SH. AKHIL 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. 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

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

68 read with Section 115BBE amounting to the tune of Rs.9,65,71,414/-. In other words, both the grounds are in support of the CIT(A)’s finding. If we peruse sub-clause (4) of Section 253 of the Income Tax Act, it provides that the AO or the assessee, as & C.O. 07/CHD/2024 A.Y.2019-20 3 the case

M/S PNG TRADING PRIVATE LIMITED,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

In the result, all four appeals are allowed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwal

68) and Rs.3,28,500/- (under Section 69) as unexplained expenditure are uncalled for because no incriminating material has been found during the course of search relevant to such additions. In substance, the plea taken under Ground No. 2 and 3 also revolves around this additional ground. Thus, the whole issue involved in the present appeal is whether

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

68) and Rs.3,28,500/- (under Section 69) as unexplained expenditure are uncalled for because no incriminating material has been found during the course of search relevant to such additions. In substance, the plea taken under Ground No. 2 and 3 also revolves around this additional ground. Thus, the whole issue involved in the present appeal is whether

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

68) and Rs.3,28,500/- (under Section 69) as unexplained expenditure are uncalled for because no incriminating material has been found during the course of search relevant to such additions. In substance, the plea taken under Ground No. 2 and 3 also revolves around this additional ground. Thus, the whole issue involved in the present appeal is whether

M/S PNG TRADING PRIVATE LIMITED,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

In the result, all four appeals are allowed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwal

68) and Rs.3,28,500/- (under Section 69) as unexplained expenditure are uncalled for because no incriminating material has been found during the course of search relevant to such additions. In substance, the plea taken under Ground No. 2 and 3 also revolves around this additional ground. Thus, the whole issue involved in the present appeal is whether

SMT. AARTI SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

68 Rs. 40,05,419/- Rs. 2,40,956/- 6.5% of NET gain (LTCG) u/s 69C towards commission expenses Rs.42,46,375/- TOTAL Addition to the returned income 19. Being aggrieved the assessee carried the matter to the Ld. CIT(A) and challenged the validity of the initiation of proceedings under section 153A of the Act as no incriminating

SH. SANJAY SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

68 Rs. 40,05,419/- Rs. 2,40,956/- 6.5% of NET gain (LTCG) u/s 69C towards commission expenses Rs.42,46,375/- TOTAL Addition to the returned income 19. Being aggrieved the assessee carried the matter to the Ld. CIT(A) and challenged the validity of the initiation of proceedings under section 153A of the Act as no incriminating

SMT. AARTI SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

68 Rs. 40,05,419/- Rs. 2,40,956/- 6.5% of NET gain (LTCG) u/s 69C towards commission expenses Rs.42,46,375/- TOTAL Addition to the returned income 19. Being aggrieved the assessee carried the matter to the Ld. CIT(A) and challenged the validity of the initiation of proceedings under section 153A of the Act as no incriminating

SH. SANJAY SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

68 Rs. 40,05,419/- Rs. 2,40,956/- 6.5% of NET gain (LTCG) u/s 69C towards commission expenses Rs.42,46,375/- TOTAL Addition to the returned income 19. Being aggrieved the assessee carried the matter to the Ld. CIT(A) and challenged the validity of the initiation of proceedings under section 153A of the Act as no incriminating

SMT. AARTI SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

68 Rs. 40,05,419/- Rs. 2,40,956/- 6.5% of NET gain (LTCG) u/s 69C towards commission expenses Rs.42,46,375/- TOTAL Addition to the returned income 19. Being aggrieved the assessee carried the matter to the Ld. CIT(A) and challenged the validity of the initiation of proceedings under section 153A of the Act as no incriminating

SH. SANJAY SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

68 Rs. 40,05,419/- Rs. 2,40,956/- 6.5% of NET gain (LTCG) u/s 69C towards commission expenses Rs.42,46,375/- TOTAL Addition to the returned income 19. Being aggrieved the assessee carried the matter to the Ld. CIT(A) and challenged the validity of the initiation of proceedings under section 153A of the Act as no incriminating

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

132A of the Act. The object of Section 153A is to bring under tax the undisclosed income which is found during the course of search or pursuant to search or requisition. Therefore, only in a case where the undisclosed income is found on the basis of incriminating material, the AO would assume the jurisdiction to assess or reassess

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

132A of the Act. The object of Section 153A is to bring under tax the undisclosed income which is found during the course of search or pursuant to search or requisition. Therefore, only in a case where the undisclosed income is found on the basis of incriminating material, the AO would assume the jurisdiction to assess or reassess

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

The appeals are partly allowed

132A of the Act. The object of Section\n153A is to bring under tax the undisclosed income which is\nfound during the course of search or pursuant to search or\nrequisition. Therefore, only in a case where the undisclosed\nincome is found on the basis of incriminating material, the AO\nwould assume the jurisdiction to assess or reassess