M/S TJR PROPERTIES PVT. LTD.,CHANDIGARH vs. ACIT, CC-2, CHANDIGARH

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

section 68 of the Act. Thus, it required to examine the identity and creditworthiness of the persons from who's amounts have been received and genuineness of the transactions on merit considering each credit separately. The AO has not discussed each and cred separately on merits in the assessment order before drawing the inference that the credits were unexplained

SHRI BALBIR SINGH VERMA,SHIMLA vs. PR.CIT, SHIMLA

In the result, appeal of the Assessee is allowed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

68, read with Section 115BBE. The absence of independent inquiry led the Pr. CIT to determine that the assessment order was again erroneous and prejudicial to the revenue. 5.4 Upon examining the Balance Sheet and its schedules, the Pr. CIT also found a discrepancy of Rs. 17,50,000 in the closing stock value of four flats. Although

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

Sections 2(47)(ii), (v) and (vi) of the Income Tax Act. He further held that, in the case of an assessee owning a 1000 square yards plot, the full value of consideration would be Rs.3.675 crores less cost of acquisition of Rs.12,81,724/-. The long term capital gain was, therefore, stated to be Rs.3,54,68,276

M/S DIN DAYAL PURSOTAM LAL,SIRSA vs. PR.CIT, ROHTAK

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

68 of the Act. This position stands settled vide inter-alia, the following decisions : i) ITA No. 325/2008 (Del) CIT vs. Ritu Anurag Agarwal "As there was no case for disallowance for corresponding purchases, no addition could be made under Section 68 in as much as it is not in dispute that the creditors outstanding related to purchases

M/S DIN DAYAL PURSOTAM LAL,SIRSA vs. PR.CIT, ROHTAK

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

68 of the Act. This position stands settled vide inter-alia, the following decisions : i) ITA No. 325/2008 (Del) CIT vs. Ritu Anurag Agarwal "As there was no case for disallowance for corresponding purchases, no addition could be made under Section 68 in as much as it is not in dispute that the creditors outstanding related to purchases

M/S DIN DAYAL PURSOTAM LAL,SIRSA vs. PR.CIT, ROHTAK

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

68 of the Act. This position stands settled vide inter-alia, the following decisions : i) ITA No. 325/2008 (Del) CIT vs. Ritu Anurag Agarwal "As there was no case for disallowance for corresponding purchases, no addition could be made under Section 68 in as much as it is not in dispute that the creditors outstanding related to purchases

LAKHVIR KAUR,MOHALI vs. DCIT/ACIT(CEN)-2, CHANDIGARH

In the result, both the above appeals of the Assessee are\nallowed

section 127of the Income\nTax Act, 1961.\n5.2 Accordingly, assessment in the case under consideration\nhas been made u/s 153A r.w.s 143(3) of the Act, vide order dated\n31.03.2022 by the Ld. A.O.\n5.3 During the course of assessment for AY 2020-21, total\naddition of Rs.85,68,276

LAKHVIR KAUR,MOHALI, CHANDIGARH vs. DCIT/ACIT(CEN)-2 CHD, CHANDIGARH

In the result, both the above appeals of the Assessee are\nallowed

section 127of the Income\nTax Act, 1961.\n5.2 Accordingly, assessment in the case under consideration\nhas been made u/s 153A r.w.s 143(3) of the Act, vide order dated\n31.03.2022 by the Ld. A.O.\n5.3 During the course of assessment for AY 2020-21, total\naddition of Rs.85,68,276

HIMACHAL PRADESH TECHNICAL UNIVERSITY ,HAMIRPUR vs. CIT(E), CHANDIGARH

In the result, the appeal of the assessee is allowed for statistical purposes

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

276 and another decision in case of Visvescaraya Technological University (2016) 384 ITR 37. 16. Further, reference was drawn to the Hon’ble Jurisdictional Himachal Pradesh High Court decision in case of Maa Saraswati Educational Trust (2013) 353 ITR 312 wherein their Lordship have held that generating surplus and accumulation of income will not disqualify an institution for the benefits

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

Appeal of the assessee is allowed

Bench: Ao)

68,12,209/- and the expenditure assumed and considered by ld. AO is Rs.71,22,923/- . The amount of Rs.6949470/-/6812209/- is accepted and 50% of it comes to Rs.34,37,627/- which is added by ld. CIT(A) and considered. The difference between Rs.71,22,923/- -6949470/- comes to Rs.1,73,452/- and therefore the opening balance according

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

Appeal of the assessee is allowed

Bench: Ao)

68,12,209/- and the expenditure assumed and considered by ld. AO is Rs.71,22,923/- . The amount of Rs.6949470/-/6812209/- is accepted and 50% of it comes to Rs.34,37,627/- which is added by ld. CIT(A) and considered. The difference between Rs.71,22,923/- -6949470/- comes to Rs.1,73,452/- and therefore the opening balance according

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

Appeal of the assessee is allowed

Bench: Ao)

68,12,209/- and the expenditure assumed and considered by ld. AO is Rs.71,22,923/- . The amount of Rs.6949470/-/6812209/- is accepted and 50% of it comes to Rs.34,37,627/- which is added by ld. CIT(A) and considered. The difference between Rs.71,22,923/- -6949470/- comes to Rs.1,73,452/- and therefore the opening balance according

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

Appeal of the assessee is allowed

Bench: Ao)

68,12,209/- and the expenditure assumed and considered by ld. AO is Rs.71,22,923/- . The amount of Rs.6949470/-/6812209/- is accepted and 50% of it comes to Rs.34,37,627/- which is added by ld. CIT(A) and considered. The difference between Rs.71,22,923/- -6949470/- comes to Rs.1,73,452/- and therefore the opening balance according

DCIT, C-,1 (E), CHANDIGARH vs. M/S PUNJAB MEDICAL FOUNDATION CHARITABLE TRUST, JALANDHAR

In the result, appeal of the Revenue is dismissed

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-"नधा"रण वष"/ Asstt.Year: 2014-15 Dcit, Cir.1(Exemption) M/S.Punjab Medical Foundation Chandigarh. Vs. Charitable Trust 63-64, Waryam Nagar Cool Road, Jalandhar Pan : Aaatp 5171 B (Applicant) (Responent) : Shri Sudhir Sehal, Advocate Assessee By Revenue By : Shri Ashok K. Khana, Addl.Cit सुनवाई क" तार"ख/Date Of Hearing : 18/11/2020 घोषणा क" तार"ख /Date Of Pronouncement: 21/12/2020 आदेश/O R D E R

276. It is stated that exemption had been granted to the assessee u/s 11 from the A.Y. 1991-92 consistently for twenty six years. There is absolutely no change of circumstances and there was no occasion for a different approach to be taken for the assessment year in question when the activities have continued uninterruptedly since the time of inception

DCIT, C-V, LUDHIANA vs. M/S HERO CYCLES LTD., LUDHIANA

In the result, appeal of the Department is dismissed and the appeal of the assessee is allowed

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 588/Chd/2018 निर्धारण वर्ष / Assessment Years : 2012-13 The DCIT C-V, Ludhiana बनाम M/s Hero Cycles Ltd. Hero Nagar, G.T. Road Ludhiana स्थायी लेखा सं./PAN NO: AAACH4073P अपीलार्थी/Appellant प्रत्यर्थी / Respondent आयकर अपील सं. / ITA No. 473/Chd/2018 निर्धारण वर्ष / Assessment Years : 2012-13 M/s Hero Cycles Ltd. Hero Nagar, G.T. Road Ludhiana बनाम The ACIT C-V, Ludhiana स्थायी लेखा सं./PAN NO: AAACH4073P

68,771/-) is disallowed and added back to the total income of the assessee as being the expenditure not wholly and exclusively for the purposes of business and is added back to the total income of the assessee." 13. Being aggrieved the assessee carried the matter to the Ld. CIT(A) and furnished the written submissions dt. 14.12.2017 which

M/S CREDO ASSETS PVT. LTD.,RUPNAGAR PUNJAB vs. DCIT/ACIT(CEN)-1 CHD, CHANDIGARH

The appeals stand partly allowed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No.487/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2013-14) M/S Singla Builders & Promoters Ltd. Dcit / Acit Central-1 बनाम/ Plot No 1265, Sector 82, Industrial Area C.R. Building, Sector 17 Vs. Rupnagar (Punjab) 140308 Chandigarh-160017 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaocs-6503-M (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकर अपील सं. / Ita No.482/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2017-18) & 3. आयकर अपील सं. / Ita No.484/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2018-19) M/S Credo Assets Private Ltd. Dcit / Acit Central-1 बनाम/ Plot No 1265-C, Sector 82, Industrial Area C.R. Building, Sector 17 Vs. Rupnagar (Punjab) 140308 Chandigarh-160017 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aafcc-6400-L (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Parikshit Aggarwal (Ca) & Smt. Shruti Khandelwal (Ca) – Ld. Ars ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) & Shri Rajat Kumar Kureel (Cit) – Ld. Drs (Virtual) Date Of Final Hearing : 27-01-2026 Date Of Pronouncement : 03-02-2026

276) and the decision of Hon’ble Gujarat High Court in the case of Anand Banwarilal Adhukia (75 Taxmann.com 301). It was further stated that what could be referred for valuation has to be ‘asset’, ‘property’ or ‘investment’ as contemplated u/s 142A(1). However, for the assessee, amount spent on construction of real estate project would only be an expenditure

M/S SINGLA BUILDERS AND PROMOTERS LIMITED,RUPNAGAR, PUNJAB vs. DCIT/ACIT(CEN)-1 CHD, CHANDIGARH

The appeals stand partly allowed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No.487/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2013-14) M/S Singla Builders & Promoters Ltd. Dcit / Acit Central-1 बनाम/ Plot No 1265, Sector 82, Industrial Area C.R. Building, Sector 17 Vs. Rupnagar (Punjab) 140308 Chandigarh-160017 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaocs-6503-M (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकर अपील सं. / Ita No.482/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2017-18) & 3. आयकर अपील सं. / Ita No.484/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2018-19) M/S Credo Assets Private Ltd. Dcit / Acit Central-1 बनाम/ Plot No 1265-C, Sector 82, Industrial Area C.R. Building, Sector 17 Vs. Rupnagar (Punjab) 140308 Chandigarh-160017 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aafcc-6400-L (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Parikshit Aggarwal (Ca) & Smt. Shruti Khandelwal (Ca) – Ld. Ars ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) & Shri Rajat Kumar Kureel (Cit) – Ld. Drs (Virtual) Date Of Final Hearing : 27-01-2026 Date Of Pronouncement : 03-02-2026

276) and the decision of Hon’ble Gujarat High Court in the case of Anand Banwarilal Adhukia (75 Taxmann.com 301). It was further stated that what could be referred for valuation has to be ‘asset’, ‘property’ or ‘investment’ as contemplated u/s 142A(1). However, for the assessee, amount spent on construction of real estate project would only be an expenditure

M/S CREDO ASSETS PVT. LTD.,RUPNAGAR PUNJAB vs. DCIT/ACIT(CEN)-1 CHD, CHANDIGARH

The appeals stand partly allowed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No.487/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2013-14) M/S Singla Builders & Promoters Ltd. Dcit / Acit Central-1 बनाम/ Plot No 1265, Sector 82, Industrial Area C.R. Building, Sector 17 Vs. Rupnagar (Punjab) 140308 Chandigarh-160017 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaocs-6503-M (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकर अपील सं. / Ita No.482/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2017-18) & 3. आयकर अपील सं. / Ita No.484/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2018-19) M/S Credo Assets Private Ltd. Dcit / Acit Central-1 बनाम/ Plot No 1265-C, Sector 82, Industrial Area C.R. Building, Sector 17 Vs. Rupnagar (Punjab) 140308 Chandigarh-160017 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aafcc-6400-L (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Parikshit Aggarwal (Ca) & Smt. Shruti Khandelwal (Ca) – Ld. Ars ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) & Shri Rajat Kumar Kureel (Cit) – Ld. Drs (Virtual) Date Of Final Hearing : 27-01-2026 Date Of Pronouncement : 03-02-2026

276) and the decision of Hon’ble Gujarat High Court in the case of Anand Banwarilal Adhukia (75 Taxmann.com 301). It was further stated that what could be referred for valuation has to be ‘asset’, ‘property’ or ‘investment’ as contemplated u/s 142A(1). However, for the assessee, amount spent on construction of real estate project would only be an expenditure

SH. LACHHMAN DASS BANSAL,BARNALA vs. DCIT, CENTRAL CIRCLE, PATIALA

The appeal of the assessee is partly allowed

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

276, para 54 and after referring to various judgments and the relevant paras are para 63 & 64, page 294 & 295, wherein, it was held that it would have taken 71 hours to weigh the stock and it was held that the surrender was made under pressure and coercion and finally, in para 66, the said addition have been deleted. Same