SH. DINESH SETHI,LUDHIANA vs. ITO, LUDHIANA

The appeals are dismissed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 376/Chd/2014 & "नधा"रण वष" / Assessment Year : 2006-07 Shri Janesh Sethi, Legal Heir Of बनाम The Ito, Late Shri Dinesh Sethi, Ward – 1(1), Vs Prop. M/S R.S. Trading Corp., Ludhiana. C-434, Urban Estate Focal Point, Ludhiana. "थायी लेखा सं./Pan /Tan No: Aaqpk1200Q अपीलाथ"/Appellant ""यथ"/Respondent "नधा"रती क" ओर से/Assessee By : Shri Sudhir Sehgal, Advocate राज"व क" ओर से/ Revenue By : Shri Manav Bansal, Cit Dr तार"ख/Date Of Hearing : 23.06.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 04.8.2025

275 ITA 376/CHD/2014 & ITA 338/CHD/2017 A.Y. 2006-07 7 3.4 For acquiring jurisdiction u/s 147 of the Act, the A.O. is required to have in his possession certain material or information on the basis of which he could prima-facie have reason to believe that income escaped assessment. The Hon'ble Delhi High Court in the case of Rattan Gupta

SHRI DINESH SETHI,LUDHIANA vs. ITO, LUDHIANA

The appeals are dismissed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 376/Chd/2014 & "नधा"रण वष" / Assessment Year : 2006-07 Shri Janesh Sethi, Legal Heir Of बनाम The Ito, Late Shri Dinesh Sethi, Ward – 1(1), Vs Prop. M/S R.S. Trading Corp., Ludhiana. C-434, Urban Estate Focal Point, Ludhiana. "थायी लेखा सं./Pan /Tan No: Aaqpk1200Q अपीलाथ"/Appellant ""यथ"/Respondent "नधा"रती क" ओर से/Assessee By : Shri Sudhir Sehgal, Advocate राज"व क" ओर से/ Revenue By : Shri Manav Bansal, Cit Dr तार"ख/Date Of Hearing : 23.06.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 04.8.2025

275 ITA 376/CHD/2014 & ITA 338/CHD/2017 A.Y. 2006-07 7 3.4 For acquiring jurisdiction u/s 147 of the Act, the A.O. is required to have in his possession certain material or information on the basis of which he could prima-facie have reason to believe that income escaped assessment. The Hon'ble Delhi High Court in the case of Rattan Gupta

DCIT,CIRCLE-1(EXEMPTION), CHANDIGARH vs. M/S MANAV MANGAL SCHOOL( MANAV MANGAL SOCIETY), CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

275 ITR 124 (AT)(TM) d) Radhasoami Satsang Vs. CIT[1992] 193 ITR 321 (SC e) CIT V/s Arthus Andersen & Co. [2009] 318 ITR 229 (Bom) f) Commissioner of Income Tax V/s Leader Valves Ltd [2007] 295 ITR 273 (P&H) 2. Intervention into matters of commercial expediency by the Learned A.O. 2.1 Notwithstanding the Appellant's contention that

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

275 ITR 124 (AT)(TM) d) Radhasoami Satsang Vs. CIT[1992] 193 ITR 321 (SC e) CIT V/s Arthus Andersen & Co. [2009] 318 ITR 229 (Bom) f) Commissioner of Income Tax V/s Leader Valves Ltd [2007] 295 ITR 273 (P&H) 2. Intervention into matters of commercial expediency by the Learned A.O. 2.1 Notwithstanding the Appellant's contention that

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

275 ITR 124 (AT)(TM) d) Radhasoami Satsang Vs. CIT[1992] 193 ITR 321 (SC e) CIT V/s Arthus Andersen & Co. [2009] 318 ITR 229 (Bom) f) Commissioner of Income Tax V/s Leader Valves Ltd [2007] 295 ITR 273 (P&H) 2. Intervention into matters of commercial expediency by the Learned A.O. 2.1 Notwithstanding the Appellant's contention that

M/S MANAV MANGAL SOCIETY,CHANDIGARH vs. DCIT, C-1, (E), CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

275 ITR 124 (AT)(TM) d) Radhasoami Satsang Vs. CIT[1992] 193 ITR 321 (SC e) CIT V/s Arthus Andersen & Co. [2009] 318 ITR 229 (Bom) f) Commissioner of Income Tax V/s Leader Valves Ltd [2007] 295 ITR 273 (P&H) 2. Intervention into matters of commercial expediency by the Learned A.O. 2.1 Notwithstanding the Appellant's contention that

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

275 ITR 124 (AT)(TM) d) Radhasoami Satsang Vs. CIT[1992] 193 ITR 321 (SC e) CIT V/s Arthus Andersen & Co. [2009] 318 ITR 229 (Bom) f) Commissioner of Income Tax V/s Leader Valves Ltd [2007] 295 ITR 273 (P&H) 2. Intervention into matters of commercial expediency by the Learned A.O. 2.1 Notwithstanding the Appellant's contention that

M/S MANAV MANGAL SOCIETY,CHANDIGARH vs. DCIT, C-1, (E), CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

275 ITR 124 (AT)(TM) d) Radhasoami Satsang Vs. CIT[1992] 193 ITR 321 (SC e) CIT V/s Arthus Andersen & Co. [2009] 318 ITR 229 (Bom) f) Commissioner of Income Tax V/s Leader Valves Ltd [2007] 295 ITR 273 (P&H) 2. Intervention into matters of commercial expediency by the Learned A.O. 2.1 Notwithstanding the Appellant's contention that

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

275 ITR 124 (AT)(TM) d) Radhasoami Satsang Vs. CIT[1992] 193 ITR 321 (SC e) CIT V/s Arthus Andersen & Co. [2009] 318 ITR 229 (Bom) f) Commissioner of Income Tax V/s Leader Valves Ltd [2007] 295 ITR 273 (P&H) 2. Intervention into matters of commercial expediency by the Learned A.O. 2.1 Notwithstanding the Appellant's contention that

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

275 ITR 124 (AT)(TM) d) Radhasoami Satsang Vs. CIT[1992] 193 ITR 321 (SC e) CIT V/s Arthus Andersen & Co. [2009] 318 ITR 229 (Bom) f) Commissioner of Income Tax V/s Leader Valves Ltd [2007] 295 ITR 273 (P&H) 2. Intervention into matters of commercial expediency by the Learned A.O. 2.1 Notwithstanding the Appellant's contention that

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

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)

275 to 304 Foundations expenses were of paperbook Inc., USA. reimbursed by its AE. volume 2). The Respondent has settled the same under VSV Scheme as no tax impact involved. 4 2009-10 3,44,47.773 New Service Foreign travelling The Hon'ble Tribunal aqreement expenditure remanded the issue dated May 12, disallowed alleging back

DCIT, CC 1, CHANDIGARH , CHANDIGARH vs. SANJEEV AGGARWAL , CHANDIGARH

The appeals of the revenue are treated as dismissed

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

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

SCOTT EDIL PHARMACIA LTD.,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

SHRI BALRAM KRISHAN,CHANDIGARH vs. DEPUTY 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

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

SHRI BALRAM KRISHAN,CHANDIGARH vs. DEPUTY 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

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