SH. BIPAN JAIN,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the ground no

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

68 arbitrarily. These are actual long term capital gains earned by the assessee. h) All the documents in the shape of share certificates issued by Maple Goods Pvt. Ltd. which are part of annexure A containing 1 to 182 pages have been doubted under the words Character of Certificates, inspite of the fact that the AO has not doubted

SH. ASHISH JAIN,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the ground no

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

68 arbitrarily. These are actual long term capital gains earned by the assessee. h) All the documents in the shape of share certificates issued by Maple Goods Pvt. Ltd. which are part of annexure A containing 1 to 182 pages have been doubted under the words Character of Certificates, inspite of the fact that the AO has not doubted

SH. ASHISH JAIN,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the ground no

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

68 arbitrarily. These are actual long term capital gains earned by the assessee. h) All the documents in the shape of share certificates issued by Maple Goods Pvt. Ltd. which are part of annexure A containing 1 to 182 pages have been doubted under the words Character of Certificates, inspite of the fact that the AO has not doubted

M/S JAIN AMAR CLOTHING PVT. LTD.,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the ground no

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

68 of the Act. As against the returned income of Rs. 8,85,15,010/-, the assessed income was determined at Rs. 37,11,61,260/- by bringing to tax the whole of the share premium amounting to Rs. 28,26,46,250/-. 4. Being aggrieved, the assessee carried the matter in appeal before

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

Block Provisions of Provisions of Provisions of Assessment u/s Search Search Search 158BC Assessment u/s assessment u/s assessment 153A 148 u/s 158BC Applicability In respect of search In respect of In respect of In respect of initiated prior to search initiated search initiated search 31/05/2003 after 31/05/2003 after 01/04/2021 initiated after and before till 31/08/2024 01/09/2024 01/04/2021 Filing of Return

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

Block Provisions of Provisions of Provisions of Assessment u/s Search Search Search 158BC Assessment u/s assessment u/s assessment 153A 148 u/s 158BC Applicability In respect of search In respect of In respect of In respect of initiated prior to search initiated search initiated search 31/05/2003 after 31/05/2003 after 01/04/2021 initiated after and before till 31/08/2024 01/09/2024 01/04/2021 Filing of Return

SHRI ABHISHEK SOIN,LUDHIANA vs. DCIT, CC-II, LUDHIANA

The appeals are partly allowed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 321 & 322/Chd/2019 "नधा"रण वष" / Assessment Year: 2010-11, 2011-12 Shri Abhishek Soin, The Dcit, C/O Sigma Cartons Pvt. Ltd., Vs Central Circle-Ii, Unit-Ii, Industrial Area-C, Ludhiana. Sua Road, Ludhiana. "थायी लेखा सं./Pan No: Anbps9446A अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Aditya Kumar, Ca Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 03.06.2025 Date Of Pronouncement : 29.07.2025 Hybrid Hearing O R D E R

block assessment period even in case of completed/unabated assessment. As per the second proviso to Section 153A, only pending assessment/reassessment shall stand abated and the AO would assume the jurisdiction with respect to such abated assessments. It does not provide that all completed/unabated assessments shall abate. If the submission on behalf of the Revenue is accepted, in that case, second

SHRI ABHISHEK SOIN,LUDHIANA vs. DCIT, CC-II, LUDHIANA

The appeals are partly allowed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 321 & 322/Chd/2019 "नधा"रण वष" / Assessment Year: 2010-11, 2011-12 Shri Abhishek Soin, The Dcit, C/O Sigma Cartons Pvt. Ltd., Vs Central Circle-Ii, Unit-Ii, Industrial Area-C, Ludhiana. Sua Road, Ludhiana. "थायी लेखा सं./Pan No: Anbps9446A अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Aditya Kumar, Ca Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 03.06.2025 Date Of Pronouncement : 29.07.2025 Hybrid Hearing O R D E R

block assessment period even in case of completed/unabated assessment. As per the second proviso to Section 153A, only pending assessment/reassessment shall stand abated and the AO would assume the jurisdiction with respect to such abated assessments. It does not provide that all completed/unabated assessments shall abate. If the submission on behalf of the Revenue is accepted, in that case, second

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)

68,78,900/- as originally declared and thereafter notice under section 143(2) and 142(1) alongwith detailed questionnaire were issued and after taking into consideration the submissions so filed by the assessee and after carrying out necessary examination/verification, the assessment proceedings were completed under section 147 r.w.s 144B vide order dt. 30/03/2022 without drawing any adverse inference with regard

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

block assessment in\nterms of Section 158BC in respect of any other person, the\nconditions precedents wherefor are: (i) Satisfaction must be\nrecorded by the Assessing Officer that any undisclosed income\nbelongs to any person, other than the person with respect to whom\nsearch was made under Section 132 of the Act; (ii) The books of\naccount or other documents

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

block assessment in\nterms of Section 158BC in respect of any other person, the\nconditions precedents wherefor are: (i) Satisfaction must be\nrecorded by the Assessing Officer that any undisclosed income\nbelongs to any person, other than the person with respect to whom\nsearch was made under Section 132 of the Act; (ii) The books of\naccount or other documents

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

block assessment in\nterms of Section 158BC in respect of any other person, the\nconditions precedents wherefor are: (i) Satisfaction must be\nrecorded by the Assessing Officer that any undisclosed income\nbelongs to any person, other than the person with respect to whom\nsearch was made under Section 132 of the Act; (ii) The books of\naccount or other documents

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

block assessment in\nterms of Section 158BC in respect of any other person, the\nconditions precedents wherefor are: (i) Satisfaction must be\nrecorded by the Assessing Officer that any undisclosed income\nbelongs to any person, other than the person with respect to whom\nsearch was made under Section 132 of the Act; (ii) The books of\naccount or other documents

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2 LUDHIANA, LUDHIANA vs. AMARJIT SINGH , BATHINDA

In the result, Cross Objections of the assessee

Bench: Shri Rajpal Yadav & Shri Krinwant Sahay

block assessment in terms of Section 158BC in respect of any other person, the conditions precedents wherefor are : (i) Satisfaction must be recorded by the Assessing Officer that any undisclosed income belongs to any person, other ,than the person with respect to whom search was made under Section 132 of the Act; (ii) The books of account or other documents

SH. DINESH SOIN,LUDHIANA vs. ACIT, LUDHIANA

The appeals are partly allowed

block assessment period even\nin case of completed/unabated assessment. As per the\nsecond proviso to Section 153A, only pending\nassessment/reassessment shall stand abated and the AO\nwould assume the jurisdiction with respect to such abated\nassessments. It does not provide that all\ncompleted/unabated assessments shall abate. If the\nsubmission on behalf of the Revenue is accepted, in that\ncase, second

SMT. GINNY SOIN,LUDHIANA vs. ACIT, CC-II, LUDHIANA

The appeals are partly allowed

block assessment period even\nin case of completed/unabated assessment. As per the\nsecond proviso to Section 153A, only pending\nassessment/reassessment shall stand abated and the AO\nwould assume the jurisdiction with respect to such abated\nassessments.\nIt does not provide that all\ncompleted/unabated assessments shall abate. If the\nsubmission on behalf of the Revenue is accepted, in that\ncase, second

SMT. GINNY SOIN,LUDHIANA vs. ACIT, CC-II, LUDHIANA

The appeals are partly allowed

block assessment period even\nin case of completed/unabated assessment. As per the\nsecond proviso to Section 153A, only pending\nassessment/reassessment shall stand abated and the AO\nwould assume the jurisdiction with respect to such abated\nassessments. It does not provide that all\ncompleted/unabated assessments shall abate. If the\nsubmission on behalf of the Revenue is accepted, in that\ncase, second

M/S PNG TRADING PRIVATE LIMITED,CHANDIGARH vs. DCIT, CHANDIGARH

In the result, all four appeals are allowed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwal

block assessment period even in case of completed/unabated assessment. As per the second proviso to Section 153A, only pending assessment/reassessment shall stand abated and the AO would assume the jurisdiction with respect to such abated assessments. It does not provide that all completed/unabated assessments shall abate. If the submission on behalf of the Revenue is accepted, in that case, second