M/S ASHA TECHNOLOGIES,KALA AMB vs. ITO, SIRMOUR

In the result, both the above appeals of the Assessee are partly allowed as aforesaid in respect of impugned orders dt

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

transfer to a new business of machinery or plant previously used for any purpose." The perusal of relevant provisions of Section 80IC reveals that to become eligible for 80IC deduction, an assessee must satisfy the conditions mentioned in sub section (2) & (4), which are, in other words, qualifying provisions for exemption u/s 80IC of the Income Tax Act 1961. Eligibility

M/S AMBEY ENGINEERS AND CONTRACTORS,NEW DELHI vs. PR.CIT, PATIALA

In the result, all the appeals of the respective assessees stands allowed

Transfer Pricing Officer" shall have the same meaning as assigned to it in the Explanation to section 92CA.] (2) No order shall be made under sub-section (1) after the expiry of two years from the end of the financial year in which the order sought to be revised was passed. (3) Notwithstanding anything contained in sub-section

M/S HIND CONSTRUCTION ENGINEERS CONTRCTORS,SANGRUR vs. PR.CIT, PATIALA

In the result, all the appeals of the respective assessees stands allowed

Transfer Pricing Officer" shall have the same meaning as assigned to it in the Explanation to section 92CA.] (2) No order shall be made under sub-section (1) after the expiry of two years from the end of the financial year in which the order sought to be revised was passed. (3) Notwithstanding anything contained in sub-section

M/S AMAR CONTRUCTION AND ENGINEER ,SANGRUR vs. PCTI, PATIALA

In the result, all the appeals of the respective assessees stands allowed

Transfer Pricing Officer" shall have the same meaning as assigned to it in the Explanation to section 92CA.] (2) No order shall be made under sub-section (1) after the expiry of two years from the end of the financial year in which the order sought to be revised was passed. (3) Notwithstanding anything contained in sub-section

M/S ADARSH CONSTRUCTIONS AND ENGINEERS,SANGRUR vs. PR.CIT, PATIALA

In the result, all the appeals of the respective assessees stands allowed

Transfer Pricing Officer" shall have the same meaning as assigned to it in the Explanation to section 92CA.] (2) No order shall be made under sub-section (1) after the expiry of two years from the end of the financial year in which the order sought to be revised was passed. (3) Notwithstanding anything contained in sub-section

M/S ANAND ENGINEERS & CONTRACTORS,SANGURUR vs. PR.CIT, PATIALA

In the result, all the appeals of the respective assessees stands allowed

Transfer Pricing Officer" shall have the same meaning as assigned to it in the Explanation to section 92CA.] (2) No order shall be made under sub-section (1) after the expiry of two years from the end of the financial year in which the order sought to be revised was passed. (3) Notwithstanding anything contained in sub-section

M/S GANGA CONSTRUCTIONS,SANGURUR vs. PCIT, PATIALA

In the result, all the appeals of the respective assessees stands allowed

Transfer Pricing Officer" shall have the same meaning as assigned to it in the Explanation to section 92CA.] (2) No order shall be made under sub-section (1) after the expiry of two years from the end of the financial year in which the order sought to be revised was passed. (3) Notwithstanding anything contained in sub-section

M/S CHENAB CONSTRUCTION,SANGRUR vs. PCIT, PATIALA

In the result, all the appeals of the respective assessees stands allowed

Transfer Pricing Officer" shall have the same meaning as assigned to it in the Explanation to section 92CA.] (2) No order shall be made under sub-section (1) after the expiry of two years from the end of the financial year in which the order sought to be revised was passed. (3) Notwithstanding anything contained in sub-section

M/S HIMALYAN CONSTRUCTION AND ENGINEERS,SANGRUR vs. PCIT, PATIALA

In the result, all the appeals of the respective assessees stands allowed

Transfer Pricing Officer" shall have the same meaning as assigned to it in the Explanation to section 92CA.] (2) No order shall be made under sub-section (1) after the expiry of two years from the end of the financial year in which the order sought to be revised was passed. (3) Notwithstanding anything contained in sub-section

M/S MAA BHAGWATI ENTERPRISES,SANGRUR vs. PCIT, PATIALA

The appeals of the assessees stand allowed

Bench: Shri Sudhanshu Srivastava & Shri Vikram Singh Yadav

133(6) of the Income Tax Act, 1961 [in short 'the Act'] but the assessee firm did not furnish the required details. Therefore, the AO proceeded to issue notice u/s 148 of the Act. In response to this notice, the assessee filed its return of income declaring income of Rs. 28,710/- from business u/s 44AD

M/S OMKAR ENGINEER AND CONTRACTOR,SANGRUR vs. PCTI, PATIALA

The appeals of the assessees stand allowed

Bench: Shri Sudhanshu Srivastava & Shri Vikram Singh Yadav

133(6) of the Income Tax Act, 1961 [in short 'the Act'] but the assessee firm did not furnish the required details. Therefore, the AO proceeded to issue notice u/s 148 of the Act. In response to this notice, the assessee filed its return of income declaring income of Rs. 28,710/- from business u/s 44AD

M/S SHIV SHAKTI CONSTRUCTION,SANGRUR vs. PCIT, PATIALA

The appeals of the assessees stand allowed

Bench: Shri Sudhanshu Srivastava & Shri Vikram Singh Yadav

133(6) of the Income Tax Act, 1961 [in short 'the Act'] but the assessee firm did not furnish the required details. Therefore, the AO proceeded to issue notice u/s 148 of the Act. In response to this notice, the assessee filed its return of income declaring income of Rs. 28,710/- from business u/s 44AD

M/S OM CONTRACTOR AND ENGINEERS,SANGRUR vs. PCIT, PATIALA

The appeals of the assessees stand allowed

Bench: Shri Sudhanshu Srivastava & Shri Vikram Singh Yadav

133(6) of the Income Tax Act, 1961 [in short 'the Act'] but the assessee firm did not furnish the required details. Therefore, the AO proceeded to issue notice u/s 148 of the Act. In response to this notice, the assessee filed its return of income declaring income of Rs. 28,710/- from business u/s 44AD

JATIN GARG,CHANDIGARH vs. ASSTT. COMMISSIONER OF INCOME TAX, CC-2,, CHANDIGARH

In the result, the appeal of the assessee is allowed

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

133(6) on 06.05.222 and in response to that, the lender submitted complete details on 10.05.2022 as per (P.B. page 1) to the Ld. Assessing Officer. The Ld. Assessing Officer intentionally did not make mention of any such information called during the remand proceedings from the lender and the required details submitted by the lender during remand proceedings in remand

SH. ABHIMANYU SOIN,LUDHIANA vs. ACIT, LUDHIANA

In the result, appeal of the Assessee is dismissed

Bench: Shri. Sanjay Garg, Judicial, Member & Dr. B.R.R. Kumarassessment Year: 2011-12

133(6) then there is heavy onus on the AO to prove that the transaction is bogus and it cannot be simply done only on the imagination and probabilities built by the AO. It is pertinent to mention here that the purchase of shares of M/s Sharp Transport Pvt. Ltd. was made by the assessee in cash

SH. RAMINDER SINGH,MOHALI vs. INCOME TAX OFFICER, WARD-6(2), MOHALI

The appeal of the assessee stands partly allowed

Bench: Shri Sanjay Garg & Smt.Annapurna Guptaआयकर अपील सं./ Ita No.1270/Chd/2019 "नधा"रण वष" / Assessment Year : 2015-16

section 50C of the Act,as against 1.14 crs shown by the assessee, on the basis of information called for u/s 133(6) of the Act from the Estate Officer GMADA, who submitted as under: Size of Plot Transfer fees charged Total 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

6 Punjab & Haryana High Court in the case of Osho Forge Ltd. Vs CIT reported in 410 ITR 198, 255 Taxman 375. He drew our attention towards relevant paragraphs of the judgement which read as under : “11. The assessment order dated 24.12.2010 was passed under Section 153A read with Section 143(3) of the Act after obtaining approval under Section

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

6 Punjab & Haryana High Court in the case of Osho Forge Ltd. Vs CIT reported in 410 ITR 198, 255 Taxman 375. He drew our attention towards relevant paragraphs of the judgement which read as under : “11. The assessment order dated 24.12.2010 was passed under Section 153A read with Section 143(3) of the Act after obtaining approval under Section