DCIT, C-1, LUDHIANA vs. M/S VARDHMAN TEXTILES LIMITED, LUDHIANA

In the result, appeals of the Assessee are partly allowed whereas the Cross appeals of the Revenue are dismissed

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. SHRI. KRINWANT SAHAY (Accountant Member)

income of Rs. 65,47,626/-. Its breakup is rebate and discount of Rs. 55,97,132/-, recovery from contractor of Rs. 7,24,136/- and other miscellaneous receipts of Rs. 2,26,358/-. 16.5 Regarding the rebate and discount, this comprises of Turnover discount received from suppliers. It is undisputedly relates to material purchases, which is, obviously the business

ACIT,CIRCLE-1, LUDHIANA vs. M/S VARDHMAN TEXTILES LTD., LUDHIANA

In the result, appeals of the Assessee are partly allowed whereas the Cross appeals of the Revenue are dismissed

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. SHRI. KRINWANT SAHAY (Accountant Member)

income of Rs. 65,47,626/-. Its breakup is rebate and discount of Rs. 55,97,132/-, recovery from contractor of Rs. 7,24,136/- and other miscellaneous receipts of Rs. 2,26,358/-. 16.5 Regarding the rebate and discount, this comprises of Turnover discount received from suppliers. It is undisputedly relates to material purchases, which is, obviously the business

M/S VARDHMAN TEXTILES LIMITED,LUDHIANA vs. ACIT, C-1, LUDHIANA

In the result, appeals of the Assessee are partly allowed whereas the Cross appeals of the Revenue are dismissed

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. SHRI. KRINWANT SAHAY (Accountant Member)

income of Rs. 65,47,626/-. Its breakup is rebate and discount of Rs. 55,97,132/-, recovery from contractor of Rs. 7,24,136/- and other miscellaneous receipts of Rs. 2,26,358/-. 16.5 Regarding the rebate and discount, this comprises of Turnover discount received from suppliers. It is undisputedly relates to material purchases, which is, obviously the business

VARDHMAN TEXTILES LIMITED,LUDHIANA vs. ACIT-CIRCLE-1, LUDHIANA

In the result, appeals of the Assessee are partly allowed whereas the Cross appeals of the Revenue are dismissed

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. SHRI. KRINWANT SAHAY (Accountant Member)

income of Rs. 65,47,626/-. Its breakup is rebate and discount of Rs. 55,97,132/-, recovery from contractor of Rs. 7,24,136/- and other miscellaneous receipts of Rs. 2,26,358/-. 16.5 Regarding the rebate and discount, this comprises of Turnover discount received from suppliers. It is undisputedly relates to material purchases, which is, obviously the business

M/S VARDHMAN TEXTILES LIMITED,LUDHIANA vs. DCIT, C-1, LUDHIANA

In the result, appeals of the Assessee are partly allowed whereas the Cross appeals of the Revenue are dismissed

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. SHRI. KRINWANT SAHAY (Accountant Member)

income of Rs. 65,47,626/-. Its breakup is rebate and discount of Rs. 55,97,132/-, recovery from contractor of Rs. 7,24,136/- and other miscellaneous receipts of Rs. 2,26,358/-. 16.5 Regarding the rebate and discount, this comprises of Turnover discount received from suppliers. It is undisputedly relates to material purchases, which is, obviously the business

PAREXEL INTERNATIONAL SERVICES INDIA PVT.LTD,,CHANDIGARH vs. ACIT,CIRCLE-5(1),(NEAC), CHANDIGARH

In the result, the appeal of the Assessee is partly allowed

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. SHRI. KRINWANT SAHAY (Accountant Member)

Transfer Pricing adjustment order, which is under challenge before us. 3 5. Vide order dt. 31/03/2021, assessment was finalised by the National e- Assessment Centre, Delhi, pursuant to directions of the Dispute Resolution Panel, under section 143(3) r.w.s. 144C(13) read with sections 143(3A) and 143(3B) of the Income Tax Act. Aggrieved therewith, the assessee

KAPIL GUPTA,SIRMAUR vs. ACIT CENTRAL CIRCLE SHIMLA, SHIMLA

The appeals stand partly allowed in terms of our above order

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.1010/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2020-21) & 2. आयकर अपील सं. / Ita No.1011/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2021-22) 3. आयकर अपील सं. / Ita No.1012/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2022-23) & 4. आयकर अपील सं. / Ita No.1013/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2023-24) Shri Kapil Gupta Acit (Central) C/O M/S Himgiri Beverages बनाम/ Vs. Shimla (Hp) -171001 Kala Amb – 173030 (Hp) "थायीलेखासं./जीआइआरसं./Pan/Gir No. Addpg-0399-Q (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Ajay Jain (Ca) A/W Sh. Lovesh Bansal (Ca) – Ld. Ars ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) & Shri Rajat Kumar Kureel (Cit) – Ld. Drs Date Of Final Hearing : 27-01-2026 Date Of Pronouncement : 29-01-2026 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeals By Assessee For Assessment Years (Ay) 2020-21 To 2023-24 Arises Out Of Separate Orders Of Learned First

transfer such unaccounted liquor are destroyed after delivery to the buyers. d) Perusal of the above statements of employees of M/s Himgiri Beverages corroborated the fact that the three Diaries belonging to calendar year 2020 (Annexure A-1), calendar year 2021 (Annexure A-2) & calendar year 2022 (Annexure A-3) which were found and seized from the residential premise

KAPIL GUPTA,SIRMAUR vs. ACIT CENTRAL CIRCLE SHIMLA, SHIMLA

The appeals stand partly allowed in terms of our above order

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.1010/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2020-21) & 2. आयकर अपील सं. / Ita No.1011/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2021-22) 3. आयकर अपील सं. / Ita No.1012/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2022-23) & 4. आयकर अपील सं. / Ita No.1013/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2023-24) Shri Kapil Gupta Acit (Central) C/O M/S Himgiri Beverages बनाम/ Vs. Shimla (Hp) -171001 Kala Amb – 173030 (Hp) "थायीलेखासं./जीआइआरसं./Pan/Gir No. Addpg-0399-Q (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Ajay Jain (Ca) A/W Sh. Lovesh Bansal (Ca) – Ld. Ars ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) & Shri Rajat Kumar Kureel (Cit) – Ld. Drs Date Of Final Hearing : 27-01-2026 Date Of Pronouncement : 29-01-2026 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeals By Assessee For Assessment Years (Ay) 2020-21 To 2023-24 Arises Out Of Separate Orders Of Learned First

transfer such unaccounted liquor are destroyed after delivery to the buyers. d) Perusal of the above statements of employees of M/s Himgiri Beverages corroborated the fact that the three Diaries belonging to calendar year 2020 (Annexure A-1), calendar year 2021 (Annexure A-2) & calendar year 2022 (Annexure A-3) which were found and seized from the residential premise

KAPIL GUPTA,SIRMAUR vs. ACIT CENTRAL SHIMLA, SHIMLA

The appeals stand partly allowed in terms of our above order

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.1010/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2020-21) & 2. आयकर अपील सं. / Ita No.1011/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2021-22) 3. आयकर अपील सं. / Ita No.1012/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2022-23) & 4. आयकर अपील सं. / Ita No.1013/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2023-24) Shri Kapil Gupta Acit (Central) C/O M/S Himgiri Beverages बनाम/ Vs. Shimla (Hp) -171001 Kala Amb – 173030 (Hp) "थायीलेखासं./जीआइआरसं./Pan/Gir No. Addpg-0399-Q (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Ajay Jain (Ca) A/W Sh. Lovesh Bansal (Ca) – Ld. Ars ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) & Shri Rajat Kumar Kureel (Cit) – Ld. Drs Date Of Final Hearing : 27-01-2026 Date Of Pronouncement : 29-01-2026 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeals By Assessee For Assessment Years (Ay) 2020-21 To 2023-24 Arises Out Of Separate Orders Of Learned First

transfer such unaccounted liquor are destroyed after delivery to the buyers. d) Perusal of the above statements of employees of M/s Himgiri Beverages corroborated the fact that the three Diaries belonging to calendar year 2020 (Annexure A-1), calendar year 2021 (Annexure A-2) & calendar year 2022 (Annexure A-3) which were found and seized from the residential premise

KAPIL GUPTA,SIRMAUR vs. ACIT CENTRAL CIRCLE SHIMLA, SHIMLA

The appeals stand partly allowed in terms of our above order

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.1010/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2020-21) & 2. आयकर अपील सं. / Ita No.1011/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2021-22) 3. आयकर अपील सं. / Ita No.1012/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2022-23) & 4. आयकर अपील सं. / Ita No.1013/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2023-24) Shri Kapil Gupta Acit (Central) C/O M/S Himgiri Beverages बनाम/ Vs. Shimla (Hp) -171001 Kala Amb – 173030 (Hp) "थायीलेखासं./जीआइआरसं./Pan/Gir No. Addpg-0399-Q (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Ajay Jain (Ca) A/W Sh. Lovesh Bansal (Ca) – Ld. Ars ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) & Shri Rajat Kumar Kureel (Cit) – Ld. Drs Date Of Final Hearing : 27-01-2026 Date Of Pronouncement : 29-01-2026 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeals By Assessee For Assessment Years (Ay) 2020-21 To 2023-24 Arises Out Of Separate Orders Of Learned First

transfer such unaccounted liquor are destroyed after delivery to the buyers. d) Perusal of the above statements of employees of M/s Himgiri Beverages corroborated the fact that the three Diaries belonging to calendar year 2020 (Annexure A-1), calendar year 2021 (Annexure A-2) & calendar year 2022 (Annexure A-3) which were found and seized from the residential premise

ITO, WARD, PARWANOO vs. M/S PREETHI HIMACHAL & COMPANY, NALAGARH

In the result, both the appeals of the revenue are hereby dismissed

Bench: Shri Sanjay Garg & Shri Vikram Singh Yadav

transferring its business on slump sale basis to Preeti Kitchen Appliances Private Limited. The purchase price for such slump sale was agreed at Rs.184,59,00,000/-, with Rs.161,51,62,500/- received in FY 2011-12 and the remaining amount was kept in escrow and received in FY 2012-13. The said amount was invested in securities (shares/mutual funds/bonds

ITO, WARD, PARWANOO vs. M/S PREETHI HIMACHAL & COMPANY, NALAGARH

In the result, both the appeals of the revenue are hereby dismissed

Bench: Shri Sanjay Garg & Shri Vikram Singh Yadav

transferring its business on slump sale basis to Preeti Kitchen Appliances Private Limited. The purchase price for such slump sale was agreed at Rs.184,59,00,000/-, with Rs.161,51,62,500/- received in FY 2011-12 and the remaining amount was kept in escrow and received in FY 2012-13. The said amount was invested in securities (shares/mutual funds/bonds

BALJIT SINGH,AMBALA CITY vs. INCOME TAX OFFICER, WARD-1, AMBALA, AMBALA

business or profession\" or \"Income from other sources\",\nshall be computed in accordance with either cash or mercantile system of\naccounting regularly employed by the assessee. Further, the Hon'ble Supreme Court\nin the case of Rama Sai v. CIT (181 ITR 400) has held that arrears of interest computed\non delayed or enhanced compensation shall be taxable on accrual

CT EDUCATIONAL SOCIETY,JALANDHAR vs. DCIT, CHANDIGARH

In the result, the appeal filed by the Assessee is Partly Allowed for\nStatistical Purposes as per the directions above

price and no\ninterest bearing loan was used for the purpose, the addition on such account is\nnot justified. Thus, for the shake of principle of natural justice the AO should also\nget an opportunity to examine the contention of the appellant and therefore, I\ndirect the AO to verify the claim of the appellant on this issue

SH. AJIT SINGH,PINJORE vs. ITO, WARD-1, PANCHKULA

business or profession\" or \"Income from other sources\",\nshall be computed in accordance with either cash or mercantile system of\naccounting regularly employed by the assessee. Further, the Hon'ble Supreme Court\nin the case of Rama Sai v. CIT (181 ITR 400) has held that arrears of interest computed\non delayed or enhanced compensation shall be taxable on accrual

SH. RAMESH CHAND,JAGADHRI vs. ITO, WARD-3, YAMUNA NAGAR

business or profession\" or \"Income from other sources\",\nshall be computed in accordance with either cash or mercantile system of\naccounting regularly employed by the assessee. Further, the Hon'ble Supreme Court\nin the case of Rama Sai v. CIT (181 ITR 400) has held that arrears of interest computed\non delayed or enhanced compensation shall be taxable on accrual

SH. RAM LAL,CHANDIGARH vs. ITO, WARD-6(1), CHANDIGARH

business or profession\" or \"Income from other sources\",\nshall be computed in accordance with either cash or mercantile system of\naccounting regularly employed by the assessee. Further, the Hon'ble Supreme Court\nin the case of Rama Sai v. CIT (181 ITR 400) has held that arrears of interest computed\non delayed or enhanced compensation shall be taxable on accrual

INCOME TAX OFFICER, WARD-5(5), CHANDIGARH, CHANDIGARH vs. AVTAR SINGH, VILLAGE- KAIMBWALA

income-tax under clauses (ii) and (iii) of section\n28 or section 41 or section 59;\n53[(va) any sum chargeable to income-tax under clause (iiia) of section 28 ;]\n54[(vb) any sum chargeable to income-tax under clause (iiib) of section 28 ;]\n55[(vc) any sum chargeable to income-tax under clause (iiic) of section