DCIT, C-1(1) , CHANDIGARH vs. M/S FIDELITY INFORMATION SERVICES INDIA PVT. LTD., CHANDIGARH

In the result, the cross-objection filed by the assessee is dismissed

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

1. in levying interest amounting to Rs 43,45,973 and Rs. 302,575 under sections 234B and 234C of the Act respectively on the additional income assessed pursuant to the Advance Pricing Agreement ("APA"). 2. That on the facts and circumstances of the case and in law, the levy of interest under sections 234B and 234C

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)

1) dt. 18/10/2023 of Ld. CIT(A) under section 253 of the Income Tax Act, 1961. The order of Ld. CIT(A) is passed under section 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

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

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 and had filed his return of income under section

M/S PAGRO FROZEN FOODS PVT. LTD.,CHANDIGARH vs. ITO, W-2(3), CHANDIGARH

The appeal of the Assessee is dismissed

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

253 of the Act and has interalia raised the following grounds of appeal. 1. That the order passed by Ld. Commissioner of Income Tax (Appeals)-4, Ludhiana vide appeal No. 47/ROT(10725)/CHD/IT/CIT(A)-4/LDH/2016-17 dated 22.06.2018 is contrary to law and facts of the case. 2. That in the facts and circumstances of the case, the ld. Commissioner

M/S PUNJAB TOURISM DEVELOPMENET CORPORATION LIMITED,CHANDIGARH vs. DCIT,CIRCLE-1(1), CHANDIGARH

Appeal of the assessee is allowed

Bench: Ao)

68,75,253/-) we adopt our observations, findings and Conclusions which we have given for identical situation in ITA No. 139/Chd/2020 particularly inpara 7.1, 7.4 7.5, 7.6 and 7.7. 31.2 We notice that in the impugned order the Ld. CIT(A) has laid much emphasis on section 37 of the Act. Section 37 falls under Chapter IV which

M/S PUNJAB TOURISM DEVELOPMENET CORPORATION LIMITED,CHANDIGARH vs. DCIT,CIRCLE-1(1), CHANDIGARH

Appeal of the assessee is allowed

Bench: Ao)

68,75,253/-) we adopt our observations, findings and Conclusions which we have given for identical situation in ITA No. 139/Chd/2020 particularly inpara 7.1, 7.4 7.5, 7.6 and 7.7. 31.2 We notice that in the impugned order the Ld. CIT(A) has laid much emphasis on section 37 of the Act. Section 37 falls under Chapter IV which

M/S PUNJAB TOURISM DEVELOPMENET CORPORATION LIMITED,CHANDIGARH vs. DCIT,CIRCLE-1(1), CHANDIGARH

Appeal of the assessee is allowed

Bench: Ao)

68,75,253/-) we adopt our observations, findings and Conclusions which we have given for identical situation in ITA No. 139/Chd/2020 particularly inpara 7.1, 7.4 7.5, 7.6 and 7.7. 31.2 We notice that in the impugned order the Ld. CIT(A) has laid much emphasis on section 37 of the Act. Section 37 falls under Chapter IV which

M/S PUNJAB TOURISM DEVELOPMENET CORPORATION LIMITED,CHANDIGARH vs. DCIT,CIRCLE-1(1), CHANDIGARH

Appeal of the assessee is allowed

Bench: Ao)

68,75,253/-) we adopt our observations, findings and Conclusions which we have given for identical situation in ITA No. 139/Chd/2020 particularly inpara 7.1, 7.4 7.5, 7.6 and 7.7. 31.2 We notice that in the impugned order the Ld. CIT(A) has laid much emphasis on section 37 of the Act. Section 37 falls under Chapter IV which

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2, LUDHIANA vs. AB ALCOBEV PRIVATE LIMITED, DELHI

In the result, appeals of Revenue are dismissed, Cross\nObjections of the assessee for

253 contemplates that the\nTribunal may admit an appeal or permit filing of memorandum\nof cross- objections after expiry of relevant period, if it is\nsatisfied that there was a sufficient cause for not presenting\nit within that period. This expression sufficient cause\nemployed in the section has also been used identically in sub-\nsection 3 of section

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2, LUDHIANA , LUDHIANA vs. AB ALCOBEV PRIVATE LIMITED, DELHI

In the result, appeals of Revenue are dismissed, Cross\nObjections of the assessee for

253 contemplates that the\nTribunal may admit an appeal or permit filing of memorandum\nof cross- objections after expiry of relevant period, if it is\nsatisfied that there was a sufficient cause for not presenting\nit within that period. This expression sufficient cause\nemployed in the section has also been used identically in sub-\nsection 3 of section

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2,, LUDHIANA vs. AB ALCOBEV PRIVATE LIMITED, DELHI

In the result, appeals of Revenue are dismissed, Cross\nObjections of the assessee for

253 contemplates that the\nTribunal may admit an appeal or permit filing of memorandum\nof cross- objections after expiry of relevant period, if it is\nsatisfied that there was a sufficient cause for not presenting\nit within that period. This expression sufficient cause\nemployed in the section has also been used identically in sub-\nsection 3 of section

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2 LUDHIANA, LUDHIANA vs. AB ALCOBEV PRIVATE LIMITED , DELHI

In the result, appeals of Revenue are dismissed, Cross\nObjections of the assessee for

253 contemplates that the\nTribunal may admit an appeal or permit filing of memorandum\nof cross- objections after expiry of relevant period, if it is\nsatisfied that there was a sufficient cause for not presenting\nit within that period. This expression sufficient cause\nemployed in the section has also been used identically in sub-\nsection 3 of section

INCOME TAX OFICER, BC BAZAR vs. THE KESRI UNION FARMERS SERVICE CO-OP SOCIETY LTD, AMBALA

In the result appeal of Department / Revenue is dismissed

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

section 253 before us. 20. In the grounds of appeal the Revenue has contended as under and has raised the following grounds of appeal before us: 1. On the facts and circumstances of the case, the Ld. CIT(A) has erred in deleting the addition made by the AO by treating the cash deposits of Rs. 1

SMT. JAGDEEP KAUR,LUDHIANA vs. ITO, WARD 6(4), LUDHIANA

In the result, appeal of the Assessee is dismissed

Bench: This Hon’Ble Tribunal Under Section 253 Of The Income Tax Act, 1961. 3. The Assessee Is Aggrieved By Din & Order No. Itba/Nfac/S/250/2022- 23/1048105767(1) Dt. 20/12/2022 Which Was Passed By The Ld. Cit(A) Nfac, Delhi Under Section 250 Of The Income Tax Act, 1961. The Said First Appeal Was Dismissed By The Ld. Cit(A). Therefore Assessee Is Before Us. The Said Order Of The Ld. Cit(A) Is Hereinafter Referred To As The “Impugned Order”. 4. In Form No. 36 The Assessee Interalia Has Take Up Following Grounds Of Appeal Against The Impugned Order Which Are Reproduced Below:

253 of the Income Tax Act, 1961. 3. The assessee is aggrieved by DIN & Order No. ITBA/NFAC/S/250/2022- 23/1048105767(1) DT. 20/12/2022 which was passed by the Ld. CIT(A) NFAC, Delhi under section 250 of the Income Tax Act, 1961. The said first appeal was dismissed by the Ld. CIT(A). Therefore assessee is before us. The said order

JINDAL PADDING PRIVATE LIMITED,VILLAGE MANNPURA, TEHSIL NALAG vs. INCOME TAX OFFICER PARWANO, PARWANO

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

253 of the Income Tax Act, 1961 (Act for short). The assessee is aggrieved by the order bearing No. ITBA/NFAC/S/250/2023-24/1059642201(1) dated 12.01.2024 passed by ld. CIT(A) which is hereinafter referred to as the “impugned order”, which is passed under Section 250 of the Act. The relevant assessment ITA 100/CHD/2024 A.Y. 2010-11 2 year

SWARN GANGA JEWELLERS,CHANDIGARH vs. DCIT, CIRCLE 4(1) NOW DCIT, CIRCLE 1(1), CHANDIGARH

In the result, the appeal of the assessee stands allowed

Bench: This Tribunal Being Aggrieved By An Order No. Itba/Nfac/S/250/2022-23/1045180258(1) For A.Y. 2017-18 Dt. 05/09/2022 Which Is Hereinafter Referred To As The “Impugned Order”. The Impugned Order Is Passed By Cit(A) In Terms Of Section 250 Of The Income Tax Act, 1961. Factual Matrix 2. That Survey U/S 133A Of The Income Tax Act, 1961 Was Conducted On The Business Premises Of The Assessee On 06/09/2016. The Assessee Surrendered A Sum Of Rs. 50,00,000/- During The Survey & Paid Tax Thereon. The Return Of Income Was Filed On 01/11/2017 Declaring A Total Income Of Rs. 89,48,260/-. Thereafter The Case Of The Assessee Was Selected For Scrutiny Under Compulsory Scrutiny Guidelines & Notice Under Section 143(2) Of The Act Was Issued On 11/09/2018. The Assessment Was Finalised Vide Order Dt. 23/12/2019 Whereby Addition Of Rs. 95,70,882/- Was Made U/S 68 R.W..S 115Bbe Of The Act.

253 of the Income Tax Act, 1961, before this Tribunal being aggrieved by an order No. ITBA/NFAC/S/250/2022-23/1045180258(1) for A.Y. 2017-18 dt. 05/09/2022 which is hereinafter referred to as the “impugned order”. The impugned order is passed by CIT(A) in terms of Section 250 of the Income Tax Act, 1961. Factual Matrix 2. That survey u/s 133A

ITO, W-1(3), CHANDIGARH vs. SMT. RENU ANAND, CHANDIGARH

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

253 of the Income Tax Act, 1961(which is hereinafter referred to as Act). The Revenue is aggrievedby the order dt. 29/08/2018 passed by the Commissioner of Income Tax (Appeals) in First Appeal No. 10316/16-17 which is hereinafter referred to as the “impugned order”. The relevant assessment year is 2013-14 and the corresponding previous year period is From 01/04/2012

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