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

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 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

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)

253 of the Income Tax Act, 1961. The assessee is aggrieved by the order passed under Section 263 of the Act, bearing order no. ITBA/REV/F/REV5/2022 dt. 27/03/2023 which is hereinafter referred to as the impugned order. The impugned order has revised the AO’s order no. ITBA/AST/S/143(3) 2020-21/1027309634(1) dt. 12/06/2020 which is hereinafter referred

DCIT, CC-I, CHANDIGARH , CHANDIGARH vs. VALCO INDUSTRIES LTD., , CHANDIGARH

In the result, the appeal of the Revenue is dismissed

Bench: The Hon'Ble Punjab & Haryana High Court? Ii) Whether On The Facts & Circumstances Of The Case & In Law, Ld. Cit(A) Is Right Holding Such Consequential Order As Void An Initio Ignoring The Facts That Order Passed By Ld. Pcit (Central), Gurugram U/S 263 Has Not Attained Its Finality? Iii) Whether On The Facts & In Circumstances Of The Case & In Law, The Ld. Cit(A) Was Right In Holding That Consequential Order Passed U/S 147 R.W.S. 263 Of The Act As Void As Initio Without Giving Any Liberty To The Revenue To Revive The Proceedings Consequent To Any Directions Or Order

2,12,00,625/-, being the assessee’s share of revenue from joint venture which was treated as capital receipt by the assessee. 4. Thereafter, notice u/s 148 was issued on 10/03/2017 and reassessment was completed u/s 147 r/w 143(3) on 27/11/2017 at an income of Rs 8,87,92,864/- wherein the deduction claimed u/s 80IC was restricted

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)

253(4) of the Act. 36. Now, reverting to levy of interest u/s 234B of the Act, during the course of hearing, the Ld. AR submitted that the assessee entered into APA with CBDT on 06/02/2017 in relation to the covered international transaction with AE as stated in the said agreement. It was submitted that the said agreement was entered

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2, LUDHIANA , LUDHIANA vs. AB ALCOBEV PRIVATE LIMITED, DELHI

In the result, appeals of Revenue are dismissed, Cross\nObjections of the assessee for

253 contemplates that the\nTribunal may admit an appeal or permit filing of memorandum\nof cross- objections after expiry of relevant period, if it is\nsatisfied that there was a sufficient cause for not presenting\nit within that period. This expression sufficient cause\nemployed in the section has also been used identically in sub-\nsection 3 of section

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2, LUDHIANA vs. AB ALCOBEV PRIVATE LIMITED, DELHI

In the result, appeals of Revenue are dismissed, Cross\nObjections of the assessee for

253 contemplates that the\nTribunal may admit an appeal or permit filing of memorandum\nof cross- objections after expiry of relevant period, if it is\nsatisfied that there was a sufficient cause for not presenting\nit within that period. This expression sufficient cause\nemployed in the section has also been used identically in sub-\nsection 3 of section

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2 LUDHIANA, LUDHIANA vs. AB ALCOBEV PRIVATE LIMITED , DELHI

In the result, appeals of Revenue are dismissed, Cross\nObjections of the assessee for

253 contemplates that the\nTribunal may admit an appeal or permit filing of memorandum\nof cross- objections after expiry of relevant period, if it is\nsatisfied that there was a sufficient cause for not presenting\nit within that period. This expression sufficient cause\nemployed in the section has also been used identically in sub-\nsection 3 of section

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2,, LUDHIANA vs. AB ALCOBEV PRIVATE LIMITED, DELHI

In the result, appeals of Revenue are dismissed, Cross\nObjections of the assessee for

253 contemplates that the\nTribunal may admit an appeal or permit filing of memorandum\nof cross- objections after expiry of relevant period, if it is\nsatisfied that there was a sufficient cause for not presenting\nit within that period. This expression sufficient cause\nemployed in the section has also been used identically in sub-\nsection 3 of section

SH.RANDHIR SINGH,MOHALI vs. PR.CIT-1, CHANDIGARH

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

253 of the Income Tax Act, 1961 (hereinafter referred to as the Act). The assessee is aggrieved by the order passed under Section 263 of the Act bearing order No. ITBA/Rev/F/REV- 5/2020-21/1031827224 dated 27.03.2021 which is hereinafter referred to as “the impugned order”. The impugned order has revised the ld. AO order No.NIL dated 06.12.2017 which was passed under Section

DY. COMMISSIONER OF INCOME TAX, AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, FOCAL POINT

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

253 of the Income Tax Act, 1961 (hereinafter referred to as Act) before this Tribunal. The Revenue is aggrieved by the order bearing No. ITBA/NFAC/S/250/2023- 24/1056753913(i) dt. 04/10/2023 dt. 04/10/2023 of Ld. CIT(A) which is hereinafter referred to as the “impugned order” . The impugned order is passed in the first appellate proceedings u/s

DY. COMMISSIONER OF INCOME TAX, CIRCLE-4,, AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

253 of the Income Tax Act, 1961 (hereinafter referred to as Act) before this Tribunal. The Revenue is aggrieved by the order bearing No. ITBA/NFAC/S/250/2023- 24/1056753913(i) dt. 04/10/2023 dt. 04/10/2023 of Ld. CIT(A) which is hereinafter referred to as the “impugned order” . The impugned order is passed in the first appellate proceedings u/s

DY. COMMISSIONER OF INCOME TAX, CIRCLE-4, , AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

253 of the Income Tax Act, 1961 (hereinafter referred to as Act) before this Tribunal. The Revenue is aggrieved by the order bearing No. ITBA/NFAC/S/250/2023- 24/1056753913(i) dt. 04/10/2023 dt. 04/10/2023 of Ld. CIT(A) which is hereinafter referred to as the “impugned order” . The impugned order is passed in the first appellate proceedings u/s

DY. COMMISSIONER OF INCOME TAX, CIRCLE-4, AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

253 of the Income Tax Act, 1961 (hereinafter referred to as Act) before this Tribunal. The Revenue is aggrieved by the order bearing No. ITBA/NFAC/S/250/2023- 24/1056753913(i) dt. 04/10/2023 dt. 04/10/2023 of Ld. CIT(A) which is hereinafter referred to as the “impugned order” . The impugned order is passed in the first appellate proceedings u/s

DY. COMMISSIONER OF INCOME TAX, CIRCLE-4, LUDHIANA, AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

253 of the Income Tax Act, 1961 (hereinafter referred to as Act) before this Tribunal. The Revenue is aggrieved by the order bearing No. ITBA/NFAC/S/250/2023- 24/1056753913(i) dt. 04/10/2023 dt. 04/10/2023 of Ld. CIT(A) which is hereinafter referred to as the “impugned order” . The impugned order is passed in the first appellate proceedings u/s

DCIT CIRCLE-4, LUDHIANA, LUDHIANA vs. ROCKMAN INDUSTRIES LTD, LUDHIANA

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

253 of the Income Tax Act, 1961 (hereinafter referred to as Act) before this Tribunal. The Revenue is aggrieved by the order bearing No. ITBA/NFAC/S/250/2023- 24/1056753913(i) dt. 04/10/2023 dt. 04/10/2023 of Ld. CIT(A) which is hereinafter referred to as the “impugned order” . The impugned order is passed in the first appellate proceedings u/s

ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-4, AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

253 of the Income Tax Act, 1961 (hereinafter referred to as Act) before this Tribunal. The Revenue is aggrieved by the order bearing No. ITBA/NFAC/S/250/2023- 24/1056753913(i) dt. 04/10/2023 dt. 04/10/2023 of Ld. CIT(A) which is hereinafter referred to as the “impugned order” . The impugned order is passed in the first appellate proceedings u/s

DY. COMMISSIONER OF INCOME TAX, CIRCLE-4, LUDHIANA, - vs. ROCKMAN INDUSTRIES LTD, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

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

253 of the Income Tax Act, 1961 (hereinafter referred to as Act) before this Tribunal. The Revenue is aggrieved by the order bearing No. ITBA/NFAC/S/250/2023- 24/1056753913(i) dt. 04/10/2023 dt. 04/10/2023 of Ld. CIT(A) which is hereinafter referred to as the “impugned order” . The impugned order is passed in the first appellate proceedings u/s

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)

253 of the Income Tax Act, 1961 as and by way of second appeal under the Act. The assessee is aggrieved by order dt. 01/05/2023 passed in first appeal bearing No. 10408/2012-13/IT/CIT(A)- 5/Ldh/2021-22 of Ld. CIT(A) under section 250(6) of the Act, which is hereinafter referred to as the “impugned order”. FACTUAL MATRIX 2. The assessee