SATISH KATOCH,PALAMPUR vs. ITO, PALAMPUR

The appeal of the assessee is dismissed

Bench: The A.O. U/S 154 Of The Act Against

reassessment. Assessee's contention that if no' interest has been charged u/s 143(1) or regular assessment, than interest cannot be charged u/s 234B is not correct and hence rejected. Explanation 2 to section 234B(1J clearly says that "where in relation to an assessment year, an assessment is made for 4 A.Y.2007-08 the 1st time under section 147

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)

2) of the Act, intcr-alia, to examine the claim of 'Large any other deduction claimed in Schedule BP of return' (refer page 5 of submission dated 06.06.2024 filed by DR). 26. Accordingly, the assessing officer, vide notice dated 30.06.2017 issued under section 142(1) of the Act, directed the assesse to furnish various details, including copy of the audited

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

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

SBS BIOTECH UNIT II,SIRMOUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX-1, CHANDIGARH

In the result, the appeal of the assessee is allowed

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

2) of Section 80-IC of the Act and starts availing exemption of 100 per cent tax under sub-section (3) of Section 80-IC (which is admissible for five years) can start claiming the exemption at the same rate of 100% beyond the period of five years on the ground that the assessee has now carried out Substantial expansion

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

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

2. This position has been reiterated by Hon’ble Delhi High Court in the case of “Pr. CIT Vs. Best Infrastructure(India) Pvt. Ltd.”, 397 ITR 182 (Delhi.), by observing in para 38 of the said order that statements recorded under Section 132(4) of the Act of the Act do not by themselves constitute incriminating material as has been

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

JAMNA DASS NIKKAMAL JAIN SARAF PRIVATE LIMITED, LUDHIANA,LUDHIANA vs. THE DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 1, LUDHIANA, LUDHIANA

In the result, the appeal filed by Revenue is dismissed and the appeal filed by the Assessee is allowed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

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

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, LUDHIANA, LUDHIANA vs. M/S JAMNA DASS NIKKAMAL JAIN SARAF PVT. LTD., LUDHIANA

In the result, the appeal filed by Revenue is dismissed and the appeal filed by the Assessee is allowed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

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

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)

147 of the Act were bad in law, void ab initio has been examined. In order to decide this ground of appeal it is relevant to refer to 4th proviso to section 153A of the Act which is reproduced as under:- ITA 514/CHD/2023 A.Y. 2012-13 5 Provided also that no notice for assessment or reassessment shall be issued

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

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

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

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 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