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Sewa Singh and Co. Vs. Income Tax Officer

Court : Income Tax Appellate Tribunal ITAT Amritsar

1. the appellant has filed appeal against the order passed by the cit(a) vide a. no. cit(a)/it/bti/104/85-86, dt. 6th august, 1990, and taken following grounds in the appeal: "(1) the learned cit(a) has erred in law and facts in upholding that there is interlacing and inter-locking of funds between the two concerns. finding is without proper appreciation of true nature of transactions. 2. the learned cit(a) has erred in law and facts in upholding that payment to agriculturists belonging to trust have been made by the assessee-firm. finding is incorrect. 3. the learned cit(a) has erred in law and facts in holding that cases decided by tribunal, amritsar bench, amritsar, quoted and referred by assessee during hearing did not have the similarities with the facts of assessee's case. 4. the learned cit(a) has erred in law and facts by not taking into consideration the factum of non-compliance of directions under s. 144a." 2. the ao has observed that part of arhat received by the appellant was credited in the books of account of gulab singh & co., gulab singh & co. is a trust floated by joginder singh s/o gobind singh of ludhiana on 10th august, 1982 which has been settled with corpus of rs. 5000 and pritam singh was appointed trustee, for the benefit of relatives of the partners of the firm sewa singh & co. the ao recorded statement of pritam singh on 9th december, 1985. pritam singh is having 25 per cent share with sewa singh & co. as well as he is also trustee of the alleged .....

income Tax Officer Vs. Dr. A.K. Sharma

Court : Income Tax Appellate Tribunal ITAT Amritsar

1. the following is the effective ground agitated in this appeal of the revenue : "on the facts and in the circumstances of the case, the learned cit (a) has erred in deleting the addition of rs. 2,36,838 made by the ao on account of alleged foreign gifts when there was no occasion for such huge gifts and the case is fully covered by the decision of the hon'ble punjab & haryana high court in the case of lal chand kalra vs. cit".2. the facts giving rise to this appeal are that the assessee is a doctor by profession and deriving income from that profession. during the assessment proceedings, it was noted by the ao (hereinafter referred as the ao) that the assessee had received two foreign gifts of rs. 19,661 and rs. 1,50,200 totalling to rs. 1,69,861 and received another amount of rs. 23,000 from smt. krishna parmar by way of transfer from nre a/c no. 103 with indian bank, phagwara, thereby total foreign gifts were rs. 1,92,861. the assessee was examined by the ao to verify the genuineness of the foreign gifts in which he stated that rs. 1,50,200 was sent to him by his religious brother piara lal residing in canada for the last 25 years. the other amount of rs. 19,661 was given to him from smt. veena birla, who was classfellow of his wife and sister-in-law of her sister. rs. 23,000 were received from smt. krishna parmar, a family friend. the ao further noted that assessee's wife smt.mukta sharma had also received foreign remittances of rs. 14,044 from smt. veena birla and rs. .....

Jai Sharda Rice Mills Vs. Income-tax Officer

Court : Income Tax Appellate Tribunal ITAT Amritsar

Reported in : (1991)36ITD254(Asr.)

1. the assessee, a registered firm, is running a rice mill at mahatpur.the income returned disclosed an income of rs. 31,983. the assessee has maintained stock registers, which showed purchase of paddy pr-106 and ir-8. stock registers show separately the quantities purchased under both these varieties. similarly, the rice produced from both the varieties are disclosed separately. the assessee had an overdraft facility with the punjab national bank, jalandhar. they were allowed a facility of rs. 6 lakhs against the hypothecation of stock. the ito compared the stock as declared by the assessee for hypothecation with the figures given in the stock register. he found that there were variations. the stock declared under hypothecation to the bank, on many dates, were much more than what was found in the stock register. the peak difference in value was rs. 15,91,527. after consideration of the assessee's objections, the ito held that this amount represented the assessee's income not disclosed in the books and added the same.2. at the end of the year, the stock with the assessee did not reflect this excess noticed by the ito. he assumed that the excess must have been sold off. since the assessee had disclosed a profit rate of 10.3%, he assumed that, on the sale of the stock outside the books, the assessee must have derived similar rate of profit. he added rs. 1,07,986.3. the assessee appealed. in the ground of appeal, it was submitted that there was no valid material with the ito to .....

Mrs. Purnima Beri Vs. Deputy Commissioner of Income Tax

Court : Income Tax Appellate Tribunal ITAT Amritsar

Reported in : (2002)82ITD137(Asr.)

..... this fact alone goes to prove that both these witnesses were fully alive about the transaction going on between the parties as they were said to be the man of confidence and even documents were with them. ..... shri yash paul mittal must be the man of confidence of both the parties that is why these valuable documents were given to him by both the parties and further he must be taken as a privy to the transaction and developments thereafter. ..... since you are standing as a man of truth between the parties, please state how much cash as per your knowledge has been passed till today. ..... since you are standing as a man of trust between the parties, please state how much cash as per your knowledge has been passed till today. ..... mittal must be a man of confidence of both the parties and that was why the valuable documents were given to him by the parties and he must, therefore, be taken as a party to the transaction and developments thereafter. .....

Purnima Beri Vs. Dy. Cit

Court : Income Tax Appellate Tribunal ITAT Amritsar

Reported in : (2002)76TTJ(Asr.)467

..... this fact alone goes to prove that both these witnesses were fully alive about the transaction going on between the parties as they were said to be the man of confidence and even documents were with them. ..... shri yash paul mittal must be the man of confidence of both the parties that is why these valuable documents were given to him by both the parties and further he must be taken as a privy to the transaction and developments thereafter. ..... since you are standing as a man of truth between the parties, please state how much cash as per your knowledge has been passed till today. ..... since you are standing as a man of trust between the parties, please state how much cash as per your knowledge has been passed till today. ..... mittal must be a man of confidence of both the parties and that was why the valuable documents were given to him by the parties and he must, therefore, be taken as a party to the transaction and developments thereafter. .....

Anil Duggal Vs. Asstt. Cit

Court : Income Tax Appellate Tribunal ITAT Amritsar

Reported in : (2004)91TTJ(Asr.)1140

the appellant has filed appeals against the or-der passed by the commissioner (appeals) vide order dt. 26-6-1998, and taken following grounds in appeals : "1 that the learned commissioner (appeals) erred in law and on facts in dismissing the appeal in liminie for assessment year 1985-86 on the plea that the appeal was invalid although sh. y.p. duggal had signed the appeal as power of attorney holder of his son, sh, anil duggal, the, appellant (who was in america at the time of filing of appeal and who, had given general power of attorney to sh. yash pal duggal, his father, before leaving india) filed before the learned commissioner (appeals) against the additions/disallowances made in the assessment under section 144 of income tax act, dated 27-3-1997, where; during hearings, detailed explanations covering all aspects of the case were duly filed before the learned commissioner (appeals).2. the learned commissioner (appeals) erred in law and on facts in deciding the appeal in a grossly improper, illegal and baseless manner against all cannons of equity, fair play and justice without, appreciating the facts and circumstances of the case.3. the learned commissioner (appeals) erred in law and facts in not accepting that general power of attorney,' which was duly registered on 18-3-1997, in the government sub registrar's office, empowered sh. y.p.duggal, his father, to deal with government departments like railways and post office was simply illustrating the government .....

The Income-tax Officer Vs. Sheetal Khurana Food (P) Ltd.

Court : Income Tax Appellate Tribunal ITAT Amritsar

..... its expenditure and loss, the assessee had no choice but to let out the upper floor of the building on lease, for a limited period only; that the actions of the assessee certainly part took of those of a business man exploiting his property/asset, as explained and to reduce the losses due to non completion of the hotel/restaurant project; that it is the motive, intention and actual activity of the assessee in dealing with the property, ..... only the upper floor, and not the whole property, for a short limited period and in further agreeing to the lease condition of removing the entire building on the expiry of the lease period, were actions of a business man exploiting his property/assets, cutting his loss/expenses; that the tax treatment for the relevant year, i.e ..... only, in order to reduce its expenditure and losses; that the assessee had agreed to the restrictive lease condition of removing its entire building on the expiry of the lease period, which was indicative of the intention of a business-man to exploit its property/asset .....

income Tax Officer Vs. Tarlochan Singh

Court : Income Tax Appellate Tribunal ITAT Amritsar

Reported in : (2003)81TTJ(Asr.)1021

1. these two appeals by the assesses and the department are directed against the order of the cit(a), jalandhar dt. 1st march, 1996, relating to the asst. yr. : 1993-94.2. in ita no.415(asr)/1996, the assesses has taken the following grounds: "1. that the order of the authorities below is against law and facts of the case. 2. that the c1t(a) has erred in concurring with the dy. cit in mentioning that the appellant accepted deposit of rs. 70,000 i.e. rs. 50,000 on 27th jan., 1993, and rs. 20,000 on 20th feb., 1993 and thereby has violated provision of section 269ss. 3. that the cit(a) has erred in concurring with the dy. cit in not appreciating the contention of the appellant that the ito was not justified to record statements of the appellant and his wife under section 131 and thereby any adverse inference drawn by him was not justified. 4. that the cit(a) has erred in concurring with the dy, cit in drawing adverse inference from the statements of the appellant and his wife under section 131. 5. that the cit(a) has erred in concurring with the dy. cit in not accepting the contention of the appellant that the bank a/c no. 2121 with bank of baroda in fact belonged to the appellant and the cit(a) further erred in concurring with the dy. cit in not appreciating that the appellant had disclosed the same in his assets and the question of loan from the said a/c did not arise. 6. that the cit(a) has erred in concurring with the dy. cit in not accepting the contention of the assesses .....

The Asstt. Commr. of Income-tax Vs. Sachdeva and Sons

Court : Income Tax Appellate Tribunal ITAT Amritsar

Reported in : (2005)97TTJ(Asr.)1101

these are two appeals - one filed by the revenue against the order of cit(a), ludhiana, dated 10.03.2003 for the assessment year 1988-89 and another filed by the assessee against order dated 20^th march, 2003 cit(a), jammu with hqrs. at amritsar for the assessment year 1989-90.since the issues in these appeals are common, these were heard together and are being disposed of by this consolidated order for the sake of convenience.2. in the appeal filed by the revenue for the assessment year 1988-89 the following two effective grounds of appeal have been taken : " 1 that the ld. cit(a)-1, ludhiana has erred in quashing the re-assessment proceedings initiated vide notice under section 148 dated 24.3-1999 on the ground that earlier re-assessment proceedings were still pending as a result of order of hon'ble itat, amritsar dated 20.3.1998 which was restored to the file of the a.o. on a limited issue regarding admissibility of deductions under section 32ab & 80hhc. 2. that the ld. cit(a)-1, ludhiana has also erred in observing that the basis of re-assessment proceedings did not exist after the fera proceedings were quashed by the special director (enforcement) when there was independent evidence indicating under-invoicing of export by the assessee apart from confessional statement of partner shri ashok sachdeva when on the similar facts arid circumstances the ld. cit(a), amritsar has upheld the order of the a.o. in the case of the assessee for the assessment year 1989-90 vide his .....

Asstt. Commr. of Income Tax Vs. Sachdeva and Sons

Court : Income Tax Appellate Tribunal ITAT Amritsar

Reported in : (2006)97ITD425(Asr.)

these are two appeals one filed by the revenue against the order of cit(a), ludhiana, dated 10-3-2003 for the assessment year 1988-89 and another filed by the assessee against order dated 20-3-2003 of cit(a), jammu, with headquarters at amritsar for the assessment year 1989-90.since the issues in these appeals are common, these were heard together and are being disposed of by this consolidated order for the sake of convenience.in the appeal filed by the revenue for the assessment year 1988-89, the following two effective grounds of appeal have been taken : "1. that the learned cit(a)-i, ludhiana, has erred in quashing the reassessment proceedings initiated vide notice under section 148, dated 24-3-1999 on the ground that earlier reassessment proceedings were still pending as a result of order of hon'ble tribunal amritsar, dt.20-3-1998 which was restored to the file of the assessing officer on a limited issue regarding admissibility of deductions under sections 32ab and 80hhc.2. that the learned cit(a)-1, ludhiana has also erred in observing that the basis of reassessment proceedings did not exist after the fera proceedings were quashed by the special director (enforcement) when there was independent evidence indicating underinvoicing of export by the assessee apart from confessional statement of partner shri ashok sachdeva when on the similar facts and circumstances, the learned cit(a), amritsar, has upheld the order of the assessing officer in the case of the assessee for .....