ITO, LUDHIANA vs. SH. CHARANJIT SINGH ATWAL, LUDHIANA

In the result, the penalty of the assessee is hereby allowed and that of the Revenue is dismissed

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumarassessment Year : 2007-08 Sh. Charanjit Singh Atwal, Vs. The Ito, Ward 6(1), 484-A, Model Town Extension, Ludhiana Ludhiana

68,276/-. 6. The Commissioner (Appeals) dismissed the appeal upholding the order passed by the Assessing Officer. Aggrieved by the order, the assessee filed appeal before the Income Tax Appellate Tribunal (ITAT), which was also dismissed by the ITAT. 7. The assessee further preferred appeal before the Hon'ble Punjab & Haryana High Court. The Hon'ble High Court vide order

SH. CHARANJIT SINGH ATWAL,LUDHIANA vs. ITO, LUDHIANA

In the result, the penalty of the assessee is hereby allowed and that of the Revenue is dismissed

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumarassessment Year : 2007-08 Sh. Charanjit Singh Atwal, Vs. The Ito, Ward 6(1), 484-A, Model Town Extension, Ludhiana Ludhiana

68,276/-. 6. The Commissioner (Appeals) dismissed the appeal upholding the order passed by the Assessing Officer. Aggrieved by the order, the assessee filed appeal before the Income Tax Appellate Tribunal (ITAT), which was also dismissed by the ITAT. 7. The assessee further preferred appeal before the Hon'ble Punjab & Haryana High Court. The Hon'ble High Court vide order

SH. JAI RAM,JAGADHARI vs. ITO, YAMUNANAGAR

In the result, both the appeal of different assessees are allowed

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

68,000/- in cash, Rs. 16,77,625/- by cheque dated 15.03.2007 and Rs. 1,74,55,250/- by cheque from M/s Stepping Stone Buildhome Pvt. Ltd. Jaipur. The proceeds of the aforesaid cheques were realized by assessee in March, 2007 and August, 2008 respectively. The assessee offered the part sale consideration of Rs. 17,45,625/- for capital gains

SH. AMAR SINGH,JAGADHARI vs. ITO, YAMUNANAGAR

In the result, both the appeal of different assessees are allowed

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

68,000/- in cash, Rs. 16,77,625/- by cheque dated 15.03.2007 and Rs. 1,74,55,250/- by cheque from M/s Stepping Stone Buildhome Pvt. Ltd. Jaipur. The proceeds of the aforesaid cheques were realized by assessee in March, 2007 and August, 2008 respectively. The assessee offered the part sale consideration of Rs. 17,45,625/- for capital gains

SH. SANJAY SINGAL HUF,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-

68 Pages). It is, therefore prayed that these documents may kindly be admitted as additional evidence in the aforesaid cases, and these may be considered at the time of hearing of the appeals on merits. This is being filed in digital mode and physical copy would also be made available if required. Revenue shall be obliged

SH. ANIKET SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-

68 Pages). It is, therefore prayed that these documents may kindly be admitted as additional evidence in the aforesaid cases, and these may be considered at the time of hearing of the appeals on merits. This is being filed in digital mode and physical copy would also be made available if required. Revenue shall be obliged

SMT. AARTI SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-

68 Pages). It is, therefore prayed that these documents may kindly be admitted as additional evidence in the aforesaid cases, and these may be considered at the time of hearing of the appeals on merits. This is being filed in digital mode and physical copy would also be made available if required. Revenue shall be obliged

SH. SANJAY SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-

68 Pages). It is, therefore prayed that these documents may kindly be admitted as additional evidence in the aforesaid cases, and these may be considered at the time of hearing of the appeals on merits. This is being filed in digital mode and physical copy would also be made available if required. Revenue shall be obliged

SH. ANIKET SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-

68 Pages). It is, therefore prayed that these documents may kindly be admitted as additional evidence in the aforesaid cases, and these may be considered at the time of hearing of the appeals on merits. This is being filed in digital mode and physical copy would also be made available if required. Revenue shall be obliged

SMT. AARTI SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-

68 Pages). It is, therefore prayed that these documents may kindly be admitted as additional evidence in the aforesaid cases, and these may be considered at the time of hearing of the appeals on merits. This is being filed in digital mode and physical copy would also be made available if required. Revenue shall be obliged

SH. SANJAY SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-

68 Pages). It is, therefore prayed that these documents may kindly be admitted as additional evidence in the aforesaid cases, and these may be considered at the time of hearing of the appeals on merits. This is being filed in digital mode and physical copy would also be made available if required. Revenue shall be obliged

SMT. AARTI SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-

68 Pages). It is, therefore prayed that these documents may kindly be admitted as additional evidence in the aforesaid cases, and these may be considered at the time of hearing of the appeals on merits. This is being filed in digital mode and physical copy would also be made available if required. Revenue shall be obliged

SH. SANJAY SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-

68 Pages). It is, therefore prayed that these documents may kindly be admitted as additional evidence in the aforesaid cases, and these may be considered at the time of hearing of the appeals on merits. This is being filed in digital mode and physical copy would also be made available if required. Revenue shall be obliged

NEERU ARORA,CHANDIGARH vs. CIRCLE-1, INTERNATIONAL TAXATION, CHANDIGARH

In the result, the appeal of the assessee is partly allowed in terms indicated above

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. MANOJ KUMAR AGGARWAL (Accountant Member)

53A of the Transfer of Property Act and section 2(47)(v) of the Act. 6. The AO, however, rejected the explanation and finalised the draft assessment order dated 03.03.2023 by adopting the stamp duty value of Rs.1.51 crore as deemed consideration under section 50C. He further denied the benefit of the indexed cost of acquisition and initiated

SH. CHETAN JAIN,LUDHIANA vs. DCIT, LUDHIANA

In the result, the appeal of the assessee is dismissed

Bench: Shri Sanjay Garg & Ms. Annapurna Guptash.Chetan Jain, Vs. The D.C.I.T., B-121, Pushap Vihar, Central Circle-Iii, Canal Road, Ludhiana. Ludhiana. Pan: Aaypj0618H (Appellant) (Respondent)

68,020/-,being 100% of the tax sought to be evaded on the income concealed. 3. The matter was carried in appeal before the Ld.CIT(A),where the assessee reiterated the contentions made before the AO and further contended that since no incriminating material was found during search no penalty could be imposed even by invoking Explanation 5A to section

SCOTT EDIL ADVANCE RESEARCH LABORATORIES AND EDUCATION LIMITED,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

section 80IC of the Act. Subject to above observations, this\nissue is decided in favour of the revenue.\nIssue 9 : Credits received from JAAPL and Disallowance u/s 80IC - GP earned on sale made\nto JAPPL on account of alleged bogus nature of sales to JAPPL.\n98. Following is the list of cases involving this issue :-\nSr.\nNo\n.\nName

SHRI BALRAM KRISHAN,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH, CHANDIGARH

Section 69B of the Act. In absence of any other material on\nrecord, addition was correctly deleted. Tax Appeal is, therefore, dismissed.”\n11. A perusal of the above judgments would indicate that mere valuation report is not\nsufficient to conclude that the assessee has made unexplained investment. From perusal\nof the assessment, nowhere it reveals that inspite of search

SCOTT EDIL ADVANCE RESEARCH LABORATORIES AND EDUCATION LIMITED,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

section 80IC of the Act. Subject to above observations, this\nissue is decided in favour of the revenue.\nIssue 9 : Credits received from JAAPL and Disallowance u/s 80IC - GP earned on sale made\nto JAPPL on account of alleged bogus nature of sales to JAPPL.\n98. Following is the list of cases involving this issue :-\nSr.\nNo\n.\nName

SHRI BALRAM KRISHAN,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH, CHANDIGARH

section 158BD calling upon assessee to file return of undisclosed income\nfor block period 1-4-1989 to 28-1-2000 - Thereafter, valuation of cost of construction of\nbuildings constructed by assessee-firm was referred to DVO, for valuation under section\n133(6) - Assessing Officer added difference in valuation of cost of construction adopted\nby assessee-firm