं./PAN NO: ABTPS8558B अपीलार्थी/Appellant प्रत्यर्थी/Respondent निर्धारिती की ओर से / Assessee by : Shri Pankaj Bhalla, C.A राजस्व की ओर से/ Revenue by : Shri Vivek Vardhan, Addl. CIT, Sr

147 r.w.s 144 without giving proper opportunity of being heard in contravention to the principles of natural justice i.e. audi alteram partem. 8. That the Ld. C.I.T.(A), NFAC, Delhi has failed to appreciate that the Ld. AO erred in law & facts in initiating penalty proceeding u/s 270A and 272A(1)(d) of the Act, without any base & reasons thereof

ANISH GARG,PATIALA vs. ITO WARD-4, PATIALA

In the result, the appeal of the assessee is allowed

250(4).\n6. That CIT(A) while rejecting the additional evidence application failed to\nappreciate that the law is well settled on the issue that technicalities should not\nhinder the cause of justice.\n7. That the CIT(A) has wrongly upheld that addition of Rs 4,80,000/- made by AO\non account of addition to capital the same

DCIT, C-1(1) , CHANDIGARH vs. M/S FIDELITY INFORMATION SERVICES INDIA PVT. LTD., CHANDIGARH

In the result, the cross-objection filed by the assessee is dismissed

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

250 or section 254 or section 260 or section 262 or section 263 or section 264, the amount on which interest was payable under sub-section (1) or sub-section (3) has been increased or reduced, as the case may be, the interest shall be increased or reduced accordingly, and- - In a case where the interest is increased, the Assessing

M/S INTERNATIONAL CUSTOMER RELATED MANAGEMENT SERVICES PRIVATE LIMITED,CHANDIGARH vs. D.C.I.T., CIRCLE 6(1), MOHALI

In the result, for statistical purposes, the appeal is

Bench: SHRI A.D.JAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)

reassessment proceedings under section 147 of the Act having being initiated merely on the basis of information received, without independent application of mind by the assessing officer to such information and forming opinion thereof, is illegal and bad in law. 4.4. That on the facts and circumstances of the case and in law, the assessing officer erred in making additions

WARYAM STEEL CASTINGS PRIVATE LIMITED,LUDHIANA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-4, LUDHIANA

In the result, appeal of the assessee is allowed and the Cross appeal of the Revenue is dismissed

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

reassessment proceedings have not been provided. 2. That the order dated 10.05.2024 passed u/s 250 of the Act by the National faceless Appeal Centre (NFAC). Delhi is against law and (acts on the (lie in as much as he was not justified to uphold the action of the Ld. Assessing Officer. Assessment Unit. Income Tax Department in restricting the addition

ASTT. COMMISSIONER OF INCOME TAX, CIRCLE-4, LUDHIANA, AAYAKAR BHAWAN vs. WARYAM STEEL CASTING PRIVATE LIMITED, KANGANWAL ROAD

In the result, appeal of the assessee is allowed and the Cross appeal of the Revenue is dismissed

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

reassessment proceedings have not been provided. 2. That the order dated 10.05.2024 passed u/s 250 of the Act by the National faceless Appeal Centre (NFAC). Delhi is against law and (acts on the (lie in as much as he was not justified to uphold the action of the Ld. Assessing Officer. Assessment Unit. Income Tax Department in restricting the addition

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)

u/s 69A of the Act, on account of cash deposits/credits in bank accounts treated as unexplained money, without 2 considering the facts of the case and without observing the principles of natural justice. 6. That the appellant craves the leave to add, modify, amend or delete any of the grounds of appeal at the time of hearing

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)

250 of the Act dated 19.07.2024, partly allowing the appeal. 3.2 The summary of additions and their outcome before the first appellate authority is as under: Issue Addition made Addition Remarks by AO sustained by CIT(A) Sale suppression 4,94,63,415/- 55,06,010/- The CIT(A) upheld sale suppression but quantified

CHHERING TOMDAN,SPITI, HIMACHAL PRADESH vs. INCOME TAX OFFICER, RAMPUR BUSHAHR, HIMACHAL PRADESH

In the result, the appeal is allowed

Bench: Shri A.D. Jain & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 170/Chd/2024 "नधा"रण वष" / Assessment Year : 2017-18 Chhering Tomdan, Vs. The Ito, Village Khurik, बनाम Rampur Bushahr, Po Rangreek, Himachal Pradesh Rangrik B.O. Khurik (78), Lauhaul & Spiti, H.P. 171114 "थायी लेखा सं./Pan No: Bhxpt8803P अपीलाथ"/ Appellant ""यथ"/ Repsondent ( Hybrid Mode ) "नधा"रती क" ओर से/Assessee By : Shri Nikhil Goyal, Advocate, Shri Viren Sibbal, Advocate & Shri Ashok Goyal, Ca राज"व क" ओर से/ Revenue By : Shri Ved Parkash Kalia, Jcit, Sr. Dr

reassessment proceedings are bad in law and non-est as the same have been concluded without following the directions of Hon'ble Supreme Court in the case of Union of India v. Ashish Agarwal (2022) 444 ITR 1 (SC). 4. That the impugned Order had been passed in gross violation of the principle of natural justice and without allowing reasonable

G.J. HOLDING PVT. LTD.,LUDHIANA vs. ACIT, C-2, LUDHIANA

In the result, the appeal of the assessee stands allowed

Bench: Shri Sanjay Garg & Shri Vikram Singh Yadavआयकर अपील सं./ Ita No.1171/Chandi/2019 िनधा"रण वष" / Assessment Year : 2011-12 G.J. Holding Pvt. Ltd. बनाम Acit, Central Circle-Ii, Ludhiana C/O G.S. Auto International Limited, G.S. Estate, G.T. Road, Ludhiana. "थायी लेखा सं./Pan No: Aaacg6664K अपीलाथ"/Appellant ""यथ"/Respondent िनधा"रती क" ओर से/Assessee By : Shri P.K. Goel & Sunil Arora, C.As राज"व क" ओर से/ Revenue By : Smt. Amanpreet Kaur, Sr. Dr सुनवाई क" तारीख/Date Of Hearing : 18.12.2023 उदघोषणा क" तारीख/Date Of Pronouncement : 30.01.2024 आदेश/Order Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 04.07.2019 Of The Commissioner Of Income Tax (Appeals)-5, Ludhiana[Hereinafter Referred To As The ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). The Assessee In This Appeal Has Taken The Following 2. Grounds Of Appeal:

250 of the Income Tax Act (hereinafter referred to as the ‘Act’). The assessee in this appeal has taken the following 2. grounds of appeal: “1. That the Ld. CIT(A) while sustaining addition of Assessment Year : 2011-12 G.J. Holding Pvt. Ltd. Page 2 of 26 Rs.2,00,90,000 /- has grossly erred onfacts and in law by ignoring

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, LUDHIANA, LUDHIANA vs. AMAN FEED INDUSTRIES, KHANNA

In the result, appeals of the assessee for A

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 1252, 1253,1254,1255/Chd/2024 "नधा"रण वष" / A.Y.: 2015-16, 2017-18, 2018-19,2019-20 M/S Aman Feed Industries, The Dcit, E-2, Focal Point, Vs Central Circle-1, Khanna. Ludhiana. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent आयकर अपील सं./ Ita Nos. 116,181,457/Chd/2025 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 The Dcit, Vs M/S Aman Feed Industries, Central Circle-1, E-2, Focal Point, Ludhiana. Khanna. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ashwani Kumar, Shri Kulbhushan Goyal & Ms, Deepali Aggarwal, Cas Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 28.07.2025 Date Of Pronouncement : 16.10.2025

250 of the Income Tax Act, 1961 by the Learned Commissioner of Income Tax (Appeals)-5, Ludhiana is against law and facts on the file in as much as he was gravely erred in upholding the validity of the assessment order despite the fact that the approval granted by the Learned Additional Commissioner of Income Tax as statutorily required u/s

AMAN FEED INDUSTRIES,KHANNA vs. DEPUTY COMMISSIONER OF INCOME TAX, CC-1, , LUDHIANA

In the result, appeals of the assessee for A

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 1252, 1253,1254,1255/Chd/2024 "नधा"रण वष" / A.Y.: 2015-16, 2017-18, 2018-19,2019-20 M/S Aman Feed Industries, The Dcit, E-2, Focal Point, Vs Central Circle-1, Khanna. Ludhiana. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent आयकर अपील सं./ Ita Nos. 116,181,457/Chd/2025 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 The Dcit, Vs M/S Aman Feed Industries, Central Circle-1, E-2, Focal Point, Ludhiana. Khanna. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ashwani Kumar, Shri Kulbhushan Goyal & Ms, Deepali Aggarwal, Cas Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 28.07.2025 Date Of Pronouncement : 16.10.2025

250 of the Income Tax Act, 1961 by the Learned Commissioner of Income Tax (Appeals)-5, Ludhiana is against law and facts on the file in as much as he was gravely erred in upholding the validity of the assessment order despite the fact that the approval granted by the Learned Additional Commissioner of Income Tax as statutorily required u/s

AMAN FEED INDUSTRIES,KHANNA vs. DEPUTY COMMISSIONER OF INCOME TAX, CC-1, , LUDHIANA

In the result, appeals of the assessee for A

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 1252, 1253,1254,1255/Chd/2024 "नधा"रण वष" / A.Y.: 2015-16, 2017-18, 2018-19,2019-20 M/S Aman Feed Industries, The Dcit, E-2, Focal Point, Vs Central Circle-1, Khanna. Ludhiana. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent आयकर अपील सं./ Ita Nos. 116,181,457/Chd/2025 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 The Dcit, Vs M/S Aman Feed Industries, Central Circle-1, E-2, Focal Point, Ludhiana. Khanna. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ashwani Kumar, Shri Kulbhushan Goyal & Ms, Deepali Aggarwal, Cas Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 28.07.2025 Date Of Pronouncement : 16.10.2025

250 of the Income Tax Act, 1961 by the Learned Commissioner of Income Tax (Appeals)-5, Ludhiana is against law and facts on the file in as much as he was gravely erred in upholding the validity of the assessment order despite the fact that the approval granted by the Learned Additional Commissioner of Income Tax as statutorily required u/s