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

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

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

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

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

In the result appeal of the assessee is dismissed

unexplained cash credit may please be dropped.\n2.27 That the aforesaid request of the assesseewith regard to copies of\nsworn depositions of CMD and other Directors of “NCL Research and\nFinancial Services Ltd.” Were provided to the assesse (Para 4.3 of Ld. AO\norder).\n2.28 That the assessee has sold the shares on different dates i.e; on\n20/05/2013, 27/05/2013, 28/05/2013

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)

cash credits. Further any investment made out of explained credits from regular bank account cannot be added under section 69 of the Income Tax Act, 1961. Therefore the learned Assessing Officer without application of his own mind and in haste of adherence to the instructions of third party by throwing all laws of the land to the winds

INCOME TAX OFFICER, WARD-1(3), LUDHIANA, LUDHIANA vs. SHREE BALAJI PROCESSORS, LUDHIANA

In the result, appeal of the Revenue is dismissed whereas, the 29

Bench: Shri A.D. Jain & Dr Krinwant Sahayआयकर अपील सं./ Ita No. 499/Chd/2023 "नधा"रण वष" / Assessment Year : 2017-18 The Ito, Vs. Shree Balaji Processors, बनाम Ward-1(3), Tajpur Road, Ludhiana Opp. Central Jail, Ludhiana 141010 "थायी लेखा सं./Pan No: Actfs8428B अपीलाथ"/ Appellant ""यथ"/ Repsondent & C.O. No. 09/Chd/2024 ( In आयकर अपील सं./ Ita No. 499/Chd/2023) "नधा"रण वष" / Assessment Year : 2017-18 Shree Balaji Processors, Vs. The Ito, बनाम Tajpur Road, Ward-1(3), Opp. Central Jail, Ludhiana Ludhiana 141010 "थायी लेखा सं./Pan No: Actfs8428B अपीलाथ"/ Appellant ""यथ"/ Repsondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : Shri Sudhir Sehgal, Advocate राज"व क" ओर से/ Revenue By : Smt. Kusum Bansal, Cit Dr सुनवाई क" तार"ख/Date Of Hearing : 26.06.2024 उदघोषणा क" तार"ख/Date Of Pronouncement : 20.08.2024

unexplained cash credit u/s 68 of the Income Tax Act. This addition was confirmed by the Ld. CIT(A). The matter was carried by the assessee before the Hon'ble ITAT and the Hon'ble ITAT deleted the addition vii). Further, it is submitted that whatever cash deposits were made by the assessee during the year under consideration and during

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

cash amount seized belonged to him\nand it represented undisclosed income not recorded in the books of accounts. The\nassessee did not immediately retract from the above admission but only during the\n24\nassessment proceedings at a belated stage. In his retraction, the assessee stated that the\nsurrender was made under a mistaken belief and without looking into books

DCIT CC-1, LUDHIANA vs. M/S OSWAL FASHION (P) LTD., G.T.ROAD (WEST), JALANDHAR BYE PASS, LUDHIANA

The appeal stand dismissed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No.1020/Chandi/2019 (िनधा"रणवष" / Assessment Year: 2011-12 Dcit M/S Oswal Fashion (P) Limited बनाम/ Central Circle -1 G.T. Road (West) Ludhiana. Jalandhar Bye Pass, Vs. Ludhiana-141001. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaaco-2183-R (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरAppellant By : Shri Arvind Kumar (Cit) – Ld. Dr ""थ"कीओरसे/Respondent By : Shri Gaurav Sharma (Ca)– Ld. Ar सुनवाईकीतारीख/Date Of Hearing : 25-08-2025 घोषणाकीतारीख /Date Of Pronouncement : 02-09-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Revenue For Assessment Year (Ay) 2011-12 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals)-5, Ludhiana [Cit(A)] Dated 05-04-2019 In The Matter Of An Assessment Framed By Ld. Assessing Officer (Ao) U/S 143(3) / 153A Of The Act On 30-03-2015. The Sole Issue That Arises For Our Consideration Is Addition Of Rs.5 Crores As Made By Ld. Ao In The Assessment Order.

unexplained cash credit u/s 68. 3. The Ld. CIT(A) rendered factual findings that the assessee had duly declared the purchase and sale consideration in the books of accounts. The assessee also computed Long Term Capital Loss on shares which was duly reflected in the return of income which was filed much before the date of search on assessee

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

cash amount seized belonged to him\nand it represented undisclosed income not recorded in the books of accounts. The\nassessee did not immediately retract from the above admission but only during the\nassessment proceedings at a belated stage. In his retraction, the assessee stated that the\nsurrender was made under a mistaken belief and without looking into books of account

M/S SEL MANUFACTURING CO. LTD.,LUDHIANA vs. DCIT, CC-3, LUDHIANA

In the result, appeal is allowed

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

transfer pricing, TDS matter, excise assessment, VAT assessment and also with regard to notices issued by the relevant Government Authority for relevant assessment years under various provisions of the Applicable Law including Income Tax Act or indirect tax laws, the relevant Government A.Y. 2011-12 14 Authorities make any further assessment with respect to resolution of losses or unabsorbed depreciation

SMT. TEENA GARG,CHANDIGARH vs. PCIT, PANCHKULA

In the result, appeal of the assessee is allowed

Transfer Pricing\nOfficer, as the case may be, shall be deemed to be erroneous in so\nfar as it is prejudicial to the interests of the revenue, if, in the opinion\nof the Principal Chief Commissioner or Chief Commissioner or\nPrincipal Commissioner or Commissioner,-\n\n(a) the order is passed without making inquiries or verification which\nshould have been

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

In the result, the ground no

Bench: SHRI. SANJAY GARG (Judicial Member), SHRI. VIKRAM SINGH YADAV (Accountant Member)

unexplained cash credit under Section 68 of the Act. 4. Being aggrieved, the assessee carried the matter in appeal before the Ld. CIT(A). 4.1 During the course of appellate proceedings, it was submitted that the assessee has made investment in shares of M/s Maple Goods (P) Ltd. in A.Y. 2011-12 and the shares were purchased through Shri

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)

unexplained cash credit under Section 68 of the Act. 5. Being aggrieved, the assessee carried the matter in appeal before the Ld. CIT(A). 5.1 During the course of appellate proceedings, it was submitted that the assessee has made investment in shares of M/s Maple Goods (P) Ltd. in A.Y. 2011-12 and the shares were purchased through Shri

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)

unexplained cash credit under Section 68 of the Act. 5. Being aggrieved, the assessee carried the matter in appeal before the Ld. CIT(A). 5.1 During the course of appellate proceedings, it was submitted that the assessee has made investment in shares of M/s Maple Goods (P) Ltd. in A.Y. 2011-12 and the shares were purchased through Shri

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)

unexplained cash credit under Section 68 of the Act. 5. Being aggrieved, the assessee carried the matter in appeal before the Ld. CIT(A). 5.1 During the course of appellate proceedings, it was submitted that the assessee has made investment in shares of M/s Maple Goods (P) Ltd. in A.Y. 2011-12 and the shares were purchased through Shri

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)

unexplained cash credit under Section 68 of the Act. 5. Being aggrieved, the assessee carried the matter in appeal before the Ld. CIT(A). 5.1 During the course of appellate proceedings, it was submitted that the assessee has made investment in shares of M/s Maple Goods (P) Ltd. in A.Y. 2011-12 and the shares were purchased through Shri