SCOTT EDIL ADVANCE RESEARCH LABORATORIES AND EDUCATION LIMITED,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.\n16\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

SCOTT EDIL ADVANCE RESEARCH LABORATORIES AND EDUCATION LIMITED,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.\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

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.\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

SCOTT EDIL ADVANCE RESEARCH LABORATORIES AND EDUCATION LIMITED,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.\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

SCOTT EDIL PHARMACIA LTD.,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.\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

MAXPORT INDIA PRIVATE LIMITED,CHANDIGARH vs. DY. 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.\n16\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

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

MAXPORT INDIA PRIVATE LIMITED,CHANDIGARH vs. DY. 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.\n16\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

SCOTT EDIL PHARMACIA LTD.,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.\n15\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

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.\n16\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

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.\n16\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

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.\n16\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

SCOTT EDIL ADVANCE RESEARCH LABORATORIES AND EDUCATION LIMITED,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.\n\n16\n\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

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...\n...\n...\n16\n8. Ground No. 8 and 9 -Carry forward of MAT credit against the demand raised\nconsequent to impugned addition made in assessment.\n9. Ground

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

220 TAXMAN 336 (Kerala HC),\nc) CIT vs. K. Jayakumar, 216 TAXMAN 166 (Madras HC), and\nd) CIT vs. D. Subramanian, 296 ITR 348 (Chennai HC)\n48. Further, the ld. Counsel for the assessee also contended that the difference in\nreport of DVO and as per books was less than 10% and therefore, the addition u/s 69B\nwas not sustainable

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, can be initiated in the year of such credit. Moreover, it is also being mentioned here that in the A.Y. 2013-14, the then AO specifically given office note about the reference to Foreign Authorities and about remedial action to be taken on the basis of information received till that date from Singapore Authority. The assessee also claimed that

SH. BALJIT SINGH,LUDHIANA vs. PR. CIT, LUDHIANA -1, LUDHIANA

In the result, appeal of the Assessee is dismissed

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

68 with regard to unsecured loans and payment of interest thereon as a consequence thereof expenditure of Rs. 1,32,97,887/- has remained unexplained. The other issue dealt by him in para 4 & 5(supra) of the impugned order stands dealt with in fresh assessment order dt. 27/03/2023-i.e; the consequential order passed in pursuance to order under section

ASSISTANT COMMISSIONER OF INCOME TAX, PANCHKULA CIRCLE, PANCHKULA, PANCHKULA vs. THE HARYANA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT, PANCHKULA

Appeal is allowed

Bench: SHRI. RAJPALYADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

220 (SC). 8.3 By respectfully following the above decisions of the Hon’ble Supreme Court, we hold that the Assessing Officer recorded valid reasons and obtained due approval from the competent authority. Accordingly, we uphold the finding of the Ld. CIT(A) and find no infirmity in the initiation and conclusion of the reassessment proceedings. Ground No. 2 is dismissed