SANJEEV KUMAR GOYAL,FATEHABAD vs. DCIT, CC-2, LUDHIANA

In the result, the appeal of the assesse 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 The Order Of The Ld. Cit(A) Dt. 20/01/2023 In Appeal No. 10853/2018-19/It/Cit(A)-5/Ldh/2021-22 For The 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. 20/01/2023 Which Is Hereinafter Referred To As The Impugned Order.

3 of assessee made before us the Ld. DR has averred as under: 11. The assessee in his brief submissions submitted on 03.07.2023 before Tribunal, he has made following submissions (Page 5 onwards):- A) The assessee has made journal entry in the books of accounts by debiting the building under construction account and crediting income surrender on account of survey

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

3 essential ingredients to prove the source in order to escape the rigors of the deeming fiction has been upheld universally. The conjoint burden of proving the 'nature and source' is therefore, not restricted to merely claiming the nexus of any activity/transaction to a particular credit/income/asset but also requires to establish with cogent evidence the nexus of such activity/transaction with

SSMT. CHARU AGGARWAL,PATIALA vs. DCIT-CC, PATIALA

In the result, appeals of both the assesses are allowed

3) and - assessment to be completed as provided u/s 144. It was further mentioned that during demonetization the assessee deposited Rs. 2,90,20,000/- in its CC account and was required to produced documentary evidence with regard to source of cash deposit and proposed to make appropriate addition on account of 'non- genuine' sales entered after demonetization, in back

KALANEEDHI JEWELLERS LLP,PATIALA vs. DCIT-CC, PATIALA

In the result, appeals of both the assesses are allowed

3) and - assessment to be completed as provided u/s 144. It was further mentioned that during demonetization the assessee deposited Rs. 2,90,20,000/- in its CC account and was required to produced documentary evidence with regard to source of cash deposit and proposed to make appropriate addition on account of 'non- genuine' sales entered after demonetization, in back

INDERJIT SINGH BRAR,PATIALA vs. INCOME TAX OFFICER, PATIALA

In the result, appeal of the assessee is allowed

Bench: Shri Rajpal Yadav

68 of the IT Act, 1961. In this connection, the appellant reply is as under: The copy of account statement of Sh. Amarinder Singh in assessee's books of accounts is as under:- DATE ENTRY DEBIT CREDIT 01.04. 2016 OPENINGBALANCE - 2,30,000/- 08.04.2016 HDFC Bank - 2,00,000/- 30.05.2016 HDFC Bank 3,00,000/- - 13.06.2016 HDFC Bank - 3

INCOME TAX OFFICER WARD 6 (1), MOHALI vs. SKYCITY BUILDERS AND PROMOTERS PRIVATE LIMITED, KHRAR PUNJAB

In the result, the corresponding grounds as raised by the revenue stand dismissed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No.1066/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2012-13) M/S Skycity Builders & Promoters Pvt. Ltd. Dcit Ward 6(1) बनाम/ Room No.3, 1St Floor Sco-90, City Heart Kharar-Chandigarh Road, Livestock Complex Vs. Kharar, Rupnagar (Punjab) - 140301 Sector – 68, Mohali -160062 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aapcs-2435-R (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकर अपील सं./ Ita No.1217/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2012-13) Dcit Ward 6(1) M/S Skycity Builders & Promoters Pvt. Ltd. बनाम/ Room No.3, 1St Floor Sco-90, City Heart Livestock Complex Kharar-Chandigarh Road, Vs. Sector – 68, Mohali -160062 Kharar, Rupnagar (Punjab) - 140301 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aapcs-2435-R (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Sudhir Sehgal (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Ms. Yamini (Cit) - Ld. Dr (Virtual) सुनवाईकीतारीख/Date Of Hearing : 05.02.2026 घोषणाकीतारीख /Date Of Pronouncement : 16.03.2026

3) has taken place in the case of the assessee for the relevant year”. In para-3 also, it has been recorded by Ld. AO that “On physical verification as well as from the ITD database, it is gathered that no return has been filed by the assessee for the A.Y.2012-13…”. Similar fact has been reiterated at paras

SKYCITY BUILDERS AND PROMOTERS PRIVATE LIMITED, ,KHARAR, RUPNAGAR vs. DCIT WARD 6(1), CHANDIGARH JAO ITO 6(1) MOHALI, CHANDIGARH

In the result, the corresponding grounds as raised by the revenue stand dismissed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No.1066/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2012-13) M/S Skycity Builders & Promoters Pvt. Ltd. Dcit Ward 6(1) बनाम/ Room No.3, 1St Floor Sco-90, City Heart Kharar-Chandigarh Road, Livestock Complex Vs. Kharar, Rupnagar (Punjab) - 140301 Sector – 68, Mohali -160062 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aapcs-2435-R (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकर अपील सं./ Ita No.1217/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2012-13) Dcit Ward 6(1) M/S Skycity Builders & Promoters Pvt. Ltd. बनाम/ Room No.3, 1St Floor Sco-90, City Heart Livestock Complex Kharar-Chandigarh Road, Vs. Sector – 68, Mohali -160062 Kharar, Rupnagar (Punjab) - 140301 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aapcs-2435-R (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Sudhir Sehgal (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Ms. Yamini (Cit) - Ld. Dr (Virtual) सुनवाईकीतारीख/Date Of Hearing : 05.02.2026 घोषणाकीतारीख /Date Of Pronouncement : 16.03.2026

3) has taken place in the case of the assessee for the relevant year”. In para-3 also, it has been recorded by Ld. AO that “On physical verification as well as from the ITD database, it is gathered that no return has been filed by the assessee for the A.Y.2012-13…”. Similar fact has been reiterated at paras

SH. MAHESH CHUGH,CHANDIGARH vs. PR.CIT-2, CHANDIGARH

In the result, the appeal of the assessee is allowed

Section 54F of the Act, the permissible deduction comes to Rs. 1,47,37,254/- as against claimed and allowed at the time of assessment at Rs. 1,85,85,741/-.” 8.1. The ld. CIT-DR sought time to verify the calculations and consult from the field as to what is the exact figure in dispute; he submitted that

FASHION ZONE,LUDHIANA vs. JCIT, WARD III(2), LUDHIANA

In the result, the appeal of the assessee is allowed

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

3. Notwithstanding the above said ground of appeal, since the sales made by the assessee have been accepted as per books of accounts and, as such, the addition made u/s 68 to the tune of Rs. 19,13,078/- amounts to double addition, which is not proper when all the purchases and sales have been accepted. 4. That appellant craves

RANJIT SINGH,PANCHKULA vs. DEPUTY DIRECTOR, CPC DEPARTMENT

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

Section 16 or Section 17 of the Act. We, therefore, hold that the statutory interest paid under Section 34 of the Act is interest paid for the delayed payment of the compensation amount and, therefore, is a revenue receipt liable to tax under the Income Tax Act." 9. This position of law has been consistently reiterated

INCOME TAX OFFICER, FATEHABAD vs. MAHESH NAGPAL, FATEHABAD

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

Section 16 or Section 17 of the Act. We, therefore, hold that the statutory interest paid under Section 34 of the Act is interest paid for the delayed payment of the compensation amount and, therefore, is a revenue receipt liable to tax under the Income Tax Act." 9. This position of law has been consistently reiterated

PAWAN KUMAR,FATEHABAD vs. INCOME TAX OFFICER WARD-1, FATEHABAD

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

Section 16 or Section 17 of the Act. We, therefore, hold that the statutory interest paid under Section 34 of the Act is interest paid for the delayed payment of the compensation amount and, therefore, is a revenue receipt liable to tax under the Income Tax Act." 9. This position of law has been consistently reiterated

SMT. SHANKRI DEVI,PANCHKULA vs. ACIT, PANCKULA CIRCLE, PANCHKULA

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

Section 16 or Section 17 of the Act. We, therefore, hold that the statutory interest paid under Section 34 of the Act is interest paid for the delayed payment of the compensation amount and, therefore, is a revenue receipt liable to tax under the Income Tax Act." 9. This position of law has been consistently reiterated

SAROJ CHAUDHARY BALA,PANCHKULA vs. ITO, WARD-4, PANCHKULA

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

Section 16 or Section 17 of the Act. We, therefore, hold that the statutory interest paid under Section 34 of the Act is interest paid for the delayed payment of the compensation amount and, therefore, is a revenue receipt liable to tax under the Income Tax Act." 9. This position of law has been consistently reiterated

SH. AMARDEEP SINGH ATHWAL,YAMUNANAGAR vs. ITO, WARD-1, YAMUNANAGAR

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

Section 16 or Section 17 of the Act. We, therefore, hold that the statutory interest paid under Section 34 of the Act is interest paid for the delayed payment of the compensation amount and, therefore, is a revenue receipt liable to tax under the Income Tax Act." 9. This position of law has been consistently reiterated

SH. AMARDEEP SINGH ATHWAL,YAMUNANAGAR vs. ITO, WARD-1, YAMUNANAGAR

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

Section 16 or Section 17 of the Act. We, therefore, hold that the statutory interest paid under Section 34 of the Act is interest paid for the delayed payment of the compensation amount and, therefore, is a revenue receipt liable to tax under the Income Tax Act." 9. This position of law has been consistently reiterated

ARJESH KUMAR,PATIALA vs. ITO NATIONAL E-ASSESSMENT CENTRE , DELHI

Section 16 or Section 17 of the Act. We, therefore, hold that the statutory interest paid under Section 34 of the Act is interest paid for the delayed payment of the compensation amount and, therefore, is a revenue receipt liable to tax under the Income Tax Act." 9. This position of law has been consistently reiterated

BALBIR KUMAR HUF,CHANDIGARH vs. ITO , CHANDIGARH

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

Section 16 or Section 17 of the Act. We, therefore, hold that the statutory interest paid under Section 34 of the Act is interest paid for the delayed payment of the compensation amount and, therefore, is a revenue receipt liable to tax under the Income Tax Act." 9. This position of law has been consistently reiterated

LATE SH. GHANSHAM DASS THROUGH L/H SH.DEVINDER SINGH,CHANDIGARH vs. DCIT-CC-1, CHANDIGARH

Appeals stand partly allowed

Bench: Shri N.K. Saini & Shri Sudhanshu Srivastavaआयकर अपील सं./ Ita Nos. 5 To 7/Chd/2021 "नधा"रण वष" / Assessment Years : 2015-16 To 2017-18 Late Sh. Ghansham Dass, The Dcit, बनाम Through L/H Sh. Davinder Singh, Central Circle-1, Sco 168-169, Sector 34, Chandigarh Chandigarh "थायी लेखा सं./Pan No: Aanpd3889R अपीलाथ"/Appellant ""यथ"/Respondent

68,89,504/- in assessment year 2015-16, interest expenditure of Rs. 65,57,340/- in assessment year 2016-17 and interest expenditure of Rs. 16,82,964/- in assessment year 2017-18. The Assessing officer confronted the assessee on the issue of interest expenditure and the assessee was asked to justify the reason for claiming interest expenditure which