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)

68 of Income Tax Act 1961 but if such income from undisclosed sources, though, invested had not been recorded in the assessee's books, than such income is liable to be assessed in terms of section 69 of Income Tax Act 1961. vii. In Roshan Lal Madan VS CIT 245 ITR (AT) 36 (Chandigarh) AND Jagmohan Ram Ram Chandra

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

In the result, appeal of the assessee is allowed

68, 69, 69A, 69B, 69C or 69D reflected in the return of income furnished under section 139 of the Act. However, in the present case no such income was reflected in the return filed under section 139 of the Act rather the income was declared in the return filed under section 153A of the Act after

M/S OSWAL TREND (P) LTD.,LUDHIANA vs. DCIT, C. C.-1, LUDHIANA

In the result, this appeal of the Revenue stands dismissed

Bench: Shri Sanjay Garg & Shri Krinwant Sahay

251. The Revenue in this appeal is aggrieved by the action of the Ld. Commissioner of Income Tax (Appeals)-5, Ludhiana [hereinafter referred to as the ‘ld. CIT(A)’] in deleting the addition of Rs.8,95,50,000/- made by the AO under Section 68

ACIT -CENTRAL CIRCLE-1,, LUDHIANA vs. M/S OSWAL TRENDS PVT. LTD., LUDHIANA

In the result, this appeal of the Revenue stands dismissed

Bench: Shri Sanjay Garg & Shri Krinwant Sahay

251. The Revenue in this appeal is aggrieved by the action of the Ld. Commissioner of Income Tax (Appeals)-5, Ludhiana [hereinafter referred to as the ‘ld. CIT(A)’] in deleting the addition of Rs.8,95,50,000/- made by the AO under Section 68

M/S OSWAL APPARELS PVT. LTD.,LUDHIANA vs. DCIT, C.C.- 1, LUDHIANA

In the result, this appeal of the Revenue stands dismissed

Bench: Shri Sanjay Garg & Shri Krinwant Sahay

251. The Revenue in this appeal is aggrieved by the action of the Ld. Commissioner of Income Tax (Appeals)-5, Ludhiana [hereinafter referred to as the ‘ld. CIT(A)’] in deleting the addition of Rs.8,95,50,000/- made by the AO under Section 68

ACIT, CENTRAL CIRCLE -1,, LUDHIANA vs. M/S OSWAL APPARELS PVT. LTD., LUDHIANA

In the result, this appeal of the Revenue stands dismissed

Bench: Shri Sanjay Garg & Shri Krinwant Sahay

251. The Revenue in this appeal is aggrieved by the action of the Ld. Commissioner of Income Tax (Appeals)-5, Ludhiana [hereinafter referred to as the ‘ld. CIT(A)’] in deleting the addition of Rs.8,95,50,000/- made by the AO under Section 68

ACIT -CENTRAL CIRCLE-1,, LUDHIANA vs. M/S OSWAL TRENDS PVT. LTD., LUDHIANA

In the result, this appeal of the Revenue stands dismissed

Bench: Shri Sanjay Garg & Shri Krinwant Sahay

251. The Revenue in this appeal is aggrieved by the action of the Ld. Commissioner of Income Tax (Appeals)-5, Ludhiana [hereinafter referred to as the ‘ld. CIT(A)’] in deleting the addition of Rs.8,95,50,000/- made by the AO under Section 68

ACIT, CENTRAL CIRCLE -1,, LUDHIANA vs. M/S OSWAL APPARELS PVT. LTD., LUDHIANA

In the result, this appeal of the Revenue stands dismissed

Bench: Shri Sanjay Garg & Shri Krinwant Sahay

251. The Revenue in this appeal is aggrieved by the action of the Ld. Commissioner of Income Tax (Appeals)-5, Ludhiana [hereinafter referred to as the ‘ld. CIT(A)’] in deleting the addition of Rs.8,95,50,000/- made by the AO under Section 68

SANJAY SINGAL,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CC-1, CHANDIGARH

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

68 of the Income Tax Act, 1961 on account of unexplained cash credit in each appeal i.e. ITA Nos. 708, 710, 71 l/Chd/2018; ITA No. 714, 716 and 717/Chd/2018; ITA No. 718 &719/Chd/2018; and 705/Chd/2018 83. Similarly, addition made by the AO by estimating the expenses on commission alleged to have been incurred by the assessee for arranging such long

M/S SANJAY SINGAL HUF,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

68 of the Income Tax Act, 1961 on account of unexplained cash credit in each appeal i.e. ITA Nos. 708, 710, 71 l/Chd/2018; ITA No. 714, 716 and 717/Chd/2018; ITA No. 718 &719/Chd/2018; and 705/Chd/2018 83. Similarly, addition made by the AO by estimating the expenses on commission alleged to have been incurred by the assessee for arranging such long

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, LUDHIANA vs. RITU DHINGRA, SHAKTI VIHAR, HAIBOWAL KALAN, LUDHIANA

In the result, the appeal of the Assessee and cross appeal of the Department are allowed for statistical purposes

Bench: him:- (a) That the assessment order dated 31.03.2023 passed u/s 143(3) r.w.s.153C is bad in law in as much no incriminating material was found suggesting any escapement of income at premises of Sh. Avtar Singh Kochhar. (b) That the assessment order passed is non-est and bad in law in as much the proceedings have not been conducted in the manner prescribed by the Department instructions from time to time which are mandatory for compliance by the Learned Authorities particularly with respect

68 of the Act and dismissed the grounds raised by the assessee. 8. Against the order of the Ld. CIT(A) the assessee preferred in appeal before the Tribunal. 9. During the course of hearing the Ld. AR invited our attention to the assessment order passed by the Assessing Officer, wherein the assessment was framed under section 153C read

RITU DHINGRA, LUDHIANA,LUDHIANA vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, LUDHIANA, LUDHIANA

In the result, the appeal of the Assessee and cross appeal of the Department are allowed for statistical purposes

Bench: him:-

68 of the Act and dismissed the grounds raised by the assessee. 8. Against the order of the Ld. CIT(A) the assessee preferred in appeal before the Tribunal. 9. During the course of hearing the Ld. AR invited our attention to the assessment order passed by the Assessing Officer, wherein the assessment was framed under section 153C read

DY. COMMISSIONER OF INCOME TAX, KITCHLU NAGAR vs. ABIR KNITS PVT. LTD., FOCAL POINT

In the result, appeal of the Revenue is dismissed

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

68 and 69C read with section 115BBE, also initiating penalty proceedings under section 271AAC. 5. Against the order of the AO the assessee went in appeal before the Ld. CIT(A). Finding of Ld. CIT(A) given in the impugned order in para 5.1 read as under: “5.1 It is observed that no proper compliance was made during

ITO, LUDHIANA vs. ARUN GUPTA, LUDHIANA

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Krinwant Sahay, Am आयकरअपीलसं./ Ita No.112/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2021-22) Ito Arun Gupta बनाम/ Vs. Aayakar Bhawan, Rishi Nagar 1698 – New Shakti Nagar, Ludhiana, Punjab - 141001 Ludhiana, Punjab - 141001 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Abkpg-4933-F (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. B.M. Monga & Sh. Rohit Kaura (Advocates) ""थ"कीओरसे/Respondent By : Sh. Manav Bansal (Cit) Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 21-01-2026 घोषणाकीतारीख /Date Of Pronouncement 19-03-2026 : आदेश / O R D E R Krinwant Sahay () This Appeal Filed By The Revenue Is Directed Against The Order Of The Ld. Cit(A)/Nfac, Delhi, Dated 04.12.2024, Pertaining To The Assessment Year 2021-22. The Revenue Has Challenged The Action Of The Ld. Cit(A) In Setting Aside The Assessment Order To The File Of The Assessing Officer For Fresh Adjudication.

section 251 of the Income Tax Act, 1961. 4. That, the Ld. Commissioner of Income Tax (Appeals) has failed to appreciate the fact that the addition of Rs. 4,13,73,219/- made by the AO being unexplained expenditure u/s 69C r.w.s. 115BBE of the Income Tax Act, 1961 on account of 25% of the unverified purchases

M/S NAMDHARI INDUSTRIAL TRADERS PVT. LTD.,LUDHIANA vs. ACIT, LUDHIANA

section 143(3) of the Act. 2. Brief facts of the case emanating from the record and pleadings of the parties are that the assessee company engaged in the business of manufacturing of pre-structured engineering goods, filed its return of income for the assessment year under consideration declaring total income of Rs. 31,50,165/- Since the case

M/S SEL MANUFACTURING CO. LTD.,LUDHIANA vs. DCIT, CC-3, LUDHIANA

In the result, appeal is allowed

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

251 (SC). 6. The ld. DR, on the other hand, has sought to place strong reliance on the decision of the Surat Bench of the Tribunal in the case of ‘Garden Silk Mills (P) Ltd. Vs DCIT’, [2023] 150 taxmann.com 442 (Surat-Trib.), wherein, since the assessment A.Y. 2011-12 8 order was passed in the case of the assessee

DCIT, CIRCLE-3, LUDHIANA vs. M/S GANESHAY OVERSEAS INDUSTRIES LIMITED, CHANDIGARH

In the result, Appeal of the Revenue is dismissed

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

251 or the imposition of penalty under section 271.]" 6.1 As per the above 'Sub-Rule (4)', the CIT(A) can independently examine or call for any information or make any enquiry as he may deem fit and his powers are coterminous with the powers of AO. Though the Assessing Officer did not respond to such sharing of information

M/S LUXMI BUILDERS,CHANDIGARH vs. DCIT, CHANDIGARH

In the result, the respective appeals and stay applications are disposed off in light of aforesaid directions

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

section that the CIT (A) while disposing off an appeal may consider and decide any matter arising out of the proceedings in which the order appealed against was passed, notwithstanding that such matter was not raised before the CIT (A) by the assessee firm. It is evident from the facts of the case as discussed above that the subject

M/S GANESH BUILDERS,PANCHKULA vs. DCIT, CC-1, CHANDIGARH

In the result, the respective appeals and stay applications are disposed off in light of aforesaid directions

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

section that the CIT (A) while disposing off an appeal may consider and decide any matter arising out of the proceedings in which the order appealed against was passed, notwithstanding that such matter was not raised before the CIT (A) by the assessee firm. It is evident from the facts of the case as discussed above that the subject