ACIT, CIRCLE 1(1), CHANDIGARH vs. M/S SML ISUZU LTD., CHANDIGARH

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

reassessment to substitute his own opinion for that o f the Assessing Officer, who made the original assessment." (emphasis supplied) 18. It has been similarly held in the following cases that proceedings under section 147 of the Act cannot be initiated unless some new/ additional fact has come on record leading to the belief of escapement of income: - Chhugamal Rajpal

S.P. SINGLA CONSTRUCTION PRIVATE LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CHANDIGARH

In the result, the appeal is allowed

Bench: SHRI MAHAVIR SINGH (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

u/s 148 is being obtained separately from the Pr. Commissioner of Income tax-8, New Delhi as per the provisions of the section 151(2) of the Income Tax Act, 1961.” 9. In view of the above reasons, ld. Counsel for the assessee stated that the only charge of the AO in the reasons recorded is that the assessee

ROSHA ALLOYS P LIMITED, AMLOH ROAD, VILLAGE TURAN, MANDI GOBINDGARH,PUNJAB vs. DCIT CENTRAL CIRCLE 1, LUDHIANA, PUNJAB

In the result, the appeals filed by the Revenue are dismissed,\nwhereas the appeals of the assessee are allowed

reassessment proceedings as per binding judgement\nof Hon'ble Apex Court in the case of ACIT Vs Teleperformance Global Service\nPvt. Ltd., reported in 170 taxman.com 81.\n3.\nWithout prejudice to the above grounds, the learned CIT (A) has erred\nin law and on facts in applying a Gross Profit (GP) rate of 4% on the alleged\nbogus purchases, without

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, LUDHIANA , LUDHIANA vs. ROSHA ALLOYS PVT. LTD., MANDI GOBINDGARH

In the result, the appeals filed by the Revenue are dismissed,\nwhereas the appeals of the assessee are allowed

reassessment proceedings as per binding judgement\nof Hon'ble Apex Court in the case of ACIT Vs Teleperformance Global Service\nPvt. Ltd., reported in 170 taxman.com 81.\n3.\nWithout prejudice to the above grounds, the learned CIT (A) has erred\nin law and on facts in applying a Gross Profit (GP) rate of 4% on the alleged\nbogus purchases, without

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, LUDHIANA , LUDHIANA vs. ROSHA ALLOYS PVT. LTD., MANDI GOBINDGARH

In the result, the appeals filed by the Revenue are dismissed,\nwhereas the appeals of the assessee are allowed

reassessment proceedings as per binding judgement\nof Hon'ble Apex Court in the case of ACIT Vs Teleperformance Global Service\nPvt. Ltd., reported in 170 taxman.com 81.\n3.\nWithout prejudice to the above grounds, the learned CIT (A) has erred\nin law and on facts in applying a Gross Profit (GP) rate of 4% on the alleged\nbogus purchases, without

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, LUDHIANA , LUDHIANA vs. ROSHA ALLOYS PVT. LTD., MANDI GOBINDGARH

In the result, the appeals filed by the Revenue are dismissed,\nwhereas the appeals of the assessee are allowed

reassessment proceedings as per binding judgement\nof Hon'ble Apex Court in the case of ACIT Vs Teleperformance Global Service\nPvt. Ltd., reported in 170 taxman.com 81.\n3.\nWithout prejudice to the above grounds, the learned CIT (A) has erred\nin law and on facts in applying a Gross Profit (GP) rate of 4% on the alleged\nbogus purchases, without

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)

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 Officer shall serve on the assessee a notice of demand in the prescribed form specifying

SH. SATNAM SINGH,MOHALI vs. ITO, WARD 6(4), MOHALI

In the result, both the appeals of the Assessee are allowed

Bench: Shri Mahavir Singh & Shri Krinwant Sahay

264 (Mad.) wherein, the Hon'ble High Court held as under:- “Heard the counsel. In this case, Return of income was filed under Section 139(4) of the Act on 15.03.2000 and notice under Section 143(2) for framing assessment under Section 143(3) could have been issued upto 31.03.2000. Therefore, a valid Return of income was pending

SH. SATNAM SINGH,MOHALI vs. ITO, WARD 6(1), MOHALI

In the result, both the appeals of the Assessee are allowed

Bench: Shri Mahavir Singh & Shri Krinwant Sahay

264 (Mad.) wherein, the Hon'ble High Court held as under:- “Heard the counsel. In this case, Return of income was filed under Section 139(4) of the Act on 15.03.2000 and notice under Section 143(2) for framing assessment under Section 143(3) could have been issued upto 31.03.2000. Therefore, a valid Return of income was pending

ACIT, CC-2, CHANDIGARH vs. M/S TJR PROPERTIES PVT. LTD., CHANDIGARH

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

264 pursuant to the assessment order, such objection was not justified in the writ petition filed; that the assessment order under section 153A cannot and should not be permitted to become a matter of writ petition as the First Appellate Forum; and that the First Appellate Statutory Authority ITA 3 &144/CHD/2023 A.Y. 2014-15 10 could deal statutorily with

M/S TJR PROPERTIES PVT. LTD.,CHANDIGARH vs. ACIT, CC-2, CHANDIGARH

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

264 pursuant to the assessment order, such objection was not justified in the writ petition filed; that the assessment order under section 153A cannot and should not be permitted to become a matter of writ petition as the First Appellate Forum; and that the First Appellate Statutory Authority ITA 3 &144/CHD/2023 A.Y. 2014-15 10 could deal statutorily with

SH. ARVAIL SINGH,SIRSA vs. PCIT, 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)

reassessment proceedings against the assessee is found to be invalid, bad in law, arbitrary and illegal, having no legal foundation and thus quashed. Ordered accordingly.” vii) 205 ITD 31 (Mum) Reuters Asia Pacific Ltd. v. DCIT viii) dated 3.7.2025 J Kumar Infraprojects Ltd. vs. DCIT 13. The requirement of signature on the notice or document issued is not merely formality

SH. PARAMJEET SINGH,SIRSA vs. PCIT, 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)

reassessment proceedings against the assessee is found to be invalid, bad in law, arbitrary and illegal, having no legal foundation and thus quashed. Ordered accordingly.” vii) 205 ITD 31 (Mum) Reuters Asia Pacific Ltd. v. DCIT viii) dated 3.7.2025 J Kumar Infraprojects Ltd. vs. DCIT 13. The requirement of signature on the notice or document issued is not merely formality

SURJEET SINGH,SIRSA vs. PCIT, ROHTAK, 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)

reassessment proceedings against the assessee is found to be invalid, bad in law, arbitrary and illegal, having no legal foundation and thus quashed. Ordered accordingly.” vii) 205 ITD 31 (Mum) Reuters Asia Pacific Ltd. v. DCIT viii) dated 3.7.2025 J Kumar Infraprojects Ltd. vs. DCIT 13. The requirement of signature on the notice or document issued is not merely formality

SH. RANDHIR SINGH,SIRSA vs. PCIT ROHTAK, 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)

reassessment proceedings against the assessee is found to be invalid, bad in law, arbitrary and illegal, having no legal foundation and thus quashed. Ordered accordingly.” vii) 205 ITD 31 (Mum) Reuters Asia Pacific Ltd. v. DCIT viii) dated 3.7.2025 J Kumar Infraprojects Ltd. vs. DCIT 13. The requirement of signature on the notice or document issued is not merely formality

DHUNI CHAND HUF,SIRSA vs. PCIT, 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)

reassessment proceedings against the assessee is found to be invalid, bad in law, arbitrary and illegal, having no legal foundation and thus quashed. Ordered accordingly.” vii) 205 ITD 31 (Mum) Reuters Asia Pacific Ltd. v. DCIT viii) dated 3.7.2025 J Kumar Infraprojects Ltd. vs. DCIT 13. The requirement of signature on the notice or document issued is not merely formality

M/S GANESH DASS HUF,SIRSA vs. PCIT, 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)

reassessment proceedings against the assessee is found to be invalid, bad in law, arbitrary and illegal, having no legal foundation and thus quashed. Ordered accordingly.” vii) 205 ITD 31 (Mum) Reuters Asia Pacific Ltd. v. DCIT viii) dated 3.7.2025 J Kumar Infraprojects Ltd. vs. DCIT 13. The requirement of signature on the notice or document issued is not merely formality

SH. KASHMIR SINGH SANDHA,SIRSA vs. PCIT, 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)

reassessment proceedings against the assessee is found to be invalid, bad in law, arbitrary and illegal, having no legal foundation and thus quashed. Ordered accordingly.” vii) 205 ITD 31 (Mum) Reuters Asia Pacific Ltd. v. DCIT viii) dated 3.7.2025 J Kumar Infraprojects Ltd. vs. DCIT 13. The requirement of signature on the notice or document issued is not merely formality

M/S TJR PROPERTIES PVT. LTD.,CHANDIGARH vs. ACIT, CC-2, CHANDIGARH

In the result, the Appeal is partly allowed

Bench: Shri A.D. Jain & Shri Vikram Singh Yadav

reassessment proceedings under Sections 147 and 148 of the IT Act. However, as noted above, all contentions of all parties are kept open in this context. 14.4 It has been contended that the Assessing Officer has wrongly made addition u/s 153A(l)(b) r.w.s. 143(3) of the Act on the direction of the third party without having any incriminating