OSWAL POLYCOT (INDIA) PVT. LTD.,LUDHIANA vs. DCIT, CC-I, LUDHIANA

In the result, the appeal of the assessee in ITA No

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

20, 350, Krishna Ludhiana Nagar, New Shopping Center, Ghumar Mandi, Ludhiana -141001 "ायी लेखा सं./PAN NO: AABCO2785N अपीलाथ"/Appellant ""थ"/Respondent िनधा"रती की ओर से/Assessee by : Shri Gaurav Sharma, C.A राज" की ओर से/ Revenue by : Smt. Kusum Bansal, CIT, DR सुनवाई की तारीख/Date of Hearing : 26/08/2024 उदघोषणा की तारीख/Date of Pronouncement : 14/11/2024 आदेश/Order

DCIT, CC-I, LUDHIANA vs. OSWAL POLYCOT (INDIA) PVT. LTD., LUDHIANA

In the result, the appeal of the assessee in ITA No

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

20, 350, Krishna Ludhiana Nagar, New Shopping Center, Ghumar Mandi, Ludhiana -141001 "ायी लेखा सं./PAN NO: AABCO2785N अपीलाथ"/Appellant ""थ"/Respondent िनधा"रती की ओर से/Assessee by : Shri Gaurav Sharma, C.A राज" की ओर से/ Revenue by : Smt. Kusum Bansal, CIT, DR सुनवाई की तारीख/Date of Hearing : 26/08/2024 उदघोषणा की तारीख/Date of Pronouncement : 14/11/2024 आदेश/Order

DCIT, CC-I, LUDHIANA vs. OSWAL POLYCOT (INDIA) PVT. LTD., LUDHIANA

In the result, the appeal of the assessee in ITA No

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

20, 350, Krishna Ludhiana Nagar, New Shopping Center, Ghumar Mandi, Ludhiana -141001 "ायी लेखा सं./PAN NO: AABCO2785N अपीलाथ"/Appellant ""थ"/Respondent िनधा"रती की ओर से/Assessee by : Shri Gaurav Sharma, C.A राज" की ओर से/ Revenue by : Smt. Kusum Bansal, CIT, DR सुनवाई की तारीख/Date of Hearing : 26/08/2024 उदघोषणा की तारीख/Date of Pronouncement : 14/11/2024 आदेश/Order

INCOME TAX OFFICER, PARWANOO vs. DEEPAK KUMAR, NAHAN

In the result, the appeal of the Revenue is dismissed

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

3), we find that firstly, there is no finding by the AO that the income so surrendered has been determined as income referred to in s. 68. s. 69, s. 69A, s. 698, s. 69C or s. 69D and secondly, in the computation of tax liability, the tax liability on the undisclosed income has been determined as per slab rate

DCIT, CHANDIGARH vs. SH. KULWANT SINGH, MOHALI

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

3) The provisions of sections 274 and 275 shall, as far as may be, apply in relation to the penalty referred to in this section.” 23. Prior to substitution of sub section (1) of section 115BBE w.e.f. 14.2017, the section 115 BBE was inserted by Finance Act 2012 w.e.f. 1.4.2013, which reads as under

DCIT, CHANDIGARH vs. SMT. MANJIT KAUR, CHANDIGARH

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

3) The provisions of sections 274 and 275 shall, as far as may be, apply in relation to the penalty referred to in this section.” 23. Prior to substitution of sub section (1) of section 115BBE w.e.f. 14.2017, the section 115 BBE was inserted by Finance Act 2012 w.e.f. 1.4.2013, which reads as under

DCIT, CHANDIGARH vs. SMT. JASWANT KAUR, MOHALI

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

3) The provisions of sections 274 and 275 shall, as far as may be, apply in relation to the penalty referred to in this section.” 23. Prior to substitution of sub section (1) of section 115BBE w.e.f. 14.2017, the section 115 BBE was inserted by Finance Act 2012 w.e.f. 1.4.2013, which reads as under

DCIT, CHANDIGARH vs. SH. PARAMJIT SINGH, MOHALI

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

3) The provisions of sections 274 and 275 shall, as far as may be, apply in relation to the penalty referred to in this section.” 23. Prior to substitution of sub section (1) of section 115BBE w.e.f. 14.2017, the section 115 BBE was inserted by Finance Act 2012 w.e.f. 1.4.2013, which reads as under

DCIT, CHANDIGARH vs. SH. KULWANT SINGH, MOHALI

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

3) The provisions of sections 274 and 275 shall, as far as may be, apply in relation to the penalty referred to in this section.” 23. Prior to substitution of sub section (1) of section 115BBE w.e.f. 14.2017, the section 115 BBE was inserted by Finance Act 2012 w.e.f. 1.4.2013, which reads as under

DCIT, CHANDIGARH vs. SMT. JASWANT KAUR, MOHALI

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

3) The provisions of sections 274 and 275 shall, as far as may be, apply in relation to the penalty referred to in this section.” 23. Prior to substitution of sub section (1) of section 115BBE w.e.f. 14.2017, the section 115 BBE was inserted by Finance Act 2012 w.e.f. 1.4.2013, which reads as under

DCIT, CHANDIGARH vs. SH. PARAMJIT SINGH, MOHALI

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

3) The provisions of sections 274 and 275 shall, as far as may be, apply in relation to the penalty referred to in this section.” 23. Prior to substitution of sub section (1) of section 115BBE w.e.f. 14.2017, the section 115 BBE was inserted by Finance Act 2012 w.e.f. 1.4.2013, which reads as under

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)

20. Section 69A of Income Tax Act 1961 is not applicable as there was no unexplained money which was not recorded in books of account. Moreover section 69A is deeming provision and Assessing Officer has to establish with cogent evidence that cash was unexplained & not recorded in books of account however in this case, the cash in hand

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)

3 who has overlapping period with table no 4, but only few entries are getting repeated in these pages. It establishes that each page is separate and maintained for separate purposes and has no 20 correlation with each other. Hence, onus is on assessee to explain and reconcile each and every entry mentioned on these pages. 3.10 Furthermore, assessee

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, LUDHIANA, LUDHIANA vs. M/S JAMNA DASS NIKKAMAL JAIN SARAF PVT. LTD., 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)

3 who has overlapping period with table no 4, but only few entries are getting repeated in these pages. It establishes that each page is separate and maintained for separate purposes and has no 20 correlation with each other. Hence, onus is on assessee to explain and reconcile each and every entry mentioned on these pages. 3.10 Furthermore, assessee

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)

3) r.w.s 147 dt. 28/12/2018 was challenged both in terms of assumption of jurisdiction under section 147 of the Act as well as on the merits of the addition so made by the AO. As far as the assessee’s challenge to the assumption of jurisdiction under section

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

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

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