M/S GANESH BUILDERS,PANCHKULA vs. DCIT, CC-1, CHANDIGARH

In the result, the respective appeals and stay applications are disposed off in light of aforesaid directions

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

survey u/s 133A was carried out. We find that the same is purely legal in nature and no new facts are required to be gone into to decide this ground of appeal. Therefore, in accordance with the law laid down by the Hon’ble Supreme Court in case of NTPC (Supra), the additional ground raised by the appellant is hereby

SH. LACHHMAN DASS BANSAL,BARNALA vs. DCIT, CENTRAL CIRCLE, PATIALA

The appeal of the assessee is partly allowed

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

transferred to Central Circle, Patiala vide notice, dated 21.10.20202. The assessee also requested vide letter, dated 04.11.2020 for copies of the statements recorded during survey, stock list as drawn and other documents. Thereafter, for the first time after more than 3 years, the notice was received from the Assessing Officer, Central Circle, Patiala, and the request was made

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)

u/s 133A of the IT Act to find out the true facts of the case when there was no compliance and cooperation on the part of the assessee to prove its primary onus. And on the basis of survey only true facts of the case were ascertained which helped in ascertaining the factual reality. The assessing office collected information u/s

M/S ASHA TECHNOLOGIES,SIRMOUR vs. ADDL. CIT, SOLAN

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)

u/s 133A of the IT Act to find out the true facts of the case when there was no compliance and cooperation on the part of the assessee to prove its primary onus. And on the basis of survey only true facts of the case were ascertained which helped in ascertaining the factual reality. The assessing office collected information u/s

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

133A - Whether\nvalid search is conducted against the assessee u/s 132? - HELD THAT:- We\nfind that the search has been initiated in the name of the assessee firm along\nwith names of partners appearing on the warrant of authorization issued u/s\n132(1) but no search was conducted at the business premises of the assessee\nfirm. The address mentioned

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

133A - Whether\nvalid search is conducted against the assessee u/s 132? - HELD THAT:- We\nfind that the search has been initiated in the name of the assessee firm along\nwith names of partners appearing on the warrant of authorization issued u/s\n132(1) but no search was conducted at the business premises of the assessee\nfirm. The address mentioned

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

133A - Whether\nvalid search is conducted against the assessee u/s 132? - HELD THAT:- We\nfind that the search has been initiated in the name of the assessee firm along\nwith names of partners appearing on the warrant of authorization issued u/s\n132(1) but no search was conducted at the business premises of the assessee\nfirm. The address mentioned

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

133A - Whether\nvalid search is conducted against the assessee u/s 132? - HELD THAT:- We\nfind that the search has been initiated in the name of the assessee firm along\nwith names of partners appearing on the warrant of authorization issued u/s\n132(1) but no search was conducted at the business premises of the assessee\nfirm. The address mentioned

SHRI KRISHAN KUMAR JALAN,BANGALORE vs. ITO, W-1, SIRSA

In the result appeal of the assessee is dismissed

transferred to the\nbeneficiaries at a very nominal price mostly off line through preferential\nallotment or offline sale to save STT.\n2.12 The beneficiary individuals were made to hold the shares for a\nminimum period of one year, the statutory period after which LTCG is\nexempt under the provisions of Section 10(38) of the Income Tax Act,\n1961.\n2.13

SH. SURINDER KUMAR,RAJPURA vs. ACIT, CIRCLE, PATIALA

In the result, all the three captioned appeals are allowed

Bench: Shri Sanjay Gargआयकर अपील सं./ Ita No. 433 /Chd/2023 "नधा"रण वष" / Assessment Year : 2018-19 बनाम Shri Mohinder Kumar, The Acit, #371, Dalima Vihar, Circle, Rajpaura 140401 Patiala Punjab "थायी लेखा सं./Pan No: Aenpk2131D अपीलाथ"/Appellant ""यथ"/Respondent

133A of the Income Tax Act, 1961 (in short 'the Act') was conducted at the business premises of the Assessee. During the course of survey, statement of the Assessee was recorded u/s 131 of the Act, wherein, the Assessee stated that the Assessee, Mohinder Kumar along with his two brothers Shri Surinder Kumar and Pawan Kumar, wife of the Assessee

SH. PAWAN KUMAR,RAJPURA vs. ACIT, CIRCLE, PATIALA

In the result, all the three captioned appeals are allowed

Bench: Shri Sanjay Gargआयकर अपील सं./ Ita No. 433 /Chd/2023 "नधा"रण वष" / Assessment Year : 2018-19 बनाम Shri Mohinder Kumar, The Acit, #371, Dalima Vihar, Circle, Rajpaura 140401 Patiala Punjab "थायी लेखा सं./Pan No: Aenpk2131D अपीलाथ"/Appellant ""यथ"/Respondent

133A of the Income Tax Act, 1961 (in short 'the Act') was conducted at the business premises of the Assessee. During the course of survey, statement of the Assessee was recorded u/s 131 of the Act, wherein, the Assessee stated that the Assessee, Mohinder Kumar along with his two brothers Shri Surinder Kumar and Pawan Kumar, wife of the Assessee

SH. MOHINDER KUMAR,RAJPURA vs. ACIT, CIRCLE, PATIALA

In the result, all the three captioned appeals are allowed

Bench: Shri Sanjay Gargआयकर अपील सं./ Ita No. 433 /Chd/2023 "नधा"रण वष" / Assessment Year : 2018-19 बनाम Shri Mohinder Kumar, The Acit, #371, Dalima Vihar, Circle, Rajpaura 140401 Patiala Punjab "थायी लेखा सं./Pan No: Aenpk2131D अपीलाथ"/Appellant ""यथ"/Respondent

133A of the Income Tax Act, 1961 (in short 'the Act') was conducted at the business premises of the Assessee. During the course of survey, statement of the Assessee was recorded u/s 131 of the Act, wherein, the Assessee stated that the Assessee, Mohinder Kumar along with his two brothers Shri Surinder Kumar and Pawan Kumar, wife of the Assessee

SARAF THE JEWELLER, CHANDIGARH,CHANDIGARH vs. THE DCIT/ACIT CENTRAL CIRCLE- 2, CHANDIGARH, CHANDIGARH

Appeal stand dismissed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं. / Ita No.1232/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2021-22) Saraf The Jeweller Dcit / Acit (Central)-2 बनाम/ Sco 45, Pocket No.1 C.R. Building Nac Showroom, Manimajra Himalaya Marg, Vs. Chandigarh – 160101 Sector-17E, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकरअपीलसं. / Ita No.1594/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2021-22) Dcit / Acit (Central)-2 Saraf The Jeweller बनाम/ C.R. Building Sco 45, Pocket No.1 Himalaya Marg, Nac Showroom, Manimajra Vs. Sector-17E, Chandigarh Chandigarh – 160101 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) Assessee By : Sh. Sudhir Sehgal (Advocate) & Sh. Sahil Ratra (Advocate) – Ld. Ars Revenue By : Sh. Abhishek Pal Garg (Cit) & Dr. Ranjit Kaur (Addl. Cit) – Ld. Drs सुनवाईकीतारीख/Date Of Hearing : 12.02.2026 घोषणाकीतारीख /Date Of Pronouncement 12.03.2026 : आदेश / O R D E R Per Bench

survey u/s 133A at assessee’s site office viz. Mohali Citi Centre, GMADA, Aerocity, Mohali, certain digital loose papers were found and impounded as Annexure-1 (Pages 16,17 & 18). The seized papers, inter-alia, contained list of customer’s names, sale price, unit and address along with welcome letter cum receipt allegedly issued by the assessee against sale

ASSISTANT COMMISSIONER OF INCOME TAX, CHANDIGARH vs. SARAF THE JEWELLERS, PUNJAB

Appeal stand dismissed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं. / Ita No.1232/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2021-22) Saraf The Jeweller Dcit / Acit (Central)-2 बनाम/ Sco 45, Pocket No.1 C.R. Building Nac Showroom, Manimajra Himalaya Marg, Vs. Chandigarh – 160101 Sector-17E, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकरअपीलसं. / Ita No.1594/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2021-22) Dcit / Acit (Central)-2 Saraf The Jeweller बनाम/ C.R. Building Sco 45, Pocket No.1 Himalaya Marg, Nac Showroom, Manimajra Vs. Sector-17E, Chandigarh Chandigarh – 160101 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) Assessee By : Sh. Sudhir Sehgal (Advocate) & Sh. Sahil Ratra (Advocate) – Ld. Ars Revenue By : Sh. Abhishek Pal Garg (Cit) & Dr. Ranjit Kaur (Addl. Cit) – Ld. Drs सुनवाईकीतारीख/Date Of Hearing : 12.02.2026 घोषणाकीतारीख /Date Of Pronouncement 12.03.2026 : आदेश / O R D E R Per Bench

survey u/s 133A at assessee’s site office viz. Mohali Citi Centre, GMADA, Aerocity, Mohali, certain digital loose papers were found and impounded as Annexure-1 (Pages 16,17 & 18). The seized papers, inter-alia, contained list of customer’s names, sale price, unit and address along with welcome letter cum receipt allegedly issued by the assessee against sale

LAKHVIR KAUR,MOHALI, CHANDIGARH vs. DCIT/ACIT(CEN)-2 CHD, CHANDIGARH

In the result, both the above appeals of the Assessee are\nallowed

transferred to the office of Ld. A.O. - ACIT- Central\nCircle II, Chandigarh vide order under section 127of the Income\nTax Act, 1961.\n5.2 Accordingly, assessment in the case under consideration\nhas been made u/s 153A r.w.s 143(3) of the Act, vide order dated\n31.03.2022 by the Ld. A.O.\n5.3 During the course of assessment for AY 2020-21, total

LAKHVIR KAUR,MOHALI vs. DCIT/ACIT(CEN)-2, CHANDIGARH

In the result, both the above appeals of the Assessee are\nallowed

transferred to the office of Ld. A.O. - ACIT- Central\nCircle II, Chandigarh vide order under section 127of the Income\nTax Act, 1961.\n5.2 Accordingly, assessment in the case under consideration\nhas been made u/s 153A r.w.s 143(3) of the Act, vide order dated\n31.03.2022 by the Ld. A.O.\n5.3 During the course of assessment for AY 2020-21, total

ITO (TDS), PATIALA vs. M/S S.A. SINGH & CO., BHAWANIGARH

In the result, the appeal of the Revenue is dismissed

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

133A(2A) of the Act was carried out at the business premises of the assessee on 15/12/2016 and on examination of the assessee’s records, it was noticed by the Survey Team that the assessee has made freight payment of Rs. 29,13,79,552/- to M/s Shree Guru Teg Bahadur Truck Operator Union Bhawanigarh for transport of goods