SH. AKHIL JAIN,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the ground no

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

price have already been mentioned therein and the assessment was duly framed under section 143(1) of the Act and thus it was a case of an unabated assessment. 7.1 It was submitted that the said disclosed income / documents cannot be treated as incriminating material. It was further submitted that there is no evidence or document which was found

SH. BIPAN JAIN,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the ground no

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

price have already been mentioned therein and the assessment was duly framed under section 143(1) of the Act and thus it was a case of an unabated assessment. 7.1 It was submitted that the said disclosed income / documents cannot be treated as incriminating material. It was further submitted that there is no evidence or document which was found

SH. ASHISH JAIN,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the ground no

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

price have already been mentioned therein and the assessment was duly framed under section 143(1) of the Act and thus it was a case of an unabated assessment. 7.1 It was submitted that the said disclosed income / documents cannot be treated as incriminating material. It was further submitted that there is no evidence or document which was found

SHRI ABHISHEK SOIN,LUDHIANA vs. DCIT, CC-II, LUDHIANA

The appeals are partly allowed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 321 & 322/Chd/2019 "नधा"रण वष" / Assessment Year: 2010-11, 2011-12 Shri Abhishek Soin, The Dcit, C/O Sigma Cartons Pvt. Ltd., Vs Central Circle-Ii, Unit-Ii, Industrial Area-C, Ludhiana. Sua Road, Ludhiana. "थायी लेखा सं./Pan No: Anbps9446A अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Aditya Kumar, Ca Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 03.06.2025 Date Of Pronouncement : 29.07.2025 Hybrid Hearing O R D E R

transferred to the beneficiary at a very nominal price mostly off-line through preferential allotment or off-line sale to save STT. The beneficiary (an individual) holds the share for one year, the statutory period after which LTCG is exempt under section 10(38) of the Income tax Act 1961. In the meantime the operators rig the price

SHRI ABHISHEK SOIN,LUDHIANA vs. DCIT, CC-II, LUDHIANA

The appeals are partly allowed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 321 & 322/Chd/2019 "नधा"रण वष" / Assessment Year: 2010-11, 2011-12 Shri Abhishek Soin, The Dcit, C/O Sigma Cartons Pvt. Ltd., Vs Central Circle-Ii, Unit-Ii, Industrial Area-C, Ludhiana. Sua Road, Ludhiana. "थायी लेखा सं./Pan No: Anbps9446A अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Aditya Kumar, Ca Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 03.06.2025 Date Of Pronouncement : 29.07.2025 Hybrid Hearing O R D E R

transferred to the beneficiary at a very nominal price mostly off-line through preferential allotment or off-line sale to save STT. The beneficiary (an individual) holds the share for one year, the statutory period after which LTCG is exempt under section 10(38) of the Income tax Act 1961. In the meantime the operators rig the price

SHRI SATISH SOIN,LUDHIANA vs. ACIT, CC-II, LUDHIANA

In the result, appeal of the assessee is allowed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 303/Chd/2019 "नधा"रण वष" / Assessment Year : 2012-13 Shri Satish Soin, बनाम The Acit, House No.31, Garden Enclave, Central Circle-2, Vs South City-Ii, Ludhiana. Ludhiana. "थायी लेखा सं./Pan /Tan No: Advps6254N अपीलाथ"/Appellant ""यथ"/Respondent "नधा"रती क" ओर से/Assessee By : Shri Ashwani Kumar & Ms. Muskan Garg, Cas राज"व क" ओर से/ Revenue By : Smt. Kusum Bansal, Cit Dr तार"ख/Date Of Hearing : 26.05.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 23.07.2025 Hybrid Hearing आदेश/Order Per Rajpal Yadav, Vp

transferred to the beneficiary at a very nominal price mostly off-line through preferential allotment or off-line sale to save STT. The beneficiary (an individual) holds the share for one year, the statutory period after which LTCG is exempt under section 10(38) of the Income tax Act 1961. In the meantime the operators rig the price

SMT. GINNY SOIN,LUDHIANA vs. ACIT, CC-II, LUDHIANA

The appeals are partly allowed

transferred\nto the beneficiary at a very nominal price mostly off-line through\npreferential allotment or off-line sale to save STT. The beneficiary\n(an individual) holds the share for one year, the statutory period\nafter which LTCG is exempt under section 10(38) of the Income\ntax Act 1961. In the meantime the operators rig the price

SH. DINESH SOIN,LUDHIANA vs. ACIT, LUDHIANA

The appeals are partly allowed

transferred\nto the beneficiary at a very nominal price mostly off-line through\npreferential allotment or off-line sale to save STT. The beneficiary\n(an individual) holds the share for one year, the statutory period\nafter which LTCG is exempt under section 10(38) of the Income\ntax Act 1961. In the meantime the operators rig the price

SMT. GINNY SOIN,LUDHIANA vs. ACIT, CC-II, LUDHIANA

The appeals are partly allowed

transferred\nto the beneficiary at a very nominal price mostly off-line through\npreferential allotment or off-line sale to save STT. The beneficiary\n(an individual) holds the share for one year, the statutory period\nafter which LTCG is exempt under section 10(38) of the Income\ntax Act 1961. In the meantime the operators rig the price

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2, LUDHIANA , LUDHIANA vs. AB ALCOBEV PRIVATE LIMITED, DELHI

In the result, appeals of Revenue are dismissed, Cross\nObjections of the assessee for

132A of the Act.\"\n22.1 The other orders relied upon by the assessee of ITAT\nChandigarh Bench are on the same line.\n23.\nIt is further observed that Section 158BD is pari\nmateria to Section 153C and judgement of Hon'ble Supreme\nCourt in the case of CIT Vs Calcutta Knitwears reported in\n362 ITR 673 also laid down

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2, LUDHIANA vs. AB ALCOBEV PRIVATE LIMITED, DELHI

In the result, appeals of Revenue are dismissed, Cross\nObjections of the assessee for

132A of the Act.\"\n22.1 The other orders relied upon by the assessee of ITAT\nChandigarh Bench are on the same line.\n23.\nIt is further observed that Section 158BD is pari\nmateria to Section 153C and judgement of Hon'ble Supreme\nCourt in the case of CIT Vs Calcutta Knitwears reported in\n362 ITR 673 also laid down

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2 LUDHIANA, LUDHIANA vs. AB ALCOBEV PRIVATE LIMITED , DELHI

In the result, appeals of Revenue are dismissed, Cross\nObjections of the assessee for

132A of the Act.\"\n22.1 The other orders relied upon by the assessee of ITAT\nChandigarh Bench are on the same line.\n23.\nIt is further observed that Section 158BD is pari\nmateria to Section 153C and judgement of Hon'ble Supreme\nCourt in the case of CIT Vs Calcutta Knitwears reported in\n362 ITR 673 also laid down

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2,, LUDHIANA vs. AB ALCOBEV PRIVATE LIMITED, DELHI

In the result, appeals of Revenue are dismissed, Cross\nObjections of the assessee for

132A of the Act.\"\n22.1 The other orders relied upon by the assessee of ITAT\nChandigarh Bench are on the same line.\n23.\nIt is further observed that Section 158BD is pari\nmateria to Section 153C and judgement of Hon'ble Supreme\nCourt in the case of CIT Vs Calcutta Knitwears reported in\n362 ITR 673 also laid down

MAXPORT INDIA PRIVATE LIMITED,CHANDIGARH vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,CHANDIGARH, CHANDIGARH

132A in the second\nproviso to sub-section (1) of section 153A shall be construed as reference to the date of\nreceiving the books of account or documents or assets seized or requisitioned by the\nAssessing Officer having jurisdiction over such other person”\n19. A perusal of the above provisions would reveal that section 153C starts with a\nnon-obstante

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

132A in the second\nproviso to sub-section (1) of section 153A shall be construed as reference to the date of\nreceiving the books of account or documents or assets seized or requisitioned by the\nAssessing Officer having jurisdiction over such other person”\n29\n19. A perusal of the above provisions would reveal that section 153C starts with a\nnon

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

transferred to the persons under control of Shirish Shah by Omprakash Khandelwal so as to provide LTCG in the shares of the company through synchronized trading. o The Directors of the company are dummy directors and the effective control and management of the company was with SCS. 6.9 The A.O. observed that SCS had accepted these facts during the course

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

transferred to the persons under control of Shirish Shah by Omprakash Khandelwal so as to provide LTCG in the shares of the company through synchronized trading. o The Directors of the company are dummy directors and the effective control and management of the company was with SCS. 6.9 The A.O. observed that SCS had accepted these facts during the course

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

transferred to the persons under control of Shirish Shah by Omprakash Khandelwal so as to provide LTCG in the shares of the company through synchronized trading. o The Directors of the company are dummy directors and the effective control and management of the company was with SCS. 6.9 The A.O. observed that SCS had accepted these facts during the course