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)

c) above will have to be set-up by the units. Considering the functional nature of the facility, Irradiation facility can be treated as a stand alone one for the purpose of availing grant. • To provide integrated and complete cold chain facilities without any break from the farm gate to the consumer, Pre-cooling facilities at production sites, reefer vans

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.

6. The Tribunal had relied upon a decision of the Gujarat High Court in Fakir Mohmed Haji Hasan v. Commissioner of Income-Tax [2001] 247 ITR 290. In that case, interpreting the scope and describing the scheme of Sections 69, 69A, 69B and 69C of the Act, it was observed:- "The scheme of sections

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

68 8 4,94,000 3,51,451 D/o Shri R.K. Chhabra, # 3085 Sector 21 D, Chandigarh Sanjay Sardana Salary Rent Interest Salary Rent Interest Salary Rent Interest 6. S/o Shri Gian 20,59,27 8 2,83,000 4,62,572 25,66,84 4 4,00,00 0 2,97,768 39,23,86 6

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

68 8 4,94,000 3,51,451 D/o Shri R.K. Chhabra, # 3085 Sector 21 D, Chandigarh Sanjay Sardana Salary Rent Interest Salary Rent Interest Salary Rent Interest 6. S/o Shri Gian 20,59,27 8 2,83,000 4,62,572 25,66,84 4 4,00,00 0 2,97,768 39,23,86 6

M/S MANAV MANGAL SOCIETY,CHANDIGARH vs. DCIT, C-1, (E), CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

68 8 4,94,000 3,51,451 D/o Shri R.K. Chhabra, # 3085 Sector 21 D, Chandigarh Sanjay Sardana Salary Rent Interest Salary Rent Interest Salary Rent Interest 6. S/o Shri Gian 20,59,27 8 2,83,000 4,62,572 25,66,84 4 4,00,00 0 2,97,768 39,23,86 6

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

68 8 4,94,000 3,51,451 D/o Shri R.K. Chhabra, # 3085 Sector 21 D, Chandigarh Sanjay Sardana Salary Rent Interest Salary Rent Interest Salary Rent Interest 6. S/o Shri Gian 20,59,27 8 2,83,000 4,62,572 25,66,84 4 4,00,00 0 2,97,768 39,23,86 6

M/S MANAV MANGAL SOCIETY,CHANDIGARH vs. DCIT, C-1, (E), CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

68 8 4,94,000 3,51,451 D/o Shri R.K. Chhabra, # 3085 Sector 21 D, Chandigarh Sanjay Sardana Salary Rent Interest Salary Rent Interest Salary Rent Interest 6. S/o Shri Gian 20,59,27 8 2,83,000 4,62,572 25,66,84 4 4,00,00 0 2,97,768 39,23,86 6

DCIT,CIRCLE-1(EXEMPTION), CHANDIGARH vs. M/S MANAV MANGAL SCHOOL( MANAV MANGAL SOCIETY), CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

68 8 4,94,000 3,51,451 D/o Shri R.K. Chhabra, # 3085 Sector 21 D, Chandigarh Sanjay Sardana Salary Rent Interest Salary Rent Interest Salary Rent Interest 6. S/o Shri Gian 20,59,27 8 2,83,000 4,62,572 25,66,84 4 4,00,00 0 2,97,768 39,23,86 6

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

68 8 4,94,000 3,51,451 D/o Shri R.K. Chhabra, # 3085 Sector 21 D, Chandigarh Sanjay Sardana Salary Rent Interest Salary Rent Interest Salary Rent Interest 6. S/o Shri Gian 20,59,27 8 2,83,000 4,62,572 25,66,84 4 4,00,00 0 2,97,768 39,23,86 6

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

68 8 4,94,000 3,51,451 D/o Shri R.K. Chhabra, # 3085 Sector 21 D, Chandigarh Sanjay Sardana Salary Rent Interest Salary Rent Interest Salary Rent Interest 6. S/o Shri Gian 20,59,27 8 2,83,000 4,62,572 25,66,84 4 4,00,00 0 2,97,768 39,23,86 6

INCOME TAX OFFICER, CHANDIGARH vs. SANBIR SINGH, CHANDIGARH

In the result, the appeal is dismissed

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

Section 133(6) of the Act to Shri Gaganpreet Singh, to ITA 455/CHD/2023 & C.O. 2/CHD/2023 A.Y. 2018-19 43 make any further enquiry. It was not disputed that the amounts as above, totaling to Rs.5 lacs had been repaid by the assessee to Shri Gaganpreet Singh through cheque, as above. Again, this was much before the issuance of notice

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)

6. That the appellant, craves leave to add or amend any ground of appeal before appeal is heard or dispose off. 3. During the course of hearing the Ld. AR submitted that the survey operation u/s 133A was conducted on the business premises of appellant on 16/04/2018. During the course of survey, the appellant surrendered the amount

DEPUTY COMMISSIONER OF INCOME TAX, CC-1, LUDHIANA, LUDHIANA vs. SHREE GANESH EDIBLES PVT. LTD., KHANNA

The appeal stand dismissed

Bench: SHRI RAJPAL YADAV (Vice President), SHRI MANOJ KUMAR AGGARWAL (Accountant Member)

43 (Delhi) has held as under: “Section 68 of the Income-tax Act, 1961 – Cash Credits – Assessment year 2001-02 – Whether though in section 68 proceedings, initial burden of proof lies on assessee, yet once he proves identity of creditors/share applicants by either furnishing their PAN numbers or income-tax assessment numbers and shows genuineness of transaction

DEPUTY COMMISSIONER OF INCOME TAX, CC-1, LUDHIANA, LUDHIANA vs. SHREE GANESH EDIBLES PVT. LTD., KHANNA

The appeal stand dismissed

Bench: SHRI RAJPAL YADAV (Vice President), SHRI MANOJ KUMAR AGGARWAL (Accountant Member)

43 (Delhi) has held as under: “Section 68 of the Income-tax Act, 1961 – Cash Credits – Assessment year 2001-02 – Whether though in section 68 proceedings, initial burden of proof lies on assessee, yet once he proves identity of creditors/share applicants by either furnishing their PAN numbers or income-tax assessment numbers and shows genuineness of transaction

SH. KRISHAN KUMAR,KHANNA vs. DCIT, CC-1, LUDHIANA

In the result, the appeal of the Assessee is allowed

Bench: Shri A.D. Jain & Shri Vikram Singh Yadav

43 subsequent profit/loss on sale of such stock of rice in future. 2.11. Having said that, the next issue that arises for consideration is whether the amount surrendered by way of investment in the unrecorded stock of rice has to be brought to tax under the head "business income" or "income from other sources". In the present case, the Assessee

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

C) The Hon'ble High Court, Gujarat Sh. VipuT Kumar Kirtilal Shah v. ITO Tax Appeal No. 1512 of 2011(Guj-HC):- Quote "Where assessee substantially agreed to computation of closing stock in statement but later claimed that discrepancy was due to error in computer generated programme, which was not established, addition on account of excess stock under section

RAJIV GOYAL, PATIALA,PATIALA, PUNJAB vs. JAO ITO WARD-3, PATIALA, PATIALA

In the result, the appeal filed by the assessee is allowed

Bench: the CIT(A) have not been considered properly.

c). Addition of Rs. 37,28,236/- Deepika Goyal wife of assessee. d). Addition of Rs. 4,00,00/- Amrit Chemtech, partnership of assessee 4. Against the order of the Assessing Officer the assessee went in appeal before the Ld. CIT(A), where detailed submissions, which have been reproduced 3 in the order of CIT(A) from pages

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

43,00,000/-), however, sustained some part of the additions (Rs. 4500000/-) made by the AO. ITA Nos. 26,27, 28 & 29/CHD/2022, 429 & 432/Chd/2021- Oswal Trend (P) Ltd. & Others, Ludhiana 5 6.1 The Revenue has come in appeal before us contesting the action of the Ld. CIT(A) in deleting the additions made by the AO, whereas, the assessee being

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

43,00,000/-), however, sustained some part of the additions (Rs. 4500000/-) made by the AO. ITA Nos. 26,27, 28 & 29/CHD/2022, 429 & 432/Chd/2021- Oswal Trend (P) Ltd. & Others, Ludhiana 5 6.1 The Revenue has come in appeal before us contesting the action of the Ld. CIT(A) in deleting the additions made by the AO, whereas, the assessee being