ITO, W-6(5), MOHALI vs. SMT. GURDEV KAUR, KHARAR

In the result, the appeal of the Revenue is dismissed

Bench: Disposal Of Appeal.”

credit of only land sold at Rs. 62,70,000/- in the absence of cash flow statement. (In fact assessee had sold land for Rs. 2,30,00,000/- and registry was made for a sum o f Rs. 73,15,000/- as submitted in the chart earlier) It was in the above background that cash flow statement has been

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

prices in the open market. The department had verified the franchise status of M/s KLG Jewellers during the course of search itself. Therefore, M/s KLG Jewellers could not be said to be an independent retailer. Accordingly, the allegation of Ld. AO had no foundation. Further, there was no unexplained cash credit in terms of Sec.68. The provisions would be attracted

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

prices in the open market. The department had verified the franchise status of M/s KLG Jewellers during the course of search itself. Therefore, M/s KLG Jewellers could not be said to be an independent retailer. Accordingly, the allegation of Ld. AO had no foundation. Further, there was no unexplained cash credit in terms of Sec.68. The provisions would be attracted

M/S SANJAY SINGAL HUF,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

transfer of shares held in M/s Maa Jagdambe Trade Link Limited, as under: Name of No. of Purchase of shares Sale of shares Long term Share shares Date of Cost Price Date of Sale Price capital gain Sale purchase Maa 18.75.000 12.03.2013 Rs.37,50.000 Various Rs. 18.68.86.042 Rs. 18.31,36.042 Jagdambe Dates Trade Link [3,75,000 Limited shares [Sept

SANJAY SINGAL,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CC-1, CHANDIGARH

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

transfer of shares held in M/s Maa Jagdambe Trade Link Limited, as under: Name of No. of Purchase of shares Sale of shares Long term Share shares Date of Cost Price Date of Sale Price capital gain Sale purchase Maa 18.75.000 12.03.2013 Rs.37,50.000 Various Rs. 18.68.86.042 Rs. 18.31,36.042 Jagdambe Dates Trade Link [3,75,000 Limited shares [Sept

SMT. AARTI SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-

transferred were not the part of the entities of Shri SCS. Therefore, there is no question of treating the sale of shares to other companies as unexplained cash credit under section 68 of the Act. Once the transaction of selling shares to the companies other than 21 companies belonging to Shri SCS has to be accepted as genuine long-term

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

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-

transferred were not the part of the entities of Shri SCS. Therefore, there is no question of treating the sale of shares to other companies as unexplained cash credit under section 68 of the Act. Once the transaction of selling shares to the companies other than 21 companies belonging to Shri SCS has to be accepted as genuine long-term

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

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-

transferred were not the part of the entities of Shri SCS. Therefore, there is no question of treating the sale of shares to other companies as unexplained cash credit under section 68 of the Act. Once the transaction of selling shares to the companies other than 21 companies belonging to Shri SCS has to be accepted as genuine long-term

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

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-

transferred were not the part of the entities of Shri SCS. Therefore, there is no question of treating the sale of shares to other companies as unexplained cash credit under section 68 of the Act. Once the transaction of selling shares to the companies other than 21 companies belonging to Shri SCS has to be accepted as genuine long-term

SMT. AARTI SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-

transferred were not the part of the entities of Shri SCS. Therefore, there is no question of treating the sale of shares to other companies as unexplained cash credit under section 68 of the Act. Once the transaction of selling shares to the companies other than 21 companies belonging to Shri SCS has to be accepted as genuine long-term

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

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-

transferred were not the part of the entities of Shri SCS. Therefore, there is no question of treating the sale of shares to other companies as unexplained cash credit under section 68 of the Act. Once the transaction of selling shares to the companies other than 21 companies belonging to Shri SCS has to be accepted as genuine long-term

SMT. AARTI SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-

transferred were not the part of the entities of Shri SCS. Therefore, there is no question of treating the sale of shares to other companies as unexplained cash credit under section 68 of the Act. Once the transaction of selling shares to the companies other than 21 companies belonging to Shri SCS has to be accepted as genuine long-term

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

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-

transferred were not the part of the entities of Shri SCS. Therefore, there is no question of treating the sale of shares to other companies as unexplained cash credit under section 68 of the Act. Once the transaction of selling shares to the companies other than 21 companies belonging to Shri SCS has to be accepted as genuine long-term

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

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-

transferred were not the part of the entities of Shri SCS. Therefore, there is no question of treating the sale of shares to other companies as unexplained cash credit under section 68 of the Act. Once the transaction of selling shares to the companies other than 21 companies belonging to Shri SCS has to be accepted as genuine long-term

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

unexplained credits, cash payment for land purchase and interest disallowance in the hands of various Group concerns. Thereafter, another search and seizure operation on 21/02/2014 was initiated by the Department at the business premises alongwith residential / business premises of the Directors and other related persons of BPSL. 6.3 The AO also observed that various new evidences in the form

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

unexplained credits, cash payment for land purchase and interest disallowance in the hands of various Group concerns. Thereafter, another search and seizure operation on 21/02/2014 was initiated by the Department at the business premises alongwith residential / business premises of the Directors and other related persons of BPSL. 6.3 The AO also observed that various new evidences in the form

SMT. AARTI SINGAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

unexplained credits, cash payment for land purchase and interest disallowance in the hands of various Group concerns. Thereafter, another search and seizure operation on 21/02/2014 was initiated by the Department at the business premises alongwith residential / business premises of the Directors and other related persons of BPSL. 6.3 The AO also observed that various new evidences in the form

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

unexplained credits, cash payment for land purchase and interest disallowance in the hands of various Group concerns. Thereafter, another search and seizure operation on 21/02/2014 was initiated by the Department at the business premises alongwith residential / business premises of the Directors and other related persons of BPSL. 6.3 The AO also observed that various new evidences in the form