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

158B(b) of the Act. It is for the above\nreason that Sections 153A and 153C begin with a non-obstante clause in order\nto make these provisions exclusive of Sections 139, 147, 148, 149, 151 and 153\nof the Act. If a search operation does not lead to detection of undisclosed income\nas defined in Chapter

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

158B(b) of the Act. It is for the above\nreason that Sections 153A and 153C begin with a non-obstante clause in order\nto make these provisions exclusive of Sections 139, 147, 148, 149, 151 and 153\nof the Act. If a search operation does not lead to detection of undisclosed income\nas defined in Chapter

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

158B(b) of the Act. It is for the above\nreason that Sections 153A and 153C begin with a non-obstante clause in order\nto make these provisions exclusive of Sections 139, 147, 148, 149, 151 and 153\nof the Act. If a search operation does not lead to detection of undisclosed income\nas defined in Chapter

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

158B(b) of the Act. It is for the above\nreason that Sections 153A and 153C begin with a non-obstante clause in order\nto make these provisions exclusive of Sections 139, 147, 148, 149, 151 and 153\nof the Act. If a search operation does not lead to detection of undisclosed income\nas defined in Chapter

SH. SARANJIT SINGH,PATIALA vs. ACIT, CENTRAL CIRCLE -2, CHANDIGARH

In the result, the appeals of the assessees stand allowed

Bench: Shri Sanjay Garg & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 381 & 382/Chd/2022 "नधा"रण वष" / Assessment Years: 2009-10 & 2011-12 Shamsher Singh, Vs. The Acit बनाम Central Circle-2, 11-A, Gen Chanda Singh Chandigarh Colony, Patiala 147001 "थायी लेखा सं./Pan No: Ahjps3586P अपीलाथ"/ Appellant ""यथ"/ Repsondent & आयकर अपील सं./ Ita Nos. 383 & 384/Chd/2023 "नधा"रण वष" / Assessment Years: 2009-10 & 2011-12 Vs. The Acit Saranjit Singh, बनाम Centralcircle-2, 11-A, Gen Chanda Chandigarh Singh Colony, Patiala 147001 "थायी लेखा सं./Pan No: Amwps9575J अपीलाथ"/ Appellant ""यथ"/ Repsondent ( Hybrid Hearing )

68,921/- 13.32% 35,820/- 11. The ld. Counsel has submitted that the difference of amount of investment in the said property at Gopal Leela Bhawan Chowk, Patiala even as per the DVO’s report is a meagre figure Rs.40,150/- which is less than 10% and is liable to be ignored. The ld. Counsel has further submitted that

SH. SARANJIT SINGH,PATIALA vs. ACIT, CENTRAL CIRCLE -2, CHANDIGARH

In the result, the appeals of the assessees stand allowed

Bench: Shri Sanjay Garg & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 381 & 382/Chd/2022 "नधा"रण वष" / Assessment Years: 2009-10 & 2011-12 Shamsher Singh, Vs. The Acit बनाम Central Circle-2, 11-A, Gen Chanda Singh Chandigarh Colony, Patiala 147001 "थायी लेखा सं./Pan No: Ahjps3586P अपीलाथ"/ Appellant ""यथ"/ Repsondent & आयकर अपील सं./ Ita Nos. 383 & 384/Chd/2023 "नधा"रण वष" / Assessment Years: 2009-10 & 2011-12 Vs. The Acit Saranjit Singh, बनाम Centralcircle-2, 11-A, Gen Chanda Chandigarh Singh Colony, Patiala 147001 "थायी लेखा सं./Pan No: Amwps9575J अपीलाथ"/ Appellant ""यथ"/ Repsondent ( Hybrid Hearing )

68,921/- 13.32% 35,820/- 11. The ld. Counsel has submitted that the difference of amount of investment in the said property at Gopal Leela Bhawan Chowk, Patiala even as per the DVO’s report is a meagre figure Rs.40,150/- which is less than 10% and is liable to be ignored. The ld. Counsel has further submitted that

SH. SHAMSHER SINGH,PATIALA vs. ACIT, CENTRAL CIRCLE-2, CHANDIGARH

In the result, the appeals of the assessees stand allowed

Bench: Shri Sanjay Garg & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 381 & 382/Chd/2022 "नधा"रण वष" / Assessment Years: 2009-10 & 2011-12 Shamsher Singh, Vs. The Acit बनाम Central Circle-2, 11-A, Gen Chanda Singh Chandigarh Colony, Patiala 147001 "थायी लेखा सं./Pan No: Ahjps3586P अपीलाथ"/ Appellant ""यथ"/ Repsondent & आयकर अपील सं./ Ita Nos. 383 & 384/Chd/2023 "नधा"रण वष" / Assessment Years: 2009-10 & 2011-12 Vs. The Acit Saranjit Singh, बनाम Centralcircle-2, 11-A, Gen Chanda Chandigarh Singh Colony, Patiala 147001 "थायी लेखा सं./Pan No: Amwps9575J अपीलाथ"/ Appellant ""यथ"/ Repsondent ( Hybrid Hearing )

68,921/- 13.32% 35,820/- 11. The ld. Counsel has submitted that the difference of amount of investment in the said property at Gopal Leela Bhawan Chowk, Patiala even as per the DVO’s report is a meagre figure Rs.40,150/- which is less than 10% and is liable to be ignored. The ld. Counsel has further submitted that

SH. SHAMSHER SINGH,PATIALA vs. ACIT, CENTRAL CIRCLE-2, CHANDIGARH

In the result, the appeals of the assessees stand allowed

Bench: Shri Sanjay Garg & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 381 & 382/Chd/2022 "नधा"रण वष" / Assessment Years: 2009-10 & 2011-12 Shamsher Singh, Vs. The Acit बनाम Central Circle-2, 11-A, Gen Chanda Singh Chandigarh Colony, Patiala 147001 "थायी लेखा सं./Pan No: Ahjps3586P अपीलाथ"/ Appellant ""यथ"/ Repsondent & आयकर अपील सं./ Ita Nos. 383 & 384/Chd/2023 "नधा"रण वष" / Assessment Years: 2009-10 & 2011-12 Vs. The Acit Saranjit Singh, बनाम Centralcircle-2, 11-A, Gen Chanda Chandigarh Singh Colony, Patiala 147001 "थायी लेखा सं./Pan No: Amwps9575J अपीलाथ"/ Appellant ""यथ"/ Repsondent ( Hybrid Hearing )

68,921/- 13.32% 35,820/- 11. The ld. Counsel has submitted that the difference of amount of investment in the said property at Gopal Leela Bhawan Chowk, Patiala even as per the DVO’s report is a meagre figure Rs.40,150/- which is less than 10% and is liable to be ignored. The ld. Counsel has further submitted that

SHRI BALRAM KRISHAN,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH, CHANDIGARH

68 on account of amount received from Jai Ambe\nPharmaceutical (JAAPL) holding the company as a shell company.\n7. Ground No. 7 – Purchase transactions carried out allegedly outside books.\n\n\n17\n8. Ground No. 8 and 9 -Carry forward of MAT credit against the demand raised\nconsequent to impugned addition made in assessment.\n9. Ground No. 10 – Transfer order

SANJEEV AGGARWAL,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1 , CHANDIGARH

158B of the Income-tax Act, 1961 - Block assessment in search cases Undisclosed\nincome - Assessment year 1999-2000- Whether where no incriminating material\nwhatsoever was found during search that might show that assessee had made more\ninvestment in properties than their declared value, addition could not be made by\ntreating investment as undisclosed on basis of any DVO's report

SCOTT EDIL ADVANCE RESEARCH LABORATORIES AND EDUCATION LIMITED,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

158B of the Income-tax Act, 1961 - Block assessment in search cases Undisclosed\nincome - Assessment year 1999-2000- Whether where no incriminating material\nwhatsoever was found during search that might show that assessee had made more\ninvestment in properties than their declared value, addition could not be made by\ntreating investment as undisclosed on basis of any DVO's report

SHRI BALRAM KRISHAN,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH, CHANDIGARH

158B of the Income-tax Act, 1961 - Block assessment in search cases Undisclosed\nincome - Assessment year 1999-2000- Whether where no incriminating material\nwhatsoever was found during search that might show that assessee had made more\ninvestment in properties than their declared value, addition could not be made by\ntreating investment as undisclosed on basis of any DVO's report

MAXPORT INDIA PRIVATE LIMITED,CHANDIGARH vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,CHANDIGARH, CHANDIGARH

158B of the Income-tax Act, 1961 - Block assessment in search cases Undisclosed\nincome - Assessment year 1999-2000- Whether where no incriminating material\nwhatsoever was found during search that might show that assessee had made more\ninvestment in properties than their declared value, addition could not be made by\ntreating investment as undisclosed on basis of any DVO's report

SCOTT EDIL PHARMACIA LTD.,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

158B of the Income-tax Act, 1961 - Block assessment in search cases Undisclosed\nincome - Assessment year 1999-2000- Whether where no incriminating material\nwhatsoever was found during search that might show that assessee had made more\ninvestment in properties than their declared value, addition could not be made by\ntreating investment as undisclosed on basis of any DVO's report

SCOTT EDIL PHARMACIA LTD.,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

158B of the Income-tax Act, 1961 - Block assessment in search cases Undisclosed\nincome - Assessment year 1999-2000- Whether where no incriminating material\nwhatsoever was found during search that might show that assessee had made more\ninvestment in properties than their declared value, addition could not be made by\ntreating investment as undisclosed on basis of any DVO's report

MAXPORT INDIA PRIVATE LIMITED,CHANDIGARH vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,CHANDIGARH, CHANDIGARH

158B of the Income-tax Act, 1961 - Block assessment in search cases Undisclosed\nincome - Assessment year 1999-2000- Whether where no incriminating material\nwhatsoever was found during search that might show that assessee had made more\ninvestment in properties than their declared value, addition could not be made by\ntreating investment as undisclosed on basis of any DVO's report

SHRI BALRAM KRISHAN,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH, CHANDIGARH

158B of the Income-tax Act, 1961 - Block assessment in search cases Undisclosed\nincome - Assessment year 1999-2000- Whether where no incriminating material\nwhatsoever was found during search that might show that assessee had made more\ninvestment in properties than their declared value, addition could not be made by\ntreating investment as undisclosed on basis of any DVO's report

SCOTT EDIL PHARMACIA LTD.,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

158B of the Income-tax Act, 1961 - Block assessment in search cases Undisclosed\nincome - Assessment year 1999-2000- Whether where no incriminating material\nwhatsoever was found during search that might show that assessee had made more\ninvestment in properties than their declared value, addition could not be made by\ntreating investment as undisclosed on basis of any DVO's report

SANJEEV AGGARWAL,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

68 on account of amount received from Jai Ambe\nPharmaceutical (JAAPL) holding the company as a shell company.\n7. Ground No. 7 – Purchase transactions carried out allegedly outside books.\n18\n8. Ground No. 8 and 9 -Carry forward of MAT credit against the demand raised\nconsequent to impugned addition made in assessment.\n9. Ground No. 10 – Transfer order