SATISH KATOCH,PALAMPUR vs. ITO, PALAMPUR

The appeal of the assessee is dismissed

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

56. Reading of Section 234B(3) makes it clear that where, as a result of an order of reassessment or recomputation under Section 147 or Section 153A, the amount on which interest was payable under Sub-section (1) is increased, the assessee shall be liable to pay simple interest at the rate of one per cent.... The reading

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)

56 of the Act made by Finance (No. 2) Act 2009 was duly considered by Hon'ble High Courts: i) 388 ITR 343 (Guj) Movaliya Bhikhubhai Balabhai v. Income-tax Officer-TDS-1-Surat. ii) 417 ITR 169 (Bom) Rupesh Rashmikant Shah vs. UOI iii) 151 taxmann.com 62 (Bom) Balkrishna vs. State of Maharashtra iv) 457 ITR 777 (Orissa

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)

56 of the Act made by Finance (No. 2) Act 2009 was duly considered by Hon'ble High Courts: i) 388 ITR 343 (Guj) Movaliya Bhikhubhai Balabhai v. Income-tax Officer-TDS-1-Surat. ii) 417 ITR 169 (Bom) Rupesh Rashmikant Shah vs. UOI iii) 151 taxmann.com 62 (Bom) Balkrishna vs. State of Maharashtra iv) 457 ITR 777 (Orissa

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)

56 of the Act made by Finance (No. 2) Act 2009 was duly considered by Hon'ble High Courts: i) 388 ITR 343 (Guj) Movaliya Bhikhubhai Balabhai v. Income-tax Officer-TDS-1-Surat. ii) 417 ITR 169 (Bom) Rupesh Rashmikant Shah vs. UOI iii) 151 taxmann.com 62 (Bom) Balkrishna vs. State of Maharashtra iv) 457 ITR 777 (Orissa

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)

56 of the Act made by Finance (No. 2) Act 2009 was duly considered by Hon'ble High Courts: i) 388 ITR 343 (Guj) Movaliya Bhikhubhai Balabhai v. Income-tax Officer-TDS-1-Surat. ii) 417 ITR 169 (Bom) Rupesh Rashmikant Shah vs. UOI iii) 151 taxmann.com 62 (Bom) Balkrishna vs. State of Maharashtra iv) 457 ITR 777 (Orissa

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)

56 of the Act made by Finance (No. 2) Act 2009 was duly considered by Hon'ble High Courts: i) 388 ITR 343 (Guj) Movaliya Bhikhubhai Balabhai v. Income-tax Officer-TDS-1-Surat. ii) 417 ITR 169 (Bom) Rupesh Rashmikant Shah vs. UOI iii) 151 taxmann.com 62 (Bom) Balkrishna vs. State of Maharashtra iv) 457 ITR 777 (Orissa

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)

56 of the Act made by Finance (No. 2) Act 2009 was duly considered by Hon'ble High Courts: i) 388 ITR 343 (Guj) Movaliya Bhikhubhai Balabhai v. Income-tax Officer-TDS-1-Surat. ii) 417 ITR 169 (Bom) Rupesh Rashmikant Shah vs. UOI iii) 151 taxmann.com 62 (Bom) Balkrishna vs. State of Maharashtra iv) 457 ITR 777 (Orissa

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)

56 of the Act made by Finance (No. 2) Act 2009 was duly considered by Hon'ble High Courts: i) 388 ITR 343 (Guj) Movaliya Bhikhubhai Balabhai v. Income-tax Officer-TDS-1-Surat. ii) 417 ITR 169 (Bom) Rupesh Rashmikant Shah vs. UOI iii) 151 taxmann.com 62 (Bom) Balkrishna vs. State of Maharashtra iv) 457 ITR 777 (Orissa

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

KANWALDEEP KAUR,CHANDIGARH vs. DCIT, CIRCLE 1, CHANDIGARH

In the result, appeal filed by the Revenue in ITA No

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

147 r.w.s. 144B and the submissions made by Gurtej Singh for the assessment year 2017-18. The Ld. AO had reassessed the assessee’s income at Rs. 5,87,09,868/-, adding Rs. 4,63,21,268/- under section 56(2)(vii)(b) due to the difference between the stamp duty value

INCOME TAX OFFICER, MOHALI vs. GURTEJ SINGH, MOHALI

In the result, appeal filed by the Revenue in ITA No

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

147 r.w.s. 144B and the submissions made by Gurtej Singh for the assessment year 2017-18. The Ld. AO had reassessed the assessee’s income at Rs. 5,87,09,868/-, adding Rs. 4,63,21,268/- under section 56(2)(vii)(b) due to the difference between the stamp duty value

ASHOK KUMAR THAKRAL,JAGADHRI vs. PRINCIPAL COMMISSIONER OF INCOME TAX, PANCHKULA , PANCHKULA

In the result, all the above appeals filed by the respective assessee’s are dismissed

Bench: the Tribunal as pointed out by the Registry. Considering that the issue involved is purely legal in nature, and respectfully following the ratio laid down by the Hon'ble Supreme Court in Collector, Land Acquisition v. Mst. Katiji & Others [(1987) 167 ITR 471 (SC)], which emphasizes that substantial justice should prevail over technical considerations, we condone the delay in filing these appeals.3. We shall take appeal of the assessee in ITA No. 167/Chd/2023 for A.Y 2018-19 as a lead case f

reassess the earlier assessment in terms of section 147 or carry out rectification u/s 154 of the Act. He can’t usurp the power of the CIT and recommend a revision. No overlapping of powers of the authorities under the Act can be permitted. As the revision proceedings in this case have triggered with the AO sending a proposal

KARAN PRATAP SINGH,SIRSA, HARYANA vs. ITO, WARD-1, SIRSA, HARYANA

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)

reassess the earlier assessment in terms of section 147 or carry out rectification u/s 154 of the Act. He can’t usurp the power of the CIT and recommend a revision. No overlapping of powers of the authorities under the Act can be permitted. As the revision proceedings in this case have triggered with the AO sending a proposal

MADHU GREWAL,CHANDIGARH vs. PRINCIPAL COMMISSIONER OF INCOME TAX, CHANDIGARH-1, CHANDIGARH

In the result, all the above appeals filed by the respective assessee’s are dismissed

Bench: the Tribunal as pointed out by the Registry. Considering that the issue involved is purely legal in nature, and respectfully following the ratio laid down by the Hon'ble Supreme Court in Collector, Land Acquisition v. Mst. Katiji & Others [(1987) 167 ITR 471 (SC)], which emphasizes that substantial justice should prevail over technical considerations, we condone the delay in filing these appeals.3. We shall take appeal of the assessee in ITA No. 167/Chd/2023 for A.Y 2018-19 as a lead case f

reassess the earlier assessment in terms of section 147 or carry out rectification u/s 154 of the Act. He can’t usurp the power of the CIT and recommend a revision. No overlapping of powers of the authorities under the Act can be permitted. As the revision proceedings in this case have triggered with the AO sending a proposal

MANINDER JEET SINGH V.P.O. UDHAMGARH,JAGADHRI,HARYANA vs. PRABHJOT KAUR,PCIT, PANCHKULA

In the result, all the above appeals filed by the respective assessee’s are dismissed

reassess the earlier assessment in terms of section 147 or carry out rectification u/s 154 of the Act. He can’t usurp the power of the CIT and recommend a revision. No overlapping of powers of the authorities under the Act can be permitted. As the revision proceedings in this case have triggered with the AO sending a proposal

ANIL TUTEJA,FATEHABAD vs. PR. COMMISSIONER OF INCOME TAX, ROHTAK, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

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

reassess the earlier assessment in terms of section 147 or carry out rectification u/s 154 of the Act. He can’t usurp the power of the CIT and recommend a revision. No overlapping of powers of the authorities under the Act can be permitted. As the revision proceedings in this case have triggered with the AO sending a proposal

PARVEEN KUMAR,229,VILLAGE MANAKPUR-II,TEHSIL JAGADHRI,HARYANA vs. PRABHJOT KAUR,PCIT PANCHKULA, CHANDIGARH

In the result, all the above appeals filed by the respective assessee’s are dismissed

Bench: the Tribunal as pointed out by the Registry. Considering that the issue involved is purely legal in nature, and respectfully following the ratio laid down by the Hon'ble Supreme Court in Collector, Land Acquisition v. Mst. Katiji & Others [(1987) 167 ITR 471 (SC)], which emphasizes that substantial justice should prevail over technical considerations, we condone the delay in filing these appeals.3. We shall take appeal of the assessee in ITA No. 167/Chd/2023 for A.Y 2018-19 as a lead case f

reassess the earlier assessment in terms of section 147 or carry out rectification u/s 154 of the Act. He can’t usurp the power of the CIT and recommend a revision. No overlapping of powers of the authorities under the Act can be permitted. As the revision proceedings in this case have triggered with the AO sending a proposal

KARTAR SINGH, FATEHABAD vs. PR. COMMISSIONER OF INCOME TAX, 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)

reassess the earlier assessment in terms of section 147 or carry out rectification u/s 154 of the Act. He can’t usurp the power of the CIT and recommend a revision. No overlapping of powers of the authorities under the Act can be permitted. As the revision proceedings in this case have triggered with the AO sending a proposal