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)

section 153A only on the basis of some incriminating material unearthed during the course of search which is clearly absent in the present case. Regarding finding of the AO that the character of certificate as found in the locker is itself incriminating material as it has been issued by the unauthorized broker indulging into an illegal trading, it was submitted

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)

section 153A only on the basis of some incriminating material unearthed during the course of search which is clearly absent in the present case. Regarding finding of the AO that the character of certificate as found in the locker is itself incriminating material as it has been issued by the unauthorized broker indulging into an illegal trading, it was submitted

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)

section 153A only on the basis of some incriminating material unearthed during the course of search which is clearly absent in the present case. Regarding finding of the AO that the character of certificate as found in the locker is itself incriminating material as it has been issued by the unauthorized broker indulging into an illegal trading, it was submitted

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

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

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

section 153C in the case of the assessee after duly\nrecording satisfaction that the seized documents belonged to the assessee and represented its\nundisclosed 11 income. In the absence of such compliance, the assessment so framed is without\njurisdiction and liable to be quashed.\n6. The Assessing Officer has relied upon various documents and digital data seized during\nthe search

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

section 153C in the case of the assessee after duly\nrecording satisfaction that the seized documents belonged to the assessee and represented its\nundisclosed 11 income. In the absence of such compliance, the assessment so framed is without\njurisdiction and liable to be quashed.\n6. The Assessing Officer has relied upon various documents and digital data seized during\nthe search

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

section 153C in the case of the assessee after duly\nrecording satisfaction that the seized documents belonged to the assessee and represented its\nundisclosed 11 income. In the absence of such compliance, the assessment so framed is without\njurisdiction and liable to be quashed.\n6. The Assessing Officer has relied upon various documents and digital data seized during\nthe search

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

section 153C in the case of the assessee after duly\nrecording satisfaction that the seized documents belonged to the assessee and represented its\nundisclosed 11 income. In the absence of such compliance, the assessment so framed is without\njurisdiction and liable to be quashed.\n6. The Assessing Officer has relied upon various documents and digital data seized during\nthe search

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

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

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

In the result, both the appeals are allowed

transferred to\nthe 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 tax\nAct 1961. In the meantime the operators rig the price

DAMANDEEP KAUR,MOHALI vs. ASSISTANT COMMISSIONER OF INCOME TAX (CENTRAL CIRCLE-2), CHANDIGARH, CHANDIGARH

In the result, all appeals of the assessee are allowed

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

Transfer Pricing Officer passed under sub-section (3) of section 92CA. For this class of assessees, it prescribes a collegium of three commissioners, once objections are preferred. The Dispute Resolution Panel's powers are coterminous with the Commissioner of Income-tax (Appeals), including the power to confirm, reduce or enhance the variation proposed and to consider the issues not agitated

DAMANDEEP KAUR,MOHALI vs. ASSISTANT COMMISSIONER OF INCOME TAX (CENTRAL CIRCLE-2), CHANDIGARH, CHANDIGARH

In the result, all appeals of the assessee are allowed

transfer-pricing cases and one for any non-resident\nassessee. It was emphasized that the AO having proposed variations prejudicial\nto the assessee, draft assessment order u/s 144C(1) became mandatory.\n13. It was submitted that the failure to issue a draft order renders the\nassessment void ab initio. The assessee further submitted that Section 144C\nbegins with

DAMANDEEP KAUR,MOHALI vs. ASSISTANT COMMISSIONER OF INCOME TAX (CENTRAL CIRCLE-2), CHANDIGARH, CHANDIGARH

In the result, all appeals of the assessee are allowed

transfer-pricing cases and one for any non-resident\nassessee. It was emphasized that the AO having proposed variations prejudicial\nto the assessee, draft assessment order u/s 144C(1) became mandatory.\n13.\nIt was submitted that the failure to issue a draft order renders the\nassessment void ab initio. The assessee further submitted that Section 144C\nbegins with

DAMANDEEP KAUR,MOHALI vs. ASSISTANT COMMISSIONER OF INCOME TAX (CENTRAL CIRCLE-2), CHANDIGARH, CHANDIGARH

In the result, all appeals of the assessee are allowed

transfer-pricing cases and one for any non-resident\nassessee. It was emphasized that the AO having proposed variations prejudicial\nto the assessee, draft assessment order u/s 144C(1) became mandatory.\n\n13.\nIt was submitted that the failure to issue a draft order renders the\nassessment void ab initio. The assessee further submitted that Section 144C\nbegins with