Entries relating to advances received from Hardev Singh and his son Maninder Singh Sahi from Canada were recorded in books of account and assessee also explained that amount was received as an advance for making investment in property by said person, and assessee was engaged in the property business. Assessee also requested AO to summon concerned party under section 131 but AO did not accede to the request of assessee and made the addition, therefore, addition made by AO was not justified.
A perusal of the record shows that this allegation of the Ld. Pr. CIT is correct in so far as no query has been raised by the AO on these two issues and neither has the assessee made any submissions either before the AO or even before the Ld. PR. CIT on these two issues even when the said issues were duly mentioned in the show cause notice issued u/s 263 of the Act. Accordingly, we have no option but to uphold the impugned order u/s 263 of the Act on these two issues.
Kamla Retail Ltd. Vs ACIT (ITAT Chandigarh) It is no doubt true that it is incumbent upon the assessee to account for the expenses in respective financial year in which they are incurred or the liability towards such expenses has accrued which is in line with the mercantile system of accounting as well as concept […]
Citi Centre Developers Vs CPC (ITAT Chandigarh) Since the facts of the present cases are identical to the facts involved in Raja Ram Vs. ITO, Yamunanagar (ITAT, Chandigarh) therefore respectfully following the earlier orders as referred to herein above of the different Benches of the ITAT, the impugned additions made by the Assessing Officer and […]
Jagmohan Singh Vs DCIT (ITAT Chandigarh) In the instant case, it is not in dispute that employees’ contribution to ESI and PF collected by the assessee from its employees had been deposited well before the due date of filing of return of income u/s 139(1) of the Act. We find that the issue is squarely […]
Reference for special audit u/s 142(A) was invalid and the assessment orders so passed in the extended time were held to be barred by limitation.
Addition on account of investment made from undisclosed sources was deleted as as all transactions were made through banking channels and AO had made the addition in question on assumption and presumption basis.
ITO Vs Rachna Arora (ITAT Chandigarh) Solitary issue in the present appeal pertained to claim of exemption u/s 54 of the Act of Long Term Capital Gains earned by the assessee being invested in another property. The shares of three co-owners namely the assessee, her son in law and her daughter in the purchased property […]
Shri Sanjay Singal Vs DCIT (ITAT Chandigarh) Addition of Rs. 61.86 Crore in 9 Appeals on Account of Bogus Long Term Capital Gain U/S 10(38) Claimed Deleted on Facts of Alleged Penny Scrip of PIL (Praneta Industries Ltd) and Revenue Rule 29 Application Containing Fir Filed by ED Against Companies of Bhushan Group & Statement […]
Since the major write off claim evidently pertained to vaccines which assessee consistently claimed had been nearing expiry and thus had no realizable value and nothing had been pointed out regarding the insufficiency of evidences filed by assessee, therefore, the claim of assessee was fully justified for write off of vaccines since undoubtedly such vaccines were not capable of being used beyond expiry period and had no realizable value thereafter.
