Asstt. CIT v. Pratibha Industries Ltd.

Shreenathji Infrastructure P.Ltd., Pipariya vs. Assistant Commissioner of Income Tax, Itarsi

Bench: Shri Chandra Mohan Garg & Shri B.M. Biyani

…meters may act as guiding factors to decide whether a contractor may be considered as a deemed developer eligible for deduction under section 80-IA(4) of the Act. 13.8 Further, in case of Asstt. CIT v. Pratibha Industries Ltd. [2012] 28 taxmann.com 246/[2013] 141 ITD 151 (Mum.), the Hon'ble Mumbai Tribunal held that where the assessee had invested his own funds, it would be assumed that the assessee was acting as a developer and not as a contractor. Relevant extract of the above decision is reproduced as under : "83 ** ** ** There are letters exchanged, written by the assessee and various Government departments,…

Shreenathji Infrastructure P.Ltd., Pipariya vs. Assistant Commissioner of Income Tax, Itarsi

Bench: Shri Chandra Mohan Garg & Shri B.M. Biyani

…meters may act as guiding factors to decide whether a contractor may be considered as a deemed developer eligible for deduction under section 80-IA(4) of the Act. 13.8 Further, in case of Asstt. CIT v. Pratibha Industries Ltd. [2012] 28 taxmann.com 246/[2013] 141 ITD 151 (Mum.), the Hon'ble Mumbai Tribunal held that where the assessee had invested his own funds, it would be assumed that the assessee was acting as a developer and not as a contractor. Relevant extract of the above decision is reproduced as under : "83 ** ** ** There are letters exchanged, written by the assessee and various Government departments,…

Shreenathji Infrastructure P.Ltd., Pipariya vs. Deputy Commissioner of Income Tax, Itarsi

Bench: Shri Chandra Mohan Garg & Shri B.M. Biyani

…meters may act as guiding factors to decide whether a contractor may be considered as a deemed developer eligible for deduction under section 80-IA(4) of the Act. 13.8 Further, in case of Asstt. CIT v. Pratibha Industries Ltd. [2012] 28 taxmann.com 246/[2013] 141 ITD 151 (Mum.), the Hon'ble Mumbai Tribunal held that where the assessee had invested his own funds, it would be assumed that the assessee was acting as a developer and not as a contractor. Relevant extract of the above decision is reproduced as under : "83 ** ** ** There are letters exchanged, written by the assessee and various Government departments,…

Shreenathji Infrastructure P.Ltd., Pipariya vs. Assistant Commissioner of Income Tax, Itarsi

Bench: Shri Chandra Mohan Garg & Shri B.M. Biyani

…meters may act as guiding factors to decide whether a contractor may be considered as a deemed developer eligible for deduction under section 80-IA(4) of the Act. 13.8 Further, in case of Asstt. CIT v. Pratibha Industries Ltd. [2012] 28 taxmann.com 246/[2013] 141 ITD 151 (Mum.), the Hon'ble Mumbai Tribunal held that where the assessee had invested his own funds, it would be assumed that the assessee was acting as a developer and not as a contractor. Relevant extract of the above decision is reproduced as under : "83 ** ** ** There are letters exchanged, written by the assessee and various Government departments,…

Shreenathji Infrastructure P.Ltd., Pipariya vs. Assistant Commissioner of Income Tax, Itarsi

Bench: Shri Chandra Mohan Garg & Shri B.M. Biyani

…meters may act as guiding factors to decide whether a contractor may be considered as a deemed developer eligible for deduction under section 80-IA(4) of the Act. 13.8 Further, in case of Asstt. CIT v. Pratibha Industries Ltd. [2012] 28 taxmann.com 246/[2013] 141 ITD 151 (Mum.), the Hon'ble Mumbai Tribunal held that where the assessee had invested his own funds, it would be assumed that the assessee was acting as a developer and not as a contractor. Relevant extract of the above decision is reproduced as under : "83 ** ** ** There are letters exchanged, written by the assessee and various Government departments,…

Thed CIT, Central-1, Bhopal vs. M/S Dilip Buildcon Ltd, Bhopal

In the result, revenue’s appeal for A

Bench: Shri Rajpal Yadav Hon'Ble & Shri Manish Borad&

…eters may act as guiding factors to decide whether a contractor may be considered as a deemed developer eligible for deduction under section 80-IA(4) of the Act. 13.8 Further, in case of Asstt. CIT v. Pratibha Industries Ltd. [2012] 28 taxmann.com 246/[2013] 141 ITD 151 (Mum.), the Hon'ble Mumbai Tribunal held that where the assessee had invested his own funds, it would be assumed that the assessee was acting as a developer and not as a contractor. Relevant extract of the above decision is reproduced as under : "83 ** ** ** There are letters exchanged, written by the assessee and various Government departments,…

Shri Dilip Buildcon Ltd, Bhopal vs. DCIT Central -1, Bhopal

In the result, revenue’s appeal for A

Bench: Shri Rajpal Yadav Hon'Ble & Shri Manish Borad&

…eters may act as guiding factors to decide whether a contractor may be considered as a deemed developer eligible for deduction under section 80-IA(4) of the Act. 13.8 Further, in case of Asstt. CIT v. Pratibha Industries Ltd. [2012] 28 taxmann.com 246/[2013] 141 ITD 151 (Mum.), the Hon'ble Mumbai Tribunal held that where the assessee had invested his own funds, it would be assumed that the assessee was acting as a developer and not as a contractor. Relevant extract of the above decision is reproduced as under : "83 ** ** ** There are letters exchanged, written by the assessee and various Government departments,…

DCIT (Central)-1, Bhopal vs. Dilip Buildcon Ltd., Bhopal

In the result, revenue’s appeal for A

Bench: Shri Rajpal Yadav Hon'Ble & Shri Manish Borad&

…eters may act as guiding factors to decide whether a contractor may be considered as a deemed developer eligible for deduction under section 80-IA(4) of the Act. 13.8 Further, in case of Asstt. CIT v. Pratibha Industries Ltd. [2012] 28 taxmann.com 246/[2013] 141 ITD 151 (Mum.), the Hon'ble Mumbai Tribunal held that where the assessee had invested his own funds, it would be assumed that the assessee was acting as a developer and not as a contractor. Relevant extract of the above decision is reproduced as under : "83 ** ** ** There are letters exchanged, written by the assessee and various Government departments,…

DCIT (Central)-1, Bhopal vs. Dilip Buildcon Ltd., Bhopal

In the result, revenue’s appeal for A

Bench: Shri Rajpal Yadav Hon'Ble & Shri Manish Borad&

…eters may act as guiding factors to decide whether a contractor may be considered as a deemed developer eligible for deduction under section 80-IA(4) of the Act. 13.8 Further, in case of Asstt. CIT v. Pratibha Industries Ltd. [2012] 28 taxmann.com 246/[2013] 141 ITD 151 (Mum.), the Hon'ble Mumbai Tribunal held that where the assessee had invested his own funds, it would be assumed that the assessee was acting as a developer and not as a contractor. Relevant extract of the above decision is reproduced as under : "83 ** ** ** There are letters exchanged, written by the assessee and various Government departments,…

Dilip Buildcon Ltd., Bhopal vs. DCIT (Central)-1, Bhopal

In the result, revenue’s appeal for A

Bench: Shri Rajpal Yadav Hon'Ble & Shri Manish Borad&

…eters may act as guiding factors to decide whether a contractor may be considered as a deemed developer eligible for deduction under section 80-IA(4) of the Act. 13.8 Further, in case of Asstt. CIT v. Pratibha Industries Ltd. [2012] 28 taxmann.com 246/[2013] 141 ITD 151 (Mum.), the Hon'ble Mumbai Tribunal held that where the assessee had invested his own funds, it would be assumed that the assessee was acting as a developer and not as a contractor. Relevant extract of the above decision is reproduced as under : "83 ** ** ** There are letters exchanged, written by the assessee and various Government departments,…

Dilip Buildcon Ltd., Bhopal vs. DCIT (Central)-1, Bhopal

In the result, revenue’s appeal for A

Bench: Shri Rajpal Yadav Hon'Ble & Shri Manish Borad&

…eters may act as guiding factors to decide whether a contractor may be considered as a deemed developer eligible for deduction under section 80-IA(4) of the Act. 13.8 Further, in case of Asstt. CIT v. Pratibha Industries Ltd. [2012] 28 taxmann.com 246/[2013] 141 ITD 151 (Mum.), the Hon'ble Mumbai Tribunal held that where the assessee had invested his own funds, it would be assumed that the assessee was acting as a developer and not as a contractor. Relevant extract of the above decision is reproduced as under : "83 ** ** ** There are letters exchanged, written by the assessee and various Government departments,…

Deputy Commissioner of Income Tax (Central)-1, Bhopal vs. Dilip Buildcon Limited, Bhopal

In the result, revenue’s appeal for A

Bench: Shri Rajpal Yadav Hon'Ble & Shri Manish Borad&

…eters may act as guiding factors to decide whether a contractor may be considered as a deemed developer eligible for deduction under section 80-IA(4) of the Act. 13.8 Further, in case of Asstt. CIT v. Pratibha Industries Ltd. [2012] 28 taxmann.com 246/[2013] 141 ITD 151 (Mum.), the Hon'ble Mumbai Tribunal held that where the assessee had invested his own funds, it would be assumed that the assessee was acting as a developer and not as a contractor. Relevant extract of the above decision is reproduced as under : "83 ** ** ** There are letters exchanged, written by the assessee and various Government departments,…

Dilip Buildcon Limited, Bhopal vs. Deputy Commissioner of Income Tax (Central)-1, Bhopal

In the result, revenue’s appeal for A

Bench: Shri Rajpal Yadav Hon'Ble & Shri Manish Borad&

…eters may act as guiding factors to decide whether a contractor may be considered as a deemed developer eligible for deduction under section 80-IA(4) of the Act. 13.8 Further, in case of Asstt. CIT v. Pratibha Industries Ltd. [2012] 28 taxmann.com 246/[2013] 141 ITD 151 (Mum.), the Hon'ble Mumbai Tribunal held that where the assessee had invested his own funds, it would be assumed that the assessee was acting as a developer and not as a contractor. Relevant extract of the above decision is reproduced as under : "83 ** ** ** There are letters exchanged, written by the assessee and various Government departments,…

Shree Balaji Engicons Pvt. Ltd, Jharsuguda vs. Principal CIT, Sambalpur

In the result, appeal of the assessee in ITA No

Bench: Shri C.M. Garg, Jm & Shri Manish Borad, Am आयकर अपीऱ सं./Ita Nos.193/Ctk/2019 (नििाारण वषा / Assessment Year :2014-2015) M/S Rawats-Balaji(Jv), Vs Pr.Cit, Sambalpur At/Po-Belpahar(Rs), Dist : Jharsuguda Pan No. : Aabar 9061 J Tan No. : Bbnr01647 C & आयकर अपीऱ सं./Ita Nos.194/Ctk/2019 (नििाारण वषा / Assessment Year :2014-2015) M/S Sbepl-Gril(Jv), Vs Pr.Cit, Sambalpur At/Po-Belpahar(Rs), Dist : Jharsuguda Pan No. : Aafas 2639 R Tan No. : Bbns04348 B & आयकर अपीऱ सं./Ita Nos.195/Ctk/2019 (नििाारण वषा / Assessment Year :2014-2015) Shree Balaji Engicons Pvt Ltd Vs Pr.Cit, Sambalpur At/Po-Belpahar(Rs), Dist : Jharsuguda Pan No. : Aagcs 4292 P Tan No. : Bbns00091 A (अऩीलाथी /Appellant) (प्रत्यथी / Respondent) .. ननधाारिती की ओर से /Assessee By : Shri Satyanarayan Agarwal, Ar िाजस्व की ओर से /Revenue By : Shri M.K.Gautam, Citdr सुनवाई की तािीख / Date Of Hearing : 26/10/2021 घोषणा की तािीख/Date Of Pronouncement : 23/12/2021 आदेश / O R D E R Per Bench: These Three Appeals Have Been Filed By Three Different Assessees Against The Order Passed By The Pr.Cit, Sambalpur, U/S.263 Of The Act, All Dated 30.03.2019 For The Assessment Year 2014-2015. 2

…आयकर अपीऱीय अधिकरण, कटक न्यायपीठ, कटक IN THE INCOME TAX APPELLATE TRIBUNAL CUTTACK BENCH, CUTTACK BEFORE SHRI C.M. GARG, JM & SHRI MANISH BORAD, AM आयकर अपीऱ सं./ITA Nos.193/CTK/2019 (नििाारण वषा / Assessment Year :2014-2015) M/s Rawats-Balaji(JV), Vs Pr.CIT, Sambalpur At/Po-Belpahar(RS), Dist : Jharsuguda PAN No. : AABAR 9061 J TAN No. : BBNR01647 C AND आयकर अपीऱ सं./ITA Nos.194/CTK/2019 (नििाारण वषा / Assessment Year :2014-2015) M/s SBEPL-GRIL(JV), Vs Pr.CIT, Sambalpur At/Po-Belpahar(RS), Dist : Jharsuguda PAN No. : AAFAS 2639 R TAN No. : BBNS04348 B AND आयकर अपीऱ सं./ITA Nos.195/CTK/2019 (नििाारण वषा / Asse…