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)

section 253(4) of the Act, the cross objections before the Tribunal are required to be filed within 30 days from the receipt of notice of appeal filed by the Revenue Department. In this case, the appeal by the Department was received by the Assessee company on January 19, 2021 and thus, 30 days expired on February

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)

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 Agencies and Trade Associations as a commission agent and receives

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 CHANDIGARH LAWN TENNIS ASSOCIATION,CHANDIGARH vs. ITO (EXEMPTIONS), CHANDIGARH

Bench: Shri Sanjay Garg & Ms. Annapurna Guptaassessment Year : 2013-14 Chandigarh Lawn Tennis Vs. The Ito (Exemptions), Association, Ward, Chandigarh Sector 10, Chandigarh Pan No. Aaatc4943J (Appellant) (Respondent) Appellant By : Sh. Y.K. Sud, Ca Respondent By : Smt. Chanderkanta, Addl. Cit (On 22.3.2018) & Sh.Yoginder Mittal, Sr. Dr (On 13.7.2018) Date Of Hearing : 22.03.2018 & 13.7.2018 Date Of Pronouncement : 26.07.2018

section 2(15) there is a paradigm shift from the earlier position. Though, some of the decisions of the Delhi High Court as referred to above and that of the Pb. & Hry. High Court in the case of The Tribune Trust (supra) have been delivered subsequent to the introduction of the second proviso to section

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

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2 LUDHIANA, LUDHIANA vs. AMARJIT SINGH , BATHINDA

In the result, Cross Objections of the assessee

Bench: Shri Rajpal Yadav & Shri Krinwant Sahay

68 read with Section 115BBE amounting to the tune of Rs.9,65,71,414/-. In other words, both the grounds are in support of the CIT(A)’s finding. If we peruse sub-clause (4) of Section 253

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

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)

4) That the assessee society had deposited Rs. 1,35,30,500/- during the demonetization period. 5) that the whole of said amounts belongs to members of the society who are account holders in the society. 6) That the main objective of the society is to provide credit to small and marginal farmers, rural artisans, and agricultural labourers

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

RACHIT AGGARWAL (PROP.) ASHOK KUMAR GUPTA & CO.,LUDHIANA vs. ITO, WARD II(2), LUDHIANA

In the result, appeal of the assessee is allowed

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

4. The assessee has not submitted the explanation as desired mentioned in the above mentioned statutory notices despite giving multiple opportunities, he was failed to provide the details before the then Assessing Officer during the assessment proceedings. At this stage, the condition of admissibility of additional submission or any other statement does not qualify as per rule

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, LUDHIANA vs. MALBROS INTERNATIONAL PVT LTD, FARIDKOT

In the result, both the appeals and the Cross Objections are dismissed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 992 & 993/Chd/2024 "नधा"रण वष" / Assessment Years: 2017-18, 2016-17 The Dcit, Vs Malbros International Pvt. Ltd., Central Circle-2, Village – Mansoorwal, Teh-Zira, Ludhiana. Head Offices Old Cantt. Road, Faridkot. "थायी लेखा सं./Pan No: Aadcm7203R अपीलाथ"/Appellant ""यथ"/Respondent & C.O. Nos. 46 & 45/Chd/2024 In आयकर अपील सं./ Ita Nos. 992 & 993/Chd/2024 "नधा"रण वष" / Assessment Year: 2017-18, 2016-17 Malbros International Pvt. Ltd., The Dcit, Village – Mansoorwal, Teh-Zira, Vs Central Circle-2, Head Offices Old Cantt. Road, Ludhiana. Faridkot. "थायी लेखा सं./Pan No: Aadcm7203R अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Sudhir Sehgal, Advocate Revenue By : Smt. Kusum Bansal, Cit Dr Date Of Hearing : 14.05.2025 Date Of Pronouncement : 25.06.2025

253 contemplates that the Tribunal may admit an appeal or permit filing of memorandum of cross- objections after expiry of relevant period, if it is satisfied that there was a sufficient cause for not presenting ITA No.992 & 993/CHD/2024 & CO 46 & 45/CHD/2024 A.Y.2017-18 & 2016-17 3 it within that period. This expression sufficient cause employed in the section has also

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

SHRI KRISHAN KUMAR JALAN,BANGALORE vs. ITO, W-1, SIRSA

In the result appeal of the assessee is dismissed

253 of the\nIncome Tax Act, 1961 (hereinafter referred to as Act) as and by way\nof second appeal before this Tribunal. The Assessee is aggrieved by the\norder dt. 29/03/2010 passed in First Appeal No. 111/HSR/2016-17 which\npertains to the assessee. The order dt. 29/03/2010 is passed by\nCommissioner of Income Tax (Appeals

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

DEVI DAYAL,KAITHAL vs. INCOME TAX OFFICER, WARD-1 , KAITHAL

In the result, appeal is allowed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 899/Chd/2024 "नधा"रण वष" / Assessment Year: 2008-09 Shri Devi Dayal, Vs The Ito, Pundri Anaj Mandi, Ward – 1, Kaithal-Haryana 136026. Kaithal. "थायी लेखा सं./Pan No: Aajpd5851H अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Parikshit Aggarwal, Ca & Ms. Shruti Khandelwal, Advocate Revenue By : Shri Manav Bansal, Cit, Dr Date Of Hearing : 30.07.2025 Date Of Pronouncement : 08.09.2025

253 contemplates that the Tribunal may admit an appeal or permit filing of memorandum of cross- objections after expiry of relevant period, if it is satisfied that there was a sufficient cause for not presenting it within that period. This expression sufficient cause A.Y.2008-09 3 employed in the section has also been used identically in sub- section