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)

ii) or clause (iii) or Context Section 153A/153C clause (iv) of Explanation 2 to section 148 Search or requisition on the 1. Search/requisition assessee under Sections 2. Survey (except under 133A(2A)) on 132 /132A or material is assessee Triggering Event used against assessee from third 3. Search/requisition on another person, but party search assets/documents relate

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

68 Gurmeet Singh Bhangu Hard Disk Loose Sheets containing 70-73 details of cash paid to Gurmeet Singh with description "Manu Ji-cash paid to Gurmeet Singh C/o AjayPrabhakar" Ravi Kapoor Slip found form Pavments in connection 14 H. No. the E-Mail ID of with some Plot No. 286 & 7200/50bawaColone Sh. Ravi Kapoor 287 without any y, Naveen nagar

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

68 Gurmeet Singh Bhangu Hard Disk Loose Sheets containing 70-73 details of cash paid to Gurmeet Singh with description "Manu Ji-cash paid to Gurmeet Singh C/o AjayPrabhakar" Ravi Kapoor Slip found form Pavments in connection 14 H. No. the E-Mail ID of with some Plot No. 286 & 7200/50bawaColone Sh. Ravi Kapoor 287 without any y, Naveen nagar

WINSOME TEXTILE INDUSTRIES LIMITED,CHANDIGARH vs. ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-4(1), CHANDIGARH, CHANDIGARH

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

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

68 Income Tax Act, 1961 are without any basis and on the reliance of SEBI investigation of the lead manager to the issue, the SEBI report was also available on record as shown to the Authorised Representative of the assessee before the issue of the first notice of reassessment on 26.03.2017. As such, the assessment framed in respect of both

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)

143(3) of the Act by the learned AO is non-est and bad in law in as much as the proceedings have not been conducted in the manner prescribed by the department instructions from time to time which are mandatory for compliance by the learned AO since the impugned order has not been uploaded on the e-filing portal

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

143(3)/263 of the Income Tax Act because ld. Commissioner has taken action under Section 263 against an assessment order passed under Section 153A/143(3) dated 31.03.2015. A perusal of the complete assessment order would reveal that nothing is being possessed by the AO. He simply made reference of some report by the Director of Investigation, Calcutta

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

143(3)/263 of the Income Tax Act because ld. Commissioner has taken action under Section 263 against an assessment order passed under Section 153A/143(3) dated 31.03.2015. A perusal of the complete assessment order would reveal that nothing is being possessed by the AO. He simply made reference of some report by the Director of Investigation, Calcutta

DCIT, CHANDIGARH vs. SH. PARAMJIT SINGH, MOHALI

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

143(3) of the Act but also in the assessment proceedings carried out u/s 153A of the Act, Even, in respect of the some of the assessment years i.e. assessment years 2007-08, 2008-09 and 2009-10 stood completed and had not abated as on the date of search on 2.5.2012 and since no incriminating material was found during

DCIT, CHANDIGARH vs. SH. KULWANT SINGH, MOHALI

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

143(3) of the Act but also in the assessment proceedings carried out u/s 153A of the Act, Even, in respect of the some of the assessment years i.e. assessment years 2007-08, 2008-09 and 2009-10 stood completed and had not abated as on the date of search on 2.5.2012 and since no incriminating material was found during

DCIT, CHANDIGARH vs. SH. PARAMJIT SINGH, MOHALI

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

143(3) of the Act but also in the assessment proceedings carried out u/s 153A of the Act, Even, in respect of the some of the assessment years i.e. assessment years 2007-08, 2008-09 and 2009-10 stood completed and had not abated as on the date of search on 2.5.2012 and since no incriminating material was found during

DCIT, CHANDIGARH vs. SMT. MANJIT KAUR, CHANDIGARH

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

143(3) of the Act but also in the assessment proceedings carried out u/s 153A of the Act, Even, in respect of the some of the assessment years i.e. assessment years 2007-08, 2008-09 and 2009-10 stood completed and had not abated as on the date of search on 2.5.2012 and since no incriminating material was found during

DCIT, CHANDIGARH vs. SMT. JASWANT KAUR, MOHALI

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

143(3) of the Act but also in the assessment proceedings carried out u/s 153A of the Act, Even, in respect of the some of the assessment years i.e. assessment years 2007-08, 2008-09 and 2009-10 stood completed and had not abated as on the date of search on 2.5.2012 and since no incriminating material was found during

DCIT, CHANDIGARH vs. SMT. JASWANT KAUR, MOHALI

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

143(3) of the Act but also in the assessment proceedings carried out u/s 153A of the Act, Even, in respect of the some of the assessment years i.e. assessment years 2007-08, 2008-09 and 2009-10 stood completed and had not abated as on the date of search on 2.5.2012 and since no incriminating material was found during

DCIT, CHANDIGARH vs. SH. KULWANT SINGH, MOHALI

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

143(3) of the Act but also in the assessment proceedings carried out u/s 153A of the Act, Even, in respect of the some of the assessment years i.e. assessment years 2007-08, 2008-09 and 2009-10 stood completed and had not abated as on the date of search on 2.5.2012 and since no incriminating material was found during

M/S SATWANT AGRO ENGINEERS,BHAWANIGARH vs. DCIT, CENTRAL CIRCLE, PATIALA

In the result, the appeal of the assessee is partly allowed for statistical purposes

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

143(3) dt. 27/09/2021 wherein the AO brought to tax the excess stock surrendered during the course of survey under section 69, unexplained capital introduced in the capital account of the partners under section 69 and unexplained excess cash under section 69A as against these amounts shown by the assessee as business income while filing the return

SH. KRISHAN KUMAR GOYAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

In the result, both the appeals of the assessee stand allowed

Bench: Shri Sanjay Garg & Ms. Annapurna Guptaआयकर अपील सं./ Ita No. 226/Chd/2019 "नधा"रण वष" / Assessment Year : 2007-08 The Dcit, Shri Krishan Kumar Goyal, बनाम Central Circle-1, Prop Sagar Enterprise, Chandigarh Scf 153, Sector 26, Grain Market, Chandigarh "थायी लेखा सं./Pan No. Agipk9063H अपीलाथ"/Appellant ""यथ"/Respondent & आयकर अपील सं./ Ita No. 456/Chd/2019 "नधा"रण वष" / Assessment Year : 2007-08 The Dcit, Shri Krishan Kumar Goyal, बनाम Central Circle-1, Prop Sagar Enterprise, Chandigarh Scf 153, Sector 26, Grain Market, Chandigarh "थायी लेखा सं./Pan No. Agipk9063H अपीलाथ"/Appellant ""यथ"/Respondent

68 of the income tax act, 1961. 3. That the worthy CIT(C)(A) has erred in not considering that the amount was received through regular banking channel and sufficient proofs have been given to prove the identity, genuineness and credit worthiness of the concerned persons. ITA Nos. 226 & 456-Chd-2019 M/s Krishan Kumar Goyal, Chandigarh 3 4. That

SH. KRISHAN KUMAR GOYAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

In the result, both the appeals of the assessee stand allowed

Bench: Shri Sanjay Garg & Ms. Annapurna Guptaआयकर अपील सं./ Ita No. 226/Chd/2019 "नधा"रण वष" / Assessment Year : 2007-08 The Dcit, Shri Krishan Kumar Goyal, बनाम Central Circle-1, Prop Sagar Enterprise, Chandigarh Scf 153, Sector 26, Grain Market, Chandigarh "थायी लेखा सं./Pan No. Agipk9063H अपीलाथ"/Appellant ""यथ"/Respondent & आयकर अपील सं./ Ita No. 456/Chd/2019 "नधा"रण वष" / Assessment Year : 2007-08 The Dcit, Shri Krishan Kumar Goyal, बनाम Central Circle-1, Prop Sagar Enterprise, Chandigarh Scf 153, Sector 26, Grain Market, Chandigarh "थायी लेखा सं./Pan No. Agipk9063H अपीलाथ"/Appellant ""यथ"/Respondent

68 of the income tax act, 1961. 3. That the worthy CIT(C)(A) has erred in not considering that the amount was received through regular banking channel and sufficient proofs have been given to prove the identity, genuineness and credit worthiness of the concerned persons. ITA Nos. 226 & 456-Chd-2019 M/s Krishan Kumar Goyal, Chandigarh 3 4. That

ARYANS EDUCATIONAL AND CHARITABLE TRUST REGD, MOHALI,MOHALI vs. COMMISSIONER OF INCOME TAX, EXEMPTIONS, CHANDIGARH

In the result, appeal is allowed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 1136/Chd/2024 "नधा"रण वष" / Assessment Year: 2025-26 Aryans Educational & The Cit (Exemptions), Charitable Trust, Regd.Mohali Vs Chandigarh, C/O Shri Tej Mohan Singh, Advocate, # 527, Sector 10-D, Chandigarh. "थायी लेखा सं./Pan No: Aabta7550L अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Tej Mohan Singh, Advocate Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 07.08.2025 Date Of Pronouncement : 24.09.2025

68 of the Act treating corpus donations received from students to be anonymous donations. 8. We find that the not considering the evidence filed by the Assessee during the appellate proceedings before the ld. CIT(A) is not justified on the part of the ld. CIT(A). In fact, the case laws relied upon

M/S SADASHIV VENTURES,CHANDIGARH vs. DCIT, CIRCLE-1, CHANDIGARH

In the result, the appeal of the Assessee stands allowed

Bench: Shri A.D. Jain & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 33/Chd/2024 "नधा"रण वष" / Assessment Year : 2011-12 M/S Sadashiv Ventures, Vs. The Dcit, बनाम Circle-1, Sco 9, Sector 7, Chandigarh Madhya Marg, Chandigarh "थायी लेखा सं./Pan No: Abufs6758C अपीलाथ"/ Appellant ""यथ"/ Repsondent ( Physical Hering ) "नधा"रती क" ओर से/Assessee By : Shri Nikhil Goyal, Advocate & Shri Ashok Goyal, Ca राज"व क" ओर से/ Revenue By : Shri Vivek Vardhan, Jcit, Sr. Dr सुनवाई क" तार"ख/Date Of Hearing : 13.08.2024 उदघोषणा क" तार"ख/Date Of Pronouncement : 04.09.2024

68 based on surmises and conjectures and without considering the documents on record. 4. That the impugned order was totally based on conjectures and surmises which were the results of borrowed satisfaction. 5. That the loss incurred by the Assessee is genuine that can also be justified by the study of SEBI Study dated January 05, 2023 "Analysis of Profit