DCIT, CHANDIGARH vs. SH. KULWANT SINGH, MOHALI

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

15. Before proceedings further, we deem it fit to first discuss the relevant provisions of section 271(1)(c) of the Act as they stood during the relevant period / assessment year under consideration. ITA Nos.41 to 44, 387, 45 to 54/Chd/17 & CO 16-to 30-Chd-2018- Shri Kulwant Singh & Others, Mohali 21 “ 271. (1) If the Assessing Officer

DCIT, CHANDIGARH vs. SMT. JASWANT KAUR, MOHALI

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

15. Before proceedings further, we deem it fit to first discuss the relevant provisions of section 271(1)(c) of the Act as they stood during the relevant period / assessment year under consideration. ITA Nos.41 to 44, 387, 45 to 54/Chd/17 & CO 16-to 30-Chd-2018- Shri Kulwant Singh & Others, Mohali 21 “ 271. (1) If the Assessing Officer

DCIT, CHANDIGARH vs. SMT. JASWANT KAUR, MOHALI

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

15. Before proceedings further, we deem it fit to first discuss the relevant provisions of section 271(1)(c) of the Act as they stood during the relevant period / assessment year under consideration. ITA Nos.41 to 44, 387, 45 to 54/Chd/17 & CO 16-to 30-Chd-2018- Shri Kulwant Singh & Others, Mohali 21 “ 271. (1) If the Assessing Officer

DCIT, CHANDIGARH vs. SH. PARAMJIT SINGH, MOHALI

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

15. Before proceedings further, we deem it fit to first discuss the relevant provisions of section 271(1)(c) of the Act as they stood during the relevant period / assessment year under consideration. ITA Nos.41 to 44, 387, 45 to 54/Chd/17 & CO 16-to 30-Chd-2018- Shri Kulwant Singh & Others, Mohali 21 “ 271. (1) If the Assessing Officer

DCIT, CHANDIGARH vs. SH. PARAMJIT SINGH, MOHALI

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

15. Before proceedings further, we deem it fit to first discuss the relevant provisions of section 271(1)(c) of the Act as they stood during the relevant period / assessment year under consideration. ITA Nos.41 to 44, 387, 45 to 54/Chd/17 & CO 16-to 30-Chd-2018- Shri Kulwant Singh & Others, Mohali 21 “ 271. (1) If the Assessing Officer

M/S CHANDIGARH LAWN TENNIS ASSOCIATION,CHANDIGARH vs. ITO (EXEMPTIONS), CHANDIGARH

Bench: Shri Sanjay Garg & Ms. Annapurna Guptaassessment Year : 2013-14 Chandigarh Lawn Tennis Vs. The Ito (Exemptions), Association, Ward, Chandigarh Sector 10, Chandigarh Pan No. Aaatc4943J (Appellant) (Respondent) Appellant By : Sh. Y.K. Sud, Ca Respondent By : Smt. Chanderkanta, Addl. Cit (On 22.3.2018) & Sh.Yoginder Mittal, Sr. Dr (On 13.7.2018) Date Of Hearing : 22.03.2018 & 13.7.2018 Date Of Pronouncement : 26.07.2018

section 2(15) there is a paradigm shift from the earlier position. Though, some of the decisions of the Delhi High Court as referred to above and that of the Pb. & Hry. High Court in the case of The Tribune Trust (supra) have been delivered subsequent to the introduction of the second proviso to section 2(15

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

CHANDIGARH EDUCATIONAL SOCIETY,MOHALI vs. PR.CIT(CENTRAL)-GURGAON, AT CHANDIGARH

15 taxmann.com 235(All) • Kanahya Lal Punj Charitable Trust Vs. DIT (Exem.) [2008] 171 Taxman 134 (Delhi) • Commissioner of Income-tax Vs. V.G.P. Foundation (Madras High Court) Tax Case No. 31 of 1998 Oct. 8, 2002 • Parivar Sewa Sanstha Vs. Deputy Director of Income-tax [2005] 1 SOT 71 (Del) • Action for Welfare & Awakening in Rural Environment (AWARE) Vs. Deputy

SHRI GURU RAM DASS EDUCATIONAL SOCIETY,MOHALI vs. PR.CIT(CENTRAL) GURGAON, AT CHANDIGARH

15 taxmann.com 235(All) • Kanahya Lal Punj Charitable Trust Vs. DIT (Exem.) [2008] 171 Taxman 134 (Delhi) • Commissioner of Income-tax Vs. V.G.P. Foundation (Madras High Court) Tax Case No. 31 of 1998 Oct. 8, 2002 • Parivar Sewa Sanstha Vs. Deputy Director of Income-tax [2005] 1 SOT 71 (Del) • Action for Welfare & Awakening in Rural Environment (AWARE) Vs. Deputy

CHANDIGARH EDUCATIONAL TRUST,MOHALI vs. PR.CIT-CENTRAL,GURGAON, AT CHANDIGARH

15 taxmann.com 235(All) • Kanahya Lal Punj Charitable Trust Vs. DIT (Exem.) [2008] 171 Taxman 134 (Delhi) • Commissioner of Income-tax Vs. V.G.P. Foundation (Madras High Court) Tax Case No. 31 of 1998 Oct. 8, 2002 • Parivar Sewa Sanstha Vs. Deputy Director of Income-tax [2005] 1 SOT 71 (Del) • Action for Welfare & Awakening in Rural Environment (AWARE) Vs. Deputy

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)

68 of Income Tax Act 1961 but if such income from undisclosed sources, though, invested had not been recorded in the assessee's books, than such income is liable to be assessed in terms of section 69 of Income Tax Act 1961. vii. In Roshan Lai Madan VS CIT 245 ITR (AT) 36 (Chandigarh) AND Jagmohan Ram Ram Chandra

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)

15,010/-. Thereafter, notice under section 143(2) and 142(1) alongwith detailed questionnaire were issued to the assessee. It was stated by the AO that during the course of search proceedings as well as assessment proceedings, it has been noticed that the assessee has received share premium of Rs. 28.26 Cr. on 30/03/2012 from three Kolkata based companies

ANUPAM,BARNALA vs. INCOME TAX OFFICER, BARNALA

In the result, Assessee’s appeal is allowed

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

15- 09-2014] whereby the Hon'ble Court laid down General Principles concerning retrospectivity, para 31 of which reads as under:- "31. Of the various rules guiding how a legislation has to be interpreted, one established rule is that unless a contrary intention appears, a legislation is presumed not to be intended to have a retrospective operation. The idea behind

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

In the result, the ground no

Bench: SHRI. SANJAY GARG (Judicial Member), 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

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