AMAN THUKRAL,LUDHIANA vs. INCOME TAX OFFICER WARD 2(1), LUDHIANA , LUDHIANA

Accordingly, Additional Ground No. 1 is allowed for statistical

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

133(6), as well as the fact that the suppliers had reported the sales in their statutory records including GST returns. According to the Revenue, the discrepancy between the sales reported by the suppliers and the purchases recorded by the assessee clearly indicates that the assessee had incurred expenditure outside the books of account

INCOME TAX OFFICER, CHANDIGARH vs. SANBIR SINGH, CHANDIGARH

In the result, the appeal is dismissed

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

6 to 9:- Addition made of Rs.1,30,00,000/- u/s. 68 of Act. a) Addition of Rs.40,00,000/- u/s 68 i) Appellant stated that he received Rs.40,00,000/- from Amarjit Kaur, (grandmother of Appellant) on 14.06.2017. Appellant used these funds to advance Rs.40,00,000/- to Sanjit S Randhawa on 14.06.2017. Source of said funds was from

ACIT, CC-2, CHANDIGARH vs. M/S TJR PROPERTIES PVT. LTD., CHANDIGARH

Bench: SHRI A.D.JAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)

133(6) or 131 of the Act for further investigation. However, it is noteworthy that neither the AO nor the CIT(A) extended any such notice to the lender for additional inquiries. Instead, an addition of Rs. 20,00,000/- was made based on the directive of a third party. 45.6 Neither enquiry was made by CIT(A) / AO before

M/S TJR PROPERTIES PVT. LTD.,CHANDIGARH vs. ACIT, CC-2, CHANDIGARH

Bench: SHRI A.D.JAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)

133(6) or 131 of the Act for further investigation. However, it is noteworthy that neither the AO nor the CIT(A) extended any such notice to the lender for additional inquiries. Instead, an addition of Rs. 20,00,000/- was made based on the directive of a third party. 45.6 Neither enquiry was made by CIT(A) / AO before

M/S ASHA TECHNOLOGIES,KALA AMB vs. ITO, SIRMOUR

In the result, both the above appeals of the Assessee are partly allowed as aforesaid in respect of impugned orders dt

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

section 133(6) the party denied to had any transaction or job work done for the assessee. 8 Sonu Rs.49,775/- Cash Letter issued u/s 133(6) received unserved Engineering Works with the remarks of the post man that "no such person existing at the given address." Above facts were confronted to the assesseee for his comments and explanation

M/S ASHA TECHNOLOGIES,SIRMOUR vs. ADDL. CIT, SOLAN

In the result, both the above appeals of the Assessee are partly allowed as aforesaid in respect of impugned orders dt

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

section 133(6) the party denied to had any transaction or job work done for the assessee. 8 Sonu Rs.49,775/- Cash Letter issued u/s 133(6) received unserved Engineering Works with the remarks of the post man that "no such person existing at the given address." Above facts were confronted to the assesseee for his comments and explanation

INCOME TAX OFFICER, NEW LIBRA KOTHI, RAILWAY ROAD, SIRHIND vs. BHAGWAN DASS, AMLOH ROAD, MANDI GOBINDGARH

In the result, appeal of the Revenue is dismissed

68,62,366/- there is a\ndifference of Rs.1,24,05,711/-. Even after adding insurance entries of Rs.22,798/-, α\ndifference of Rs.1,23,82,913/- still remained unexplained. The AO observed that\nledger accounts received from suppliers in response to section 133(6

SH. SANDEEP KUMAR,LUDHIANA vs. ITO, WARD-4, KHANNA

In the result, the appeal of the assessee is allowed

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

133(6), but he could not bring any evidence on record to prove that any such payment of Rs. 839191/- was actually made by the assessee on 09.06.2009. If no such evidence could be found even after making enquiry at the appellate stage at the Ld CIT(A)'s level, that the assessee had made any such payment, the addition

WARYAM STEEL CASTINGS PRIVATE LIMITED,LUDHIANA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-4, LUDHIANA

In the result, appeal of the assessee is allowed and the Cross appeal of the Revenue is dismissed

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

section 115JB of the Act. The notices u/s 143(2) and 142(1) alongwith questionnaires were issued to the Appellant Company from time to time which were responded to, and requisite information/details furnished. 5.1.3. During the course of assessment proceedings, a notice u/s 133(6) were also issued to RPS and also to some of the parties from whom

ASTT. COMMISSIONER OF INCOME TAX, CIRCLE-4, LUDHIANA, AAYAKAR BHAWAN vs. WARYAM STEEL CASTING PRIVATE LIMITED, KANGANWAL ROAD

In the result, appeal of the assessee is allowed and the Cross appeal of the Revenue is dismissed

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

section 115JB of the Act. The notices u/s 143(2) and 142(1) alongwith questionnaires were issued to the Appellant Company from time to time which were responded to, and requisite information/details furnished. 5.1.3. During the course of assessment proceedings, a notice u/s 133(6) were also issued to RPS and also to some of the parties from whom

TARLOCHAN SINGH ,BHAWANIGARH vs. DCIT, CENTRAL CIRCLE, PATIALA

In the result, the appeal of the assessee is partly allowed

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

133 A of Income Tax Act 1961. 3. That Ld Commissioner of Income Tax (Appeals) & Assessing Officer was not justified to assess the surrendered amount as deemed income in contravention to Section 14j)f Income Tax Act 1961 as Assessing Officer assessed these amounts as income from undisclosed sources but added & assessed in business income. 4. That

DEPUTY COMMISSIONER OF INCOME TAX, CC-1, LUDHIANA, LUDHIANA vs. SHREE GANESH EDIBLES PVT. LTD., KHANNA

The appeal stand dismissed

Bench: SHRI RAJPAL YADAV (Vice President), SHRI MANOJ KUMAR AGGARWAL (Accountant Member)

133(6) on creditors of unsecured loans – Thereafter, Assessing Officer made additions with AY: 2019-20 & 2022-23 respect to unsecured loan on ground that assessee failed to discharge onus of liability as laid down under Section 68

DEPUTY COMMISSIONER OF INCOME TAX, CC-1, LUDHIANA, LUDHIANA vs. SHREE GANESH EDIBLES PVT. LTD., KHANNA

The appeal stand dismissed

Bench: SHRI RAJPAL YADAV (Vice President), SHRI MANOJ KUMAR AGGARWAL (Accountant Member)

133(6) on creditors of unsecured loans – Thereafter, Assessing Officer made additions with AY: 2019-20 & 2022-23 respect to unsecured loan on ground that assessee failed to discharge onus of liability as laid down under Section 68

RAJIV KUMAR GOYAL,DHURI vs. DCIT, CC-2, LUDHIANA

In the result, the appeal of the assessee is allowed

Bench: This Hon’Ble Tribunal Under Section 253 Of The Income Tax Act, 1961 As Amended From Time To Time. 2. The Assessee Is Aggrieved By Order Of The Ld. Cit(A) Dated 03/02/2023 In Appeal No. 10850/2018-19/It/Cit(A)-5/Ldh/2021-22 For A.Y. 2019-20 Under Section 250(6) Of The Income Tax Act, 1961 Which Was Dismissed. Therefore The Present Second Appeal Under Section 253 Of The Income Tax Act, 1961 Before Us Against The Aforesaid Order Dt. 03/02/2023 Which Is Hereiafter Referred To As The Impugned Order. Factual Matrix 3. The Assessee Had For The Relevant Year I.E; A.Y. 2019-20 Was Also Engaged In The Same Business I.E; Manufacturing Of Pvc Pipes & Had Filed

133(A) of the Income Tax Act, 1961. We also observe that on page 20 of the paper book where said statement is annexed at bottom the assessee has stated as under “ I further want to state this income will be shown over and above in our firm’s / companies normal income and whole of the tax which will

ACIT -CENTRAL CIRCLE-1,, LUDHIANA vs. M/S OSWAL TRENDS PVT. LTD., LUDHIANA

In the result, this appeal of the Revenue stands dismissed

Bench: Shri Sanjay Garg & Shri Krinwant Sahay

133(6) to the shareholders and reply thereof were also submitted. It is observed form the details & documents furnished by the appellant that in the cases of 2 share holders, namely 1) M/s Alfort Merchants Private Limited, 2) M/s Sharekhan Merchants Private Limited, the Assessment Orders u/s 143(3) for Lne AY 2012-13 were passed u/s. 143(3) without

ACIT -CENTRAL CIRCLE-1,, LUDHIANA vs. M/S OSWAL TRENDS PVT. LTD., LUDHIANA

In the result, this appeal of the Revenue stands dismissed

Bench: Shri Sanjay Garg & Shri Krinwant Sahay

133(6) to the shareholders and reply thereof were also submitted. It is observed form the details & documents furnished by the appellant that in the cases of 2 share holders, namely 1) M/s Alfort Merchants Private Limited, 2) M/s Sharekhan Merchants Private Limited, the Assessment Orders u/s 143(3) for Lne AY 2012-13 were passed u/s. 143(3) without

ACIT, CENTRAL CIRCLE -1,, LUDHIANA vs. M/S OSWAL APPARELS PVT. LTD., LUDHIANA

In the result, this appeal of the Revenue stands dismissed

Bench: Shri Sanjay Garg & Shri Krinwant Sahay

133(6) to the shareholders and reply thereof were also submitted. It is observed form the details & documents furnished by the appellant that in the cases of 2 share holders, namely 1) M/s Alfort Merchants Private Limited, 2) M/s Sharekhan Merchants Private Limited, the Assessment Orders u/s 143(3) for Lne AY 2012-13 were passed u/s. 143(3) without

ACIT, CENTRAL CIRCLE -1,, LUDHIANA vs. M/S OSWAL APPARELS PVT. LTD., LUDHIANA

In the result, this appeal of the Revenue stands dismissed

Bench: Shri Sanjay Garg & Shri Krinwant Sahay

133(6) to the shareholders and reply thereof were also submitted. It is observed form the details & documents furnished by the appellant that in the cases of 2 share holders, namely 1) M/s Alfort Merchants Private Limited, 2) M/s Sharekhan Merchants Private Limited, the Assessment Orders u/s 143(3) for Lne AY 2012-13 were passed u/s. 143(3) without

M/S OSWAL TREND (P) LTD.,LUDHIANA vs. DCIT, C. C.-1, LUDHIANA

In the result, this appeal of the Revenue stands dismissed

Bench: Shri Sanjay Garg & Shri Krinwant Sahay

133(6) to the shareholders and reply thereof were also submitted. It is observed form the details & documents furnished by the appellant that in the cases of 2 share holders, namely 1) M/s Alfort Merchants Private Limited, 2) M/s Sharekhan Merchants Private Limited, the Assessment Orders u/s 143(3) for Lne AY 2012-13 were passed u/s. 143(3) without