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

In the result, appeal of the assessee is allowed

250(4) and (5) read with sub- rule (4) of rule 46A. ' 5.2.7. In the present case, the details submitted by the appellant are crucial to the adjudication of the grounds raised in appeal inasmuch confirmation and bank accounts statements submitted by the appellant will help to adjudicate the matter in judicious way. The major addition on the appellant

SHRI BHUWAN GOYAL,LUDHIANA vs. DCIT, CC-1, LUDHIANA

In the result, appeal of the assessee is allowed

250(6) of the Income Tax Act, 1961 by the Ld. Commissioner of Income Tax(Appeals)-5, Ludhiana is against law and facts on the file in as much as he was not justified to arbitrarily uphold the action of the Ld. Assessing Officer in treating the sum of Rs. 1.00 crore out of total surrender made

M/S FAMINA KNIT FABS,LUDHIANA vs. ACIT, C-3, LUDHIANA

In the result, the appeal of the assessee in ITA

250(6) of the Income Tax At, 1961 (hereinafter referred to as ‘Act’). 2. It was c o m m

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.

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. FACTUAL MATRIX 3. The assessee for the aforesaid business of running a hotel has been maintaining

SH. SANJAY SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

250 Crores under section 132(4) of the Act in the whole group. The A.O. pointed out that aforesaid surrenderred amount included Rs. 159.61 crores of LTCG earned through M/s PIL for the A.Y. 2011-12 and in the hands of the assessee (Rs. 55.57 Crores) Sanjay Singhal HUF(Rs. 21.66 Crores) and Smt. Aarti Singhal (Rs. 82.38 Crores

SH. SANJAY SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

250 Crores under section 132(4) of the Act in the whole group. The A.O. pointed out that aforesaid surrenderred amount included Rs. 159.61 crores of LTCG earned through M/s PIL for the A.Y. 2011-12 and in the hands of the assessee (Rs. 55.57 Crores) Sanjay Singhal HUF(Rs. 21.66 Crores) and Smt. Aarti Singhal (Rs. 82.38 Crores

SMT. AARTI SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

250 Crores under section 132(4) of the Act in the whole group. The A.O. pointed out that aforesaid surrenderred amount included Rs. 159.61 crores of LTCG earned through M/s PIL for the A.Y. 2011-12 and in the hands of the assessee (Rs. 55.57 Crores) Sanjay Singhal HUF(Rs. 21.66 Crores) and Smt. Aarti Singhal (Rs. 82.38 Crores

SMT. AARTI SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

250 Crores under section 132(4) of the Act in the whole group. The A.O. pointed out that aforesaid surrenderred amount included Rs. 159.61 crores of LTCG earned through M/s PIL for the A.Y. 2011-12 and in the hands of the assessee (Rs. 55.57 Crores) Sanjay Singhal HUF(Rs. 21.66 Crores) and Smt. Aarti Singhal (Rs. 82.38 Crores

SH. SANJAY SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

250 Crores under section 132(4) of the Act in the whole group. The A.O. pointed out that aforesaid surrenderred amount included Rs. 159.61 crores of LTCG earned through M/s PIL for the A.Y. 2011-12 and in the hands of the assessee (Rs. 55.57 Crores) Sanjay Singhal HUF(Rs. 21.66 Crores) and Smt. Aarti Singhal (Rs. 82.38 Crores

SMT. AARTI SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

250 Crores under section 132(4) of the Act in the whole group. The A.O. pointed out that aforesaid surrenderred amount included Rs. 159.61 crores of LTCG earned through M/s PIL for the A.Y. 2011-12 and in the hands of the assessee (Rs. 55.57 Crores) Sanjay Singhal HUF(Rs. 21.66 Crores) and Smt. Aarti Singhal (Rs. 82.38 Crores

BANUR BROTHER ,PATIALA vs. ITO-WARD-1, AMBALA

In the result appeal of the assessee is allowed as and by way of remand to Ld

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

250 of the Income Tax Act, 1961. Factual Matrix 2. The Appellant was a partnership firm engaged as commission agent of food grains. The Appellant sells the agricultural produce to the Government Agencies and Trade Associations as a commission agent and receives the sale proceeds in the bank account. After receiving the sale proceeds, the Appellant withdraws cash for making

SH. ANIKET SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-

250 crores. 29. In view of the above, the AO issued a show cause notice to the assessee, proposing to treat the amount of impugned long-term capital gain as unexplained cash credit under section 68 of the Act. 30. In response to such show cause notice, the assessee submitted that he acquired the shares of PIL as share

SH. ANIKET SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-

250 crores. 29. In view of the above, the AO issued a show cause notice to the assessee, proposing to treat the amount of impugned long-term capital gain as unexplained cash credit under section 68 of the Act. 30. In response to such show cause notice, the assessee submitted that he acquired the shares of PIL as share

SMT. AARTI SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-

250 crores. 29. In view of the above, the AO issued a show cause notice to the assessee, proposing to treat the amount of impugned long-term capital gain as unexplained cash credit under section 68 of the Act. 30. In response to such show cause notice, the assessee submitted that he acquired the shares of PIL as share

SMT. AARTI SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-

250 crores. 29. In view of the above, the AO issued a show cause notice to the assessee, proposing to treat the amount of impugned long-term capital gain as unexplained cash credit under section 68 of the Act. 30. In response to such show cause notice, the assessee submitted that he acquired the shares of PIL as share

SMT. AARTI SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-

250 crores. 29. In view of the above, the AO issued a show cause notice to the assessee, proposing to treat the amount of impugned long-term capital gain as unexplained cash credit under section 68 of the Act. 30. In response to such show cause notice, the assessee submitted that he acquired the shares of PIL as share

SH. SANJAY SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-

250 crores. 29. In view of the above, the AO issued a show cause notice to the assessee, proposing to treat the amount of impugned long-term capital gain as unexplained cash credit under section 68 of the Act. 30. In response to such show cause notice, the assessee submitted that he acquired the shares of PIL as share

SH. SANJAY SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-

250 crores. 29. In view of the above, the AO issued a show cause notice to the assessee, proposing to treat the amount of impugned long-term capital gain as unexplained cash credit under section 68 of the Act. 30. In response to such show cause notice, the assessee submitted that he acquired the shares of PIL as share

SH. SANJAY SINGAL HUF,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-

250 crores. 29. In view of the above, the AO issued a show cause notice to the assessee, proposing to treat the amount of impugned long-term capital gain as unexplained cash credit under section 68 of the Act. 30. In response to such show cause notice, the assessee submitted that he acquired the shares of PIL as share