OSWAL POLYCOT (INDIA) PVT. LTD.,LUDHIANA vs. DCIT, CC-I, LUDHIANA

In the result, the appeal of the assessee in ITA No

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

3) of the Act, even then the same should be quashed on the ground that no Notice under Section 143(2) of the Act had ever been issued by the Learned Assessing Officer against the Return of Income filed by the Appellant Company under Section 153C of the Act. 4. That the Learned Assessing Officer has made

DCIT, CC-I, LUDHIANA vs. OSWAL POLYCOT (INDIA) PVT. LTD., LUDHIANA

In the result, the appeal of the assessee in ITA No

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

3) of the Act, even then the same should be quashed on the ground that no Notice under Section 143(2) of the Act had ever been issued by the Learned Assessing Officer against the Return of Income filed by the Appellant Company under Section 153C of the Act. 4. That the Learned Assessing Officer has made

DCIT, CC-I, LUDHIANA vs. OSWAL POLYCOT (INDIA) PVT. LTD., LUDHIANA

In the result, the appeal of the assessee in ITA No

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

3) of the Act, even then the same should be quashed on the ground that no Notice under Section 143(2) of the Act had ever been issued by the Learned Assessing Officer against the Return of Income filed by the Appellant Company under Section 153C of the Act. 4. That the Learned Assessing Officer has made

INCOME TAX OFFICER, PARWANOO vs. DEEPAK KUMAR, NAHAN

In the result, the appeal of the Revenue is dismissed

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

6. The submissions so filed by the assessee were considered but not found acceptable to the AO. The AO referred to the provisions of Section 154 of the Act and thereafter held that the income of Rs. 2,61,69,869/- assessed under Section 68 of the Act is duly covered under the provisions of Section 115BBE

DCIT, CHANDIGARH vs. SH. KULWANT SINGH, MOHALI

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

68, 69A, 69B, 69C and 69D can be misused by the assessees to circumvent the ‘Voluntary ITA Nos.41 to 44, 387, 45 to 54/Chd/17 & CO 16-to 30-Chd-2018- Shri Kulwant Singh & Others, Mohali 32 Disclosure Scheme’ and to get their income into rotation / accounted for by paying 30% tax and declaring the same under the aforesaid sections

DCIT, CHANDIGARH vs. SH. KULWANT SINGH, MOHALI

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

68, 69A, 69B, 69C and 69D can be misused by the assessees to circumvent the ‘Voluntary ITA Nos.41 to 44, 387, 45 to 54/Chd/17 & CO 16-to 30-Chd-2018- Shri Kulwant Singh & Others, Mohali 32 Disclosure Scheme’ and to get their income into rotation / accounted for by paying 30% tax and declaring the same under the aforesaid sections

DCIT, CHANDIGARH vs. SMT. MANJIT KAUR, CHANDIGARH

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

68, 69A, 69B, 69C and 69D can be misused by the assessees to circumvent the ‘Voluntary ITA Nos.41 to 44, 387, 45 to 54/Chd/17 & CO 16-to 30-Chd-2018- Shri Kulwant Singh & Others, Mohali 32 Disclosure Scheme’ and to get their income into rotation / accounted for by paying 30% tax and declaring the same under the aforesaid sections

DCIT, CHANDIGARH vs. SH. PARAMJIT SINGH, MOHALI

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

68, 69A, 69B, 69C and 69D can be misused by the assessees to circumvent the ‘Voluntary ITA Nos.41 to 44, 387, 45 to 54/Chd/17 & CO 16-to 30-Chd-2018- Shri Kulwant Singh & Others, Mohali 32 Disclosure Scheme’ and to get their income into rotation / accounted for by paying 30% tax and declaring the same under the aforesaid sections

DCIT, CHANDIGARH vs. SMT. JASWANT KAUR, MOHALI

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

68, 69A, 69B, 69C and 69D can be misused by the assessees to circumvent the ‘Voluntary ITA Nos.41 to 44, 387, 45 to 54/Chd/17 & CO 16-to 30-Chd-2018- Shri Kulwant Singh & Others, Mohali 32 Disclosure Scheme’ and to get their income into rotation / accounted for by paying 30% tax and declaring the same under the aforesaid sections

DCIT, CHANDIGARH vs. SH. PARAMJIT SINGH, MOHALI

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

68, 69A, 69B, 69C and 69D can be misused by the assessees to circumvent the ‘Voluntary ITA Nos.41 to 44, 387, 45 to 54/Chd/17 & CO 16-to 30-Chd-2018- Shri Kulwant Singh & Others, Mohali 32 Disclosure Scheme’ and to get their income into rotation / accounted for by paying 30% tax and declaring the same under the aforesaid sections

DCIT, CHANDIGARH vs. SMT. JASWANT KAUR, MOHALI

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

68, 69A, 69B, 69C and 69D can be misused by the assessees to circumvent the ‘Voluntary ITA Nos.41 to 44, 387, 45 to 54/Chd/17 & CO 16-to 30-Chd-2018- Shri Kulwant Singh & Others, Mohali 32 Disclosure Scheme’ and to get their income into rotation / accounted for by paying 30% tax and declaring the same under the aforesaid sections

M/S SATWANT AGRO ENGINEERS,BHAWANIGARH vs. DCIT, CENTRAL CIRCLE, PATIALA

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

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

3. That the Ld Commissioner of Income Tax (Appeals) was erred in law to hold the entry of Rs.50,00,000.00 in capital account (Rs.25,00,000.00 each partner) covered u/s 68 instead of section 69 as assessed by Assessing Officer. The surrendered amount is neither covered u/s 68 nor u/s 69 of Income Tax Act 1961. 4. That

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, LUDHIANA, LUDHIANA vs. M/S JAMNA DASS NIKKAMAL JAIN SARAF PVT. LTD., LUDHIANA

In the result, the appeal filed by Revenue is dismissed and the appeal filed by the Assessee is allowed

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

68,78,906 Table 2 5,81,99,126 Table 3 4,15,99,065 Table 4 5,90,85,926 Table 5 6,13,95,026 Table 7 6,48,54,173 Table 8 1,87,18,474 Table 9 67,94,892 Page no 44 of A-3 12,80,679 Page

JAMNA DASS NIKKAMAL JAIN SARAF PRIVATE LIMITED, LUDHIANA,LUDHIANA vs. THE DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 1, LUDHIANA, LUDHIANA

In the result, the appeal filed by Revenue is dismissed and the appeal filed by the Assessee is allowed

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

68,78,906 Table 2 5,81,99,126 Table 3 4,15,99,065 Table 4 5,90,85,926 Table 5 6,13,95,026 Table 7 6,48,54,173 Table 8 1,87,18,474 Table 9 67,94,892 Page no 44 of A-3 12,80,679 Page

WINSOME TEXTILE INDUSTRIES LIMITED,CHANDIGARH vs. ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-4(1), CHANDIGARH, CHANDIGARH

In the result, the appeal of the assessee is partly allowed and the appeal of the Revenue is dismissed

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

6,45,00,000/-being share capital and Rs. 38,30,88,075/- being security premium totaling to Rs. 44,75,88,075/- as income from undisclosed sources and which was brought to tax by invoking the provisions of Section 68 of the Act. The AO further did not allow the set off of the income so assessed against

HOMELIFE BUILDCON PRIVATE LIMITED,SUNVIEW ENCLAVE, AYALI KALAN, LUDHIANA,PUNJAB vs. SMT. SAMANDEEP KAUR DCIT-CENTRAL CIRCLE-1, LUDHIANA, PUNJAB

In the result, Revenue appeal is dismissed and appeal filed by the assessee is allowed

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 880/Chd/2024 निर्धारण वर्ष / Assessment Year : 2021-22 Homelife Buildcon Private Limited Sunview Enclave, Ayali Kalan, Ludhiana, Punjab-142027 स्थायी लेखा सं./PAN NO: AABCH5690M अपीलार्थी/Appellant बनाम The DCIT Central Circle-1 Ludhiana, Punjab प्रत्यर्थी/Respondent आयकर अपील सं. / ITA No. 1036/Chd/2024 निर्धारण वर्ष / Assessment Year : 2021-22 बनाम Homelife Buildcon Private Limited Sunview Enclave, Ayali

68. As regards ground No.5 & 6, which corresponds to the ground No. 3 (a) (b) (c) of the assessee’s appeal, we have considered the arguments of both parties and the order of authorities below and find that the addition has solely been based on the basis of ‘digital data’ found from the search carried out on Sh. Ajay Prabhakar

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, LUDHIANA , LUDHIANA vs. HOMELIFE BUILDCON PVT. LTD., LUDHIANA

In the result, Revenue appeal is dismissed and appeal filed by the assessee is allowed

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 880/Chd/2024 निर्धारण वर्ष / Assessment Year : 2021-22 Homelife Buildcon Private Limited Sunview Enclave, Ayali Kalan, Ludhiana, Punjab-142027 स्थायी लेखा सं./PAN NO: AABCH5690M अपीलार्थी/Appellant The DCIT Central Circle-1 Ludhiana, Punjab प्रत्यर्थी/Respondent आयकर अपील सं. / ITA No. 1036/Chd/2024 निर्धारण वर्ष / Assessment Year : 2021-22 Homelife Buildcon Private Limited Sunview Enclave, Ayali Kalan, Lu

68. As regards ground No.5 & 6, which corresponds to the ground No. 3 (a) (b) (c) of the assessee’s appeal, we have considered the arguments of both parties and the order of authorities below and find that the addition has solely been based on the basis of ‘digital data’ found from the search carried out on Sh. Ajay Prabhakar

ARYANS EDUCATIONAL AND CHARITABLE TRUST REGD, MOHALI,MOHALI vs. COMMISSIONER OF INCOME TAX, EXEMPTIONS, CHANDIGARH

In the result, appeal is allowed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 1136/Chd/2024 "नधा"रण वष" / Assessment Year: 2025-26 Aryans Educational & The Cit (Exemptions), Charitable Trust, Regd.Mohali Vs Chandigarh, C/O Shri Tej Mohan Singh, Advocate, # 527, Sector 10-D, Chandigarh. "थायी लेखा सं./Pan No: Aabta7550L अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Tej Mohan Singh, Advocate Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 07.08.2025 Date Of Pronouncement : 24.09.2025

68 of the Act treating corpus donations received from students to be anonymous donations. 8. We find that the not considering the evidence filed by the Assessee during the appellate proceedings before the ld. CIT(A) is not justified on the part of the ld. CIT(A). In fact, the case laws relied upon