TARLOCHAN SINGH ,BHAWANIGARH vs. DCIT, CENTRAL CIRCLE, PATIALA

In the result, the appeal of the assessee is partly allowed

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

246 which is exercised in accordance with procedure with Section 250 indicate the amplitude and width which is no less wide than that of an ITO and the Appellate Authority could substitute the order of the ITO by one of his own." From the above, it is very clear that the powers of CIT(A) are coterminus with that

SH. KRISHAN KUMAR,KHANNA vs. DCIT, CC-1, LUDHIANA

In the result, the appeal of the Assessee is allowed

Bench: Shri A.D. Jain & Shri Vikram Singh Yadav

68 of the Act and computed the Tax liability under the provisions of the section 115BBE of the Act." 7.7 As regards, the charging of income tax @ 60% invoking the provisions of section 115BBE on the income declared by 175-Chd-2023– Shri Krishan Kumar, Khanna 18 the Assessee in its return of income. The Assessee has already

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

68, section 69, section 69A, section 69B, section 69C or section 69D, if such income is not covered under clause (a), the income-tax payable shall be the aggregate of- (i) the amount of income-tax calculated on the income referred to in clause (a) and clause (b), at the rate of sixty per cent

M/S JASHAN FINLEASE LTD.,KHANNA vs. DCIT, CC-1, LUDHIANA

In the result, the appeal of the assessee is allowed

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

68 or 69 would not hold good. In our view, in such a situation, the AO could not have legally and validly resorted to taxing the income of the assessee at the rate of 60% in terms of provisions of section 115BBE of the Act. 10.18 The Hon'ble Andhra Pradesh High Court in the case of Principal Commissioner

RAV SHARAN SINGH,PATIALA vs. ACIT, C.C., PATIALA

In the result, appeal of the assessee is allowed

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

68 or 69 would not hold good. In our view, in such a situation, the AO could not have legally and validly resorted to taxing the income of the assessee at the rate of 60% in terms of provisions of section 115BBE of the Act. 10.18 The Hon'ble Andhra Pradesh High Court in the case of Principal Commissioner

SARU ENTERPRISES PRIVATE LIMITED,PATIALA vs. ACIT/DCIT, CEN. CIR., PATIALA

In the result, the appeal of the assessee is allowed

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

68 were invoked by the Ld. CIT(A) as the amount was found credited in the books of accounts and income of the assessee was enhanced accordingly. 15. Against the said findings and direction of the Ld. CIT(A), the assessee is in appeal before us. 16. During the course of hearing, the Ld. AR submitted that the assessee company

JOINT COMMISSIONER OF INCOME TAX (OSD), LUDHIANA vs. M/S SHEETAL INDUSTRIES , KHANNA

The appeal of the Revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahay

68 or 69 would not hold good. In our view, in such a situation, the AO could not have legally and validly resorted to taxing the income of the Assessee at the rate of 60% in terms of provisions of section 115BBE of the Act. 10.18 The Hon'ble Andhra Pradesh High Court in the case of Principal Commissioner

MRS. KIRAN BALA,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the appeal is allowed

Bench: SHRI A.D.JAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)

68 or 69 would not hold good. In our view, in such a situation, the AO could not have legally and validly resorted to taxing the income of the Assessee at the rate of 60% in terms of provisions of section 115BBE of the Act. 10.18 The Hon'ble Andhra Pradesh High Court in the case of Principal Commissioner

M/S VEER ENTERPRISES,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the appeal is allowed

Bench: SHRI A.D.JAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)

68 or 69 would not hold good. In our view, in such a situation, the AO could not have legally and validly resorted to taxing the income of the Assessee at the rate of 60% in terms of provisions of section 115BBE of the Act. 10.18 The Hon'ble Andhra Pradesh High Court in the case of Principal Commissioner

SH. GURINDER MAKKAR,LUDHIANA vs. DCIT, CC-3, LUDHIANA

In the result, the appeal of the assessee is disposed off in light of aforesaid directions

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

68 or 69 would not hold good. In our view, in such a situation, the AO could not have legally and validly resorted to taxing the income of the assessee at the rate of 60% in terms of provisions of section 115BBE of the Act. 10.18 The Hon'ble Andhra Pradesh High Court in the case of Principal Commissioner

M/S VIRTUOSO NETSOFT PVT. LTD.,CHANDIGARH vs. DCIT, C-1(1), CHANDIGARH

In the result, appeal of the assessee is allowed

section 68 of the Act was not justified. 7. In his rival submissions the Ld. DR strongly supported the orders of the authorities below and further submitted that the firm M/s Vastech Solution was dissolved therefore the assessee could not have taken loan from the firm which was not in existence. 8. We have considered the submissions of both

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

M/S SHAM JEWELLERS,CHANDIGARH vs. THE DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -1, CHANDIGARH

In the result, ITA No. 315/Chd/2022 also stands

Bench: Shri N.K. Saini & Shri Sudhanshu Srivastava

68 or 69 would not hold good. In our view, in such a situation, the AO could not have legally and validly resorted to taxing the income of the assessee at the rate of 60% in terms of provisions of section 115BBE of the Act. 10.18 The Hon'ble Andhra Pradesh High Court in the case of Principal Commissioner

M/S SHAM FASHION MALL,CHANDIGARH vs. THE DY.C.I.T., CENTRAL CIRCLE -1, CHANDIGARH

In the result, ITA No. 315/Chd/2022 also stands

Bench: Shri N.K. Saini & Shri Sudhanshu Srivastava

68 or 69 would not hold good. In our view, in such a situation, the AO could not have legally and validly resorted to taxing the income of the assessee at the rate of 60% in terms of provisions of section 115BBE of the Act. 10.18 The Hon'ble Andhra Pradesh High Court in the case of Principal Commissioner

SH. AMBRISH SHARMA PROP. M/S PUNJAB HANDLOOM,LUDHIANA vs. DCIT, CC-2, LUDHIANA

In the result, appeal of the Assessee is allowed

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 461/Chd/2023 निर्धारण वर्ष / Assessment Year : 2019-20 Shri Ambrish Sharma, Prop. M/s Punjab Handloom, Near Petrol Pump, Link Road, Ludhiana-141003, Punjab बनाम The DCIT Central Circle-2, Ludhiana स्थायी लेखा सं./PAN NO: AYVPS7324Q अपीलार्थी/Appellant प्रत्यर्थी/Respondent निर्धारिती की ओर से / Assessee by : Shri Sudhir Sehgal, Advocate राजस्व की ओर से / Revenue by : Shri Vivek Vardhan, Addl. CIT, Sr. DR स

68, 69, 69A, 69B, 69C and 69D and as such surrendered income was charged to tax as per the provisions of section 115BBE. 5. The assessee responded to that query during the course of assessment proceedings that he has been engaged in the business of wholesale and retail trade of suiting, shirting, handlooms products and other apparels under

M/S AMARJIT & SONS,LUDHIANA vs. DCIT, CC-2, LUDHIANA

In the result, appeal of the assessee is allowed

Bench: The Ld. Cit(A) Have Not Been Appreciated.

68 or 69 would not hold good. In our view, in such a situation, the AO could not have legally and validly resorted to taxing the income of the assessee at the rate of 60% in terms of provisions of section 115BBE of the Act. 10.18 The Hon'ble Andhra Pradesh High Court in the case of Principal Commissioner

M/S A.P. KNIT FAB,LUDHIANA vs. DCIT CC-3, LUDHIANA

In the result, the appeal of the assessee is allowed

Bench: The Ld. Cit(A) Have Not Been Appreciated. 4. That The Ld. Cit(A) Has Failed To Appreciate That During The Course Of Survey, No Other Income Was Noticed By The Department And, As Such, Taxing The Amount Offered As Deemed Income, Is Against The Facts & Circumstances Of The Case. 5. That The Ld. Cit(A) Has Also Failed To Appreciate That At The Time Of Survey, It Was Agreed That The Applicant Shall Pay The Taxes On The Amount Offered

68 or 69 would not hold good. In our view, in such a situation, the AO could not have legally and validly resorted to taxing the income of the assessee at the rate of 60% in terms of provisions of section 115BBE of the Act. 10.18 The Hon'ble Andhra Pradesh High Court in the case of Principal Commissioner

RADHA MITTAL,LUDHIANA vs. ITO- WARD 7(3), LUDHIANA

In the result, the appeal of the assessee is allowed in light

Bench: Shri Sanjay Garg & Shri Vikram Singh Yadavradha Mittal, Ito बनाम H. No. 85-A, Aggar Nagar, Ward- 7(3), Ludhiana- 141012 Ludhiana

68 of the Act. 3. Being aggrieved, the assessee carried the matter in appeal before the ld. CIT(A) wherein the assessment proceedings were challenged both on the legality as well as merits of the case. However, the appeal of the assessee was dismissed and against the said findings and order of the ld. CIT(A), the assessee

BANSAL RICE TRADERS,SANGRUR vs. ITO-WARD, SANGRUR

In the result, appeal of the assessee is allowed

68 of the Income Tax Act, 1961. During the F.Y. 2009-10 the assessee has also received income from Contract u/s 194A of the Income Tax Act, 1961 amounting to Rs.2,23,119/- (Punjab Agro Food Grain Corporation Ltd.). In view of above I have reasons to believe that the income chargeable to tax to the extent