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 would defeat the very purpose of the amendment and open the floodgates to arbitrary assessments. 26. The relevant extract Memorandum explaining the finance bill is reproduced as under:- ‘(ii) Assessments or reassessments or in re-computation in cases where search is initiated under section 132 or requisition is made under 132A, after 31st March 2021, shall be under

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

251(1) regarding alleged understatement of investment in\nproperty at 28/6, Industrial Area, Phase-2, Chandigarh.\nIssue 5 : Directions by CIT(A) to AO to initiate 147/148 proceedings taking shelter of\ns.150(1)(2) for AY 2010-11 and 2012-13.\nIssue 6: Shortage of stock found during search held as undisclosed sale.\nIssue 7: Commission/profit earned at estimated rate

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

251(1) regarding alleged understatement of investment in\nproperty at 28/6, Industrial Area, Phase-2, Chandigarh.\nIssue 5 : Directions by CIT(A) to AO to initiate 147/148 proceedings taking shelter of\ns.150(1)(2) for AY 2010-11 and 2012-13.\nIssue 6: Shortage of stock found during search held as undisclosed sale.\nIssue 7: Commission/profit earned at estimated rate

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

251(1) regarding alleged understatement of investment in\nproperty at 28/6, Industrial Area, Phase-2, Chandigarh.\nIssue 5 : Directions by CIT(A) to AO to initiate 147/148 proceedings taking shelter of\ns.150(1)(2) for AY 2010-11 and 2012-13.\nIssue 6: Shortage of stock found during search held as undisclosed sale.\nIssue 7: Commission/profit earned at estimated rate

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

251(1) regarding alleged understatement of investment in\nproperty at 28/6, Industrial Area, Phase-2, Chandigarh.\nIssue 5 : Directions by CIT(A) to AO to initiate 147/148 proceedings taking shelter of\ns.150(1)(2) for AY 2010-11 and 2012-13.\nIssue 6: Shortage of stock found during search held as undisclosed sale.\nIssue 7: Commission/profit earned at estimated rate

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

251(1) regarding alleged understatement of investment in\nproperty at 28/6, Industrial Area, Phase-2, Chandigarh.\nIssue 5 : Directions by CIT(A) to AO to initiate 147/148 proceedings taking shelter of\ns.150(1)(2) for AY 2010-11 and 2012-13.\nIssue 6: Shortage of stock found during search held as undisclosed sale.\nIssue 7: Commission/profit earned at estimated rate

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

251(1) regarding alleged understatement of investment in\nproperty at 28/6, Industrial Area, Phase-2, Chandigarh.\nIssue 5 : Directions by CIT(A) to AO to initiate 147/148 proceedings taking shelter of\ns.150(1)(2) for AY 2010-11 and 2012-13.\nIssue 6: Shortage of stock found during search held as undisclosed sale.\nIssue 7: Commission/profit earned at estimated rate

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

251(1) regarding alleged understatement of investment in\nproperty at 28/6, Industrial Area, Phase-2, Chandigarh.\nIssue 5 : Directions by CIT(A) to AO to initiate 147/148 proceedings taking shelter of\ns.150(1)(2) for AY 2010-11 and 2012-13.\nIssue 6: Shortage of stock found during search held as undisclosed sale.\nIssue 7: Commission/profit earned at estimated rate

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

251(1) regarding alleged understatement of investment in\nproperty at 28/6, Industrial Area, Phase-2, Chandigarh.\nIssue 5 : Directions by CIT(A) to AO to initiate 147/148 proceedings taking shelter of\ns. 150(1)(2) for AY 2010-11 and 2012-13.\nIssue 6: Shortage of stock found during search held as undisclosed sale.\nIssue 7: Commission/profit earned at estimated

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

251(1) regarding alleged understatement of investment in\nproperty at 28/6, Industrial Area, Phase-2, Chandigarh.\nIssue 5 : Directions by CIT(A) to AO to initiate 147/148 proceedings taking shelter of\ns. 150(1)(2) for AY 2010-11 and 2012-13.\nIssue 6: Shortage of stock found during search held as undisclosed sale.\nIssue 7: Commission/profit earned at estimated

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

251(1) regarding alleged understatement of investment in\nproperty at 28/6, Industrial Area, Phase-2, Chandigarh.\nIssue 5 : Directions by CIT(A) to AO to initiate 147/148 proceedings taking shelter of\ns. 150(1)(2) for AY 2010-11 and 2012-13.\nIssue 6: Shortage of stock found during search held as undisclosed sale.\nIssue 7: Commission/profit earned at estimated

SANJEEV AGGARWAL,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

251(1) regarding alleged understatement of investment in\nproperty at 28/6, Industrial Area, Phase-2, Chandigarh.\nIssue 5 : Directions by CIT(A) to AO to initiate 147/148 proceedings taking shelter of\ns.150(1)(2) for AY 2010-11 and 2012-13.\nIssue 6: Shortage of stock found during search held as undisclosed sale.\nIssue 7: Commission/profit earned at estimated rate

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

251(1) regarding alleged understatement of investment in\nproperty at 28/6, Industrial Area, Phase-2, Chandigarh.\nIssue 5 : Directions by CIT(A) to AO to initiate 147/148 proceedings taking shelter of\ns.150(1)(2) for AY 2010-11 and 2012-13.\nIssue 6: Shortage of stock found during search held as undisclosed sale.\nIssue 7: Commission/profit earned at estimated rate

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

251(1) regarding alleged understatement of investment in\nproperty at 28/6, Industrial Area, Phase-2, Chandigarh.\nIssue 5 : Directions by CIT(A) to AO to initiate 147/148 proceedings taking shelter of\ns.150(1)(2) for AY 2010-11 and 2012-13.\nIssue 6: Shortage of stock found during search held as undisclosed sale.\nIssue 7: Commission/profit earned at estimated rate

SANJEEV AGGARWAL,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1 , CHANDIGARH

251(1) regarding alleged understatement of investment in\nproperty at 28/6, Industrial Area, Phase-2, Chandigarh.\nIssue 5 : Directions by CIT(A) to AO to initiate 147/148 proceedings taking shelter of\ns.150(1)(2) for AY 2010-11 and 2012-13.\nIssue 6: Shortage of stock found during search held as undisclosed sale.\nIssue 7: Commission/profit earned at estimated rate

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

251(1) regarding alleged understatement of investment in\nproperty at 28/6, Industrial Area, Phase-2, Chandigarh.\nIssue 5 : Directions by CIT(A) to AO to initiate 147/148 proceedings taking shelter of\ns.150(1)(2) for AY 2010-11 and 2012-13.\nIssue 6: Shortage of stock found during search held as undisclosed sale.\nIssue 7: Commission/profit earned at estimated rate

DCIT, CHANDIGARH vs. SANJEEV AGGARWAL , CHANDIGARH

251(1) regarding alleged understatement of investment in\nproperty at 28/6, Industrial Area, Phase-2, Chandigarh.\nIssue 5 : Directions by CIT(A) to AO to initiate 147/148 proceedings taking shelter of\ns.150(1)(2) for AY 2010-11 and 2012-13.\nIssue 6: Shortage of stock found during search held as undisclosed sale.\nIssue 7: Commission/profit earned at estimated rate

MAXPORT INDIA PRIVATE LIMITED,CHANDIGARH vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,CHANDIGARH, CHANDIGARH

251(1) regarding alleged understatement of investment in\nproperty at 28/6, Industrial Area, Phase-2, Chandigarh.\nIssue 5 : Directions by CIT(A) to AO to initiate 147/148 proceedings taking shelter of\ns.150(1)(2) for AY 2010-11 and 2012-13.\nIssue 6: Shortage of stock found during search held as undisclosed sale.\nIssue 7: Commission/profit earned at estimated rate

MAXPORT INDIA PRIVATE LIMITED,CHANDIGARH vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,CHANDIGARH, CHANDIGARH

251(1) regarding alleged understatement of investment in\nproperty at 28/6, Industrial Area, Phase-2, Chandigarh.\nIssue 5 : Directions by CIT(A) to AO to initiate 147/148 proceedings taking shelter of\ns.150(1)(2) for AY 2010-11 and 2012-13.\nIssue 6: Shortage of stock found during search held as undisclosed sale.\nIssue 7: Commission/profit earned at estimated rate