CIT v. Hi Tech Arai Ltd.

321 ITR 477High Court2010#1855 most cited

What is CIT v. Hi Tech Arai Ltd. authority for?

For the purpose of claiming deduction under Section 10B, the term "manufacture" includes "process" as per the Explanation to the section, allowing activities like processing gherkins into pickles to qualify.

62

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2015 to 2024.

Also referred to as

CIT v. Hi-Tech Arai Ltd. · Section 10B · export oriented unit · EOU deduction · manufacture includes process · manufacturing process · gherkin pickles · deduction for processing · 321 ITR 477 · Section 10B Explanation · Chennai High Court

Sections most often in play

Section 10BSection 144Section 145Section 147Section 80HHCSection 148Section 2(29BA)Section 10B(9A)

Issues it is cited on

section 2(29ba)section 153a(b)section 263(2)export oriented unitconvertible foreign exchangesection 142(2c)abatement of assessmentspeculation losssection 80jsection 114section 153a(1)(a)section 144ba

Judgments citing CIT v. Hi Tech Arai Ltd.

ACIT CIR 4(2), MUMBAI vs. M .M. POONJIAJI SPICES LTD, MUMBAI

ITA 755/MUM/2012[B]Status: DisposedITAT Mumbai15 Apr 2024

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

Section 10BSection 143Section 144Section 145Section 147Section 9

…nto consideration the Explanation to section 10B where the term "manufacture" included the "process". In the circumstances, we are of the view that in view of the decision of the Hon'ble jurisdictional High Court in the case of CIT v. Hi-Tech Arai Ltd. [2010] 321 ITR 477 (Mad.) we must take a different view and we do so. In the circumstances, we are of the view that the assessee is entitled to the deduction under section 10B of the Act as the assessee is manufacturing gherkin pickles from gherkin for the purpose of deduction u/s 10B. In the circumstances, the appeals of the assessee are allowed." 32. The process…

.DCIT., CIR.-4(2),MUMBAI vs. M.M. POONJIAJI SPICES LTD, MUMBAI

ITA 3409/MUM/2011[2007-08]Status: DisposedITAT Mumbai15 Apr 2024AY 2007-08

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

Section 10BSection 143Section 144Section 145Section 147Section 9

…nto consideration the Explanation to section 10B where the term "manufacture" included the "process". In the circumstances, we are of the view that in view of the decision of the Hon'ble jurisdictional High Court in the case of CIT v. Hi-Tech Arai Ltd. [2010] 321 ITR 477 (Mad.) we must take a different view and we do so. In the circumstances, we are of the view that the assessee is entitled to the deduction under section 10B of the Act as the assessee is manufacturing gherkin pickles from gherkin for the purpose of deduction u/s 10B. In the circumstances, the appeals of the assessee are allowed." 32. The process…

INCOME TAX OFFICER 4(2)(4), MUMBAI vs. M/S. M.M. POONJIAJI SPICES LTD., MUMBAI

ITA 6523/MUM/2008[2005-2006]Status: DisposedITAT Mumbai15 Apr 2024AY 2005-2006

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

Section 10BSection 143Section 144Section 145Section 147Section 9

…nto consideration the Explanation to section 10B where the term "manufacture" included the "process". In the circumstances, we are of the view that in view of the decision of the Hon'ble jurisdictional High Court in the case of CIT v. Hi-Tech Arai Ltd. [2010] 321 ITR 477 (Mad.) we must take a different view and we do so. In the circumstances, we are of the view that the assessee is entitled to the deduction under section 10B of the Act as the assessee is manufacturing gherkin pickles from gherkin for the purpose of deduction u/s 10B. In the circumstances, the appeals of the assessee are allowed." 32. The process…

ITO - 4(2)(4), MUMBAI vs. M/S. M.M. POONJIAJI SPICES LTD., MUMBAI

ITA 4988/MUM/2008[2004-2005]Status: DisposedITAT Mumbai15 Apr 2024AY 2004-2005

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

Section 10BSection 143Section 144Section 145Section 147Section 9

…nto consideration the Explanation to section 10B where the term "manufacture" included the "process". In the circumstances, we are of the view that in view of the decision of the Hon'ble jurisdictional High Court in the case of CIT v. Hi-Tech Arai Ltd. [2010] 321 ITR 477 (Mad.) we must take a different view and we do so. In the circumstances, we are of the view that the assessee is entitled to the deduction under section 10B of the Act as the assessee is manufacturing gherkin pickles from gherkin for the purpose of deduction u/s 10B. In the circumstances, the appeals of the assessee are allowed." 32. The process…

ITO - 4(2)(4), MUMBAI vs. M/S. M.M. POONJIAJI SPICES LTD., MUMBAI

ITA 4987/MUM/2008[2002-2003]Status: DisposedITAT Mumbai15 Apr 2024AY 2002-2003

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

Section 10BSection 143Section 144Section 145Section 147Section 9

…nto consideration the Explanation to section 10B where the term "manufacture" included the "process". In the circumstances, we are of the view that in view of the decision of the Hon'ble jurisdictional High Court in the case of CIT v. Hi-Tech Arai Ltd. [2010] 321 ITR 477 (Mad.) we must take a different view and we do so. In the circumstances, we are of the view that the assessee is entitled to the deduction under section 10B of the Act as the assessee is manufacturing gherkin pickles from gherkin for the purpose of deduction u/s 10B. In the circumstances, the appeals of the assessee are allowed." 32. The process…

I.T.O-4(2)(4), MUMBAI vs. M/S M.M.POONJIAJI SPICES LTD, MUMBAI

ITA 2943/MUM/2008[2001-2002]Status: DisposedITAT Mumbai15 Apr 2024AY 2001-2002

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

Section 10BSection 143Section 144Section 145Section 147Section 9

…nto consideration the Explanation to section 10B where the term "manufacture" included the "process". In the circumstances, we are of the view that in view of the decision of the Hon'ble jurisdictional High Court in the case of CIT v. Hi-Tech Arai Ltd. [2010] 321 ITR 477 (Mad.) we must take a different view and we do so. In the circumstances, we are of the view that the assessee is entitled to the deduction under section 10B of the Act as the assessee is manufacturing gherkin pickles from gherkin for the purpose of deduction u/s 10B. In the circumstances, the appeals of the assessee are allowed." 32. The process…

ITO - 4(2)(2), MUMBAI vs. M/S. M.M. POONJIAJI SPICES LTD., MUMBAI

ITA 6537/MUM/2006[2003-2004]Status: DisposedITAT Mumbai15 Apr 2024AY 2003-2004

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

Section 10BSection 143Section 144Section 145Section 147Section 9

…nto consideration the Explanation to section 10B where the term "manufacture" included the "process". In the circumstances, we are of the view that in view of the decision of the Hon'ble jurisdictional High Court in the case of CIT v. Hi-Tech Arai Ltd. [2010] 321 ITR 477 (Mad.) we must take a different view and we do so. In the circumstances, we are of the view that the assessee is entitled to the deduction under section 10B of the Act as the assessee is manufacturing gherkin pickles from gherkin for the purpose of deduction u/s 10B. In the circumstances, the appeals of the assessee are allowed." 32. The process…

BIBHUDUTTA PANDA,BHUBANESWAR vs. ASST.CIT, CORPORATE CIRCLE 1(2), BHUBANESWAR

In the result, all appeals of the assessee stand allowed

ITA 81/CTK/2022[2012-13]Status: DisposedITAT Cuttack01 Feb 2023AY 2012-13

Bench: Shri George Mathan & Shri Arun Khodpiaआयकर अऩीऱ सं/Ita Nos.76 To 81/Ctk/2022 (ननधाारण वषा / Assessment Years :2007-2008 To 2012-2013) Bibhudutta Panda, Vs Acit, Corporate Circle-1(2), Plot No.73 & 74, Jayadev Vihar, Bhubaneswar Bhubaneswar-751013 Pan No. :Adapp 6398 R (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

For Appellant: Shri S.K.Agrawalla/S.K.Hota, ArsFor Respondent: Shri M.K.Gautam, CIT-DR
Section 142(1)Section 153ASection 153D

…ase of Serajuddin & Co. (supra) has gone into the quality of the satisfaction recorded by the approving authority. We are not in agreement with the said findings and in view of the decision of Hon’ble Madras High Court in the case of CIT Vs. Hi Tech Arai Ltd, 321 ITR 477 (Mad), we take a different stand. As mentioned earlier para 9 of the official manual procedure is a guideline for the assessing authority. It is also admitted fact that said guideline is in relation to provisions of section 158BG and does not have any impact in relation to provision of section 153D of the Act, though, admittedly, both 153D and 15…

BIBHUDUTTA PANDA,BHUBANESWAR vs. ASST.CIT CORPORATE CIRCLE-1(2), BHUBANESWAR

In the result, all appeals of the assessee stand allowed

ITA 80/CTK/2022[2011-12]Status: DisposedITAT Cuttack01 Feb 2023AY 2011-12

Bench: Shri George Mathan & Shri Arun Khodpiaआयकर अऩीऱ सं/Ita Nos.76 To 81/Ctk/2022 (ननधाारण वषा / Assessment Years :2007-2008 To 2012-2013) Bibhudutta Panda, Vs Acit, Corporate Circle-1(2), Plot No.73 & 74, Jayadev Vihar, Bhubaneswar Bhubaneswar-751013 Pan No. :Adapp 6398 R (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

For Appellant: Shri S.K.Agrawalla/S.K.Hota, ArsFor Respondent: Shri M.K.Gautam, CIT-DR
Section 142(1)Section 153ASection 153D

…ase of Serajuddin & Co. (supra) has gone into the quality of the satisfaction recorded by the approving authority. We are not in agreement with the said findings and in view of the decision of Hon’ble Madras High Court in the case of CIT Vs. Hi Tech Arai Ltd, 321 ITR 477 (Mad), we take a different stand. As mentioned earlier para 9 of the official manual procedure is a guideline for the assessing authority. It is also admitted fact that said guideline is in relation to provisions of section 158BG and does not have any impact in relation to provision of section 153D of the Act, though, admittedly, both 153D and 15…

BIBHUDUTTA PANDA,BHUBANESWAR vs. ASST.CIT ,CORPORATE CIRCLE-1(2), BHUBANESWAR

In the result, all appeals of the assessee stand allowed

ITA 79/CTK/2022[2010-11]Status: DisposedITAT Cuttack01 Feb 2023AY 2010-11

Bench: Shri George Mathan & Shri Arun Khodpiaआयकर अऩीऱ सं/Ita Nos.76 To 81/Ctk/2022 (ननधाारण वषा / Assessment Years :2007-2008 To 2012-2013) Bibhudutta Panda, Vs Acit, Corporate Circle-1(2), Plot No.73 & 74, Jayadev Vihar, Bhubaneswar Bhubaneswar-751013 Pan No. :Adapp 6398 R (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

For Appellant: Shri S.K.Agrawalla/S.K.Hota, ArsFor Respondent: Shri M.K.Gautam, CIT-DR
Section 142(1)Section 153ASection 153D

…ase of Serajuddin & Co. (supra) has gone into the quality of the satisfaction recorded by the approving authority. We are not in agreement with the said findings and in view of the decision of Hon’ble Madras High Court in the case of CIT Vs. Hi Tech Arai Ltd, 321 ITR 477 (Mad), we take a different stand. As mentioned earlier para 9 of the official manual procedure is a guideline for the assessing authority. It is also admitted fact that said guideline is in relation to provisions of section 158BG and does not have any impact in relation to provision of section 153D of the Act, though, admittedly, both 153D and 15…

BIBHUDUTTA PANDA,BHUBANESWAR vs. ASST.CIT, CORPORATE CIRCLE-1(2), BHUBANESWAR

In the result, all appeals of the assessee stand allowed

ITA 78/CTK/2022[2009-10]Status: DisposedITAT Cuttack01 Feb 2023AY 2009-10

Bench: Shri George Mathan & Shri Arun Khodpiaआयकर अऩीऱ सं/Ita Nos.76 To 81/Ctk/2022 (ननधाारण वषा / Assessment Years :2007-2008 To 2012-2013) Bibhudutta Panda, Vs Acit, Corporate Circle-1(2), Plot No.73 & 74, Jayadev Vihar, Bhubaneswar Bhubaneswar-751013 Pan No. :Adapp 6398 R (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

For Appellant: Shri S.K.Agrawalla/S.K.Hota, ArsFor Respondent: Shri M.K.Gautam, CIT-DR
Section 142(1)Section 153ASection 153D

…ase of Serajuddin & Co. (supra) has gone into the quality of the satisfaction recorded by the approving authority. We are not in agreement with the said findings and in view of the decision of Hon’ble Madras High Court in the case of CIT Vs. Hi Tech Arai Ltd, 321 ITR 477 (Mad), we take a different stand. As mentioned earlier para 9 of the official manual procedure is a guideline for the assessing authority. It is also admitted fact that said guideline is in relation to provisions of section 158BG and does not have any impact in relation to provision of section 153D of the Act, though, admittedly, both 153D and 15…

BIBHUDUTTA PANDA,BHUBANESWAR vs. ASST.CIT, CORPORATE CIRCLE-1(2), BHUBANESWAR

In the result, all appeals of the assessee stand allowed

ITA 77/CTK/2022[2008-09]Status: DisposedITAT Cuttack01 Feb 2023AY 2008-09

Bench: Shri George Mathan & Shri Arun Khodpiaआयकर अऩीऱ सं/Ita Nos.76 To 81/Ctk/2022 (ननधाारण वषा / Assessment Years :2007-2008 To 2012-2013) Bibhudutta Panda, Vs Acit, Corporate Circle-1(2), Plot No.73 & 74, Jayadev Vihar, Bhubaneswar Bhubaneswar-751013 Pan No. :Adapp 6398 R (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

For Appellant: Shri S.K.Agrawalla/S.K.Hota, ArsFor Respondent: Shri M.K.Gautam, CIT-DR
Section 142(1)Section 153ASection 153D

…ase of Serajuddin & Co. (supra) has gone into the quality of the satisfaction recorded by the approving authority. We are not in agreement with the said findings and in view of the decision of Hon’ble Madras High Court in the case of CIT Vs. Hi Tech Arai Ltd, 321 ITR 477 (Mad), we take a different stand. As mentioned earlier para 9 of the official manual procedure is a guideline for the assessing authority. It is also admitted fact that said guideline is in relation to provisions of section 158BG and does not have any impact in relation to provision of section 153D of the Act, though, admittedly, both 153D and 15…

BIBHUDUTTA PANDA,BHUBANESWAR vs. ASST.CIT, CORPORATE CIRCLE-1(2), BHUBANESWAR

In the result, all appeals of the assessee stand allowed

ITA 76/CTK/2022[2007-08]Status: DisposedITAT Cuttack01 Feb 2023AY 2007-08

Bench: Shri George Mathan & Shri Arun Khodpiaआयकर अऩीऱ सं/Ita Nos.76 To 81/Ctk/2022 (ननधाारण वषा / Assessment Years :2007-2008 To 2012-2013) Bibhudutta Panda, Vs Acit, Corporate Circle-1(2), Plot No.73 & 74, Jayadev Vihar, Bhubaneswar Bhubaneswar-751013 Pan No. :Adapp 6398 R (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

For Appellant: Shri S.K.Agrawalla/S.K.Hota, ArsFor Respondent: Shri M.K.Gautam, CIT-DR
Section 142(1)Section 153ASection 153D

…ase of Serajuddin & Co. (supra) has gone into the quality of the satisfaction recorded by the approving authority. We are not in agreement with the said findings and in view of the decision of Hon’ble Madras High Court in the case of CIT Vs. Hi Tech Arai Ltd, 321 ITR 477 (Mad), we take a different stand. As mentioned earlier para 9 of the official manual procedure is a guideline for the assessing authority. It is also admitted fact that said guideline is in relation to provisions of section 158BG and does not have any impact in relation to provision of section 153D of the Act, though, admittedly, both 153D and 15…

CRAFTSMAN AUTOMATION PVT. LTD.,CHENNAI vs. JCIT, COIMBATORE

In the result, the appeal filed by the assessee is partly allowed as indicated above

ITA 652/CHNY/2016[2011-12]Status: DisposedITAT Chennai21 Dec 2022AY 2011-12

Bench: Shri Mahavir Singh, Hon’Ble & Shri Manoj Kumar Aggarwal, Hon’Bleआयकर अपील सं./Ita No.652/Chny/2016 िनधा"रण वष" /Assessment Year: 2011-12

For Appellant: Mr.N.ArjunrajFor Respondent: Dr.S.Palanikumar, CIT
Section 144C(13)Section 144C(5)Section 14ASection 92C

…ibunal. 4.3 At the outset, the Ld.Counsel for the assessee stated that neither the AO nor the DRP has considered this issue independently and the ld.Counsel argued that the Hon’ble Madras High Court in the case of CIT v. Hi Tech Ara Ltd. reported in [2010] 321 ITR 477 (Madras) [01.09.2009], has categorically held that, once the incorrect decision of earlier years, cannot :- 6 -: be followed and for this, the Ld.Counsel for the assessee referred to Para-3 of the Hon’ble Madras High Court, which reads as under: “3. We are not in a position to appreciate either of the contentions of the learned counsel for the…

SUJATA PANDA,BERHAMPUR vs. ACIT, CENTARAL CIRCLE-1, BHUBANESWAR

In the result, appeals of the assessee are allowed

ITA 421/CTK/2019[2015-16]Status: HeardITAT Cuttack18 Nov 2022AY 2015-16

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaita Nos.415 To 421/Ctk/20 /Ctk/2019 Assessment Years : 2009-10 To 2015 10 To 2015-16 Sujata Panda Sujata Panda, The X Ray Vs. Acit, Acit, Central Central Circle Circle-1, Clinic, State Bank Of India, Clinic, State Bank Of India, Bhubaneswar Bhubaneswar Berhampur- -760001 Pan/Gir No. Pan/Gir No.Agppp 7126H (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri D.Parida, Ca/C.Parida, /C.Parida, Adv Revenue By : Shri M.K.Gautam, Cit , Cit Dr Date Of Hearing : 18/11 11/2022 Date Of Pronouncement : 18/11 11/2022 O R D E R Per Bench These Are Ese Are Appeals Filed By The Assessee Against The Against The Separate Orders Of The Ld Cit(A) Of The Ld Cit(A)-2, Bhubaneswar Dated 21.8.2019 21.8.2019 In Appeal No.0760/2016 0760/2016-17, Dated 17.9.2019, Nos. 0765/2016 0765/2016-17, 0769/2016- 17,0775/2016 17,0775/2016-17, 0782/2016-17, Dated 18.9.2019 No. Dated 18.9.2019 No. 0780/2016-17 & 0788/2016-17 17 For The Assessment Years 2009 2009-10 To 2015-16, Respectively. Respectively. 2. S/Shri Shri D.Parida/C. D.Parida/C.Parida, Ld Ars Appeared Appeared For For The The Assessee & Shri M.K.Gautam, Ld Cit Dr Appeared For The Assessee & Shri M.K.Gautam, Ld Cit Dr Appeared For The Assessee & Shri M.K.Gautam, Ld Cit Dr Appeared For The Revenue.

For Appellant: Shri D.Parida, CA/C.ParidaFor Respondent: Shri M.K.Gautam, CIT
Section 132Section 153BSection 156

…Nos.415 to 421/CTK/2019 Assessment Years : 2009-10 to 2015-16 made on the last ,daY illegal. In the circumstances, respectfully following the principles and the ratio laid down by the Hon'ble Madras High Court in the case of CIT Vs. Hi-Tech Arai Ltd. (2010) 321 ITR 477, we differ from the decision taken by the Coordinate Bench in the case of Durga Condev Pvt. Ltd. (supra) as also the decision of Shanti Lai Godawat & Ors. Vs. ACIT (2009) 126 TTJ (Jodh) 135. Here, we may specifically mention that in the case of Durga Condev Pvt. Ltd. (supra), though one of us is co-signatory in that order still we differ from the…

SUJATA PANDA,BERHAMPUR vs. ACIT, CENTARAL CIRCLE-1, BHUBANESWAR

In the result, appeals of the assessee are allowed

ITA 420/CTK/2019[2014-15]Status: HeardITAT Cuttack18 Nov 2022AY 2014-15

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaita Nos.415 To 421/Ctk/20 /Ctk/2019 Assessment Years : 2009-10 To 2015 10 To 2015-16 Sujata Panda Sujata Panda, The X Ray Vs. Acit, Acit, Central Central Circle Circle-1, Clinic, State Bank Of India, Clinic, State Bank Of India, Bhubaneswar Bhubaneswar Berhampur- -760001 Pan/Gir No. Pan/Gir No.Agppp 7126H (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri D.Parida, Ca/C.Parida, /C.Parida, Adv Revenue By : Shri M.K.Gautam, Cit , Cit Dr Date Of Hearing : 18/11 11/2022 Date Of Pronouncement : 18/11 11/2022 O R D E R Per Bench These Are Ese Are Appeals Filed By The Assessee Against The Against The Separate Orders Of The Ld Cit(A) Of The Ld Cit(A)-2, Bhubaneswar Dated 21.8.2019 21.8.2019 In Appeal No.0760/2016 0760/2016-17, Dated 17.9.2019, Nos. 0765/2016 0765/2016-17, 0769/2016- 17,0775/2016 17,0775/2016-17, 0782/2016-17, Dated 18.9.2019 No. Dated 18.9.2019 No. 0780/2016-17 & 0788/2016-17 17 For The Assessment Years 2009 2009-10 To 2015-16, Respectively. Respectively. 2. S/Shri Shri D.Parida/C. D.Parida/C.Parida, Ld Ars Appeared Appeared For For The The Assessee & Shri M.K.Gautam, Ld Cit Dr Appeared For The Assessee & Shri M.K.Gautam, Ld Cit Dr Appeared For The Assessee & Shri M.K.Gautam, Ld Cit Dr Appeared For The Revenue.

For Appellant: Shri D.Parida, CA/C.ParidaFor Respondent: Shri M.K.Gautam, CIT
Section 132Section 153BSection 156

…Nos.415 to 421/CTK/2019 Assessment Years : 2009-10 to 2015-16 made on the last ,daY illegal. In the circumstances, respectfully following the principles and the ratio laid down by the Hon'ble Madras High Court in the case of CIT Vs. Hi-Tech Arai Ltd. (2010) 321 ITR 477, we differ from the decision taken by the Coordinate Bench in the case of Durga Condev Pvt. Ltd. (supra) as also the decision of Shanti Lai Godawat & Ors. Vs. ACIT (2009) 126 TTJ (Jodh) 135. Here, we may specifically mention that in the case of Durga Condev Pvt. Ltd. (supra), though one of us is co-signatory in that order still we differ from the…

SUJATA PANDA,BERHAMPUR vs. ACIT, CENTARAL CIRCLE-1, BHUBANESWAR

In the result, appeals of the assessee are allowed

ITA 419/CTK/2019[2013-14]Status: HeardITAT Cuttack18 Nov 2022AY 2013-14

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaita Nos.415 To 421/Ctk/20 /Ctk/2019 Assessment Years : 2009-10 To 2015 10 To 2015-16 Sujata Panda Sujata Panda, The X Ray Vs. Acit, Acit, Central Central Circle Circle-1, Clinic, State Bank Of India, Clinic, State Bank Of India, Bhubaneswar Bhubaneswar Berhampur- -760001 Pan/Gir No. Pan/Gir No.Agppp 7126H (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri D.Parida, Ca/C.Parida, /C.Parida, Adv Revenue By : Shri M.K.Gautam, Cit , Cit Dr Date Of Hearing : 18/11 11/2022 Date Of Pronouncement : 18/11 11/2022 O R D E R Per Bench These Are Ese Are Appeals Filed By The Assessee Against The Against The Separate Orders Of The Ld Cit(A) Of The Ld Cit(A)-2, Bhubaneswar Dated 21.8.2019 21.8.2019 In Appeal No.0760/2016 0760/2016-17, Dated 17.9.2019, Nos. 0765/2016 0765/2016-17, 0769/2016- 17,0775/2016 17,0775/2016-17, 0782/2016-17, Dated 18.9.2019 No. Dated 18.9.2019 No. 0780/2016-17 & 0788/2016-17 17 For The Assessment Years 2009 2009-10 To 2015-16, Respectively. Respectively. 2. S/Shri Shri D.Parida/C. D.Parida/C.Parida, Ld Ars Appeared Appeared For For The The Assessee & Shri M.K.Gautam, Ld Cit Dr Appeared For The Assessee & Shri M.K.Gautam, Ld Cit Dr Appeared For The Assessee & Shri M.K.Gautam, Ld Cit Dr Appeared For The Revenue.

For Appellant: Shri D.Parida, CA/C.ParidaFor Respondent: Shri M.K.Gautam, CIT
Section 132Section 153BSection 156

…Nos.415 to 421/CTK/2019 Assessment Years : 2009-10 to 2015-16 made on the last ,daY illegal. In the circumstances, respectfully following the principles and the ratio laid down by the Hon'ble Madras High Court in the case of CIT Vs. Hi-Tech Arai Ltd. (2010) 321 ITR 477, we differ from the decision taken by the Coordinate Bench in the case of Durga Condev Pvt. Ltd. (supra) as also the decision of Shanti Lai Godawat & Ors. Vs. ACIT (2009) 126 TTJ (Jodh) 135. Here, we may specifically mention that in the case of Durga Condev Pvt. Ltd. (supra), though one of us is co-signatory in that order still we differ from the…

SUJATA PANDA,BERHAMPUR vs. ACIT, CENTARAL CIRCLE-1, BHUBANESWAR

In the result, appeals of the assessee are allowed

ITA 417/CTK/2019[2011-12]Status: HeardITAT Cuttack18 Nov 2022AY 2011-12

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaita Nos.415 To 421/Ctk/20 /Ctk/2019 Assessment Years : 2009-10 To 2015 10 To 2015-16 Sujata Panda Sujata Panda, The X Ray Vs. Acit, Acit, Central Central Circle Circle-1, Clinic, State Bank Of India, Clinic, State Bank Of India, Bhubaneswar Bhubaneswar Berhampur- -760001 Pan/Gir No. Pan/Gir No.Agppp 7126H (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri D.Parida, Ca/C.Parida, /C.Parida, Adv Revenue By : Shri M.K.Gautam, Cit , Cit Dr Date Of Hearing : 18/11 11/2022 Date Of Pronouncement : 18/11 11/2022 O R D E R Per Bench These Are Ese Are Appeals Filed By The Assessee Against The Against The Separate Orders Of The Ld Cit(A) Of The Ld Cit(A)-2, Bhubaneswar Dated 21.8.2019 21.8.2019 In Appeal No.0760/2016 0760/2016-17, Dated 17.9.2019, Nos. 0765/2016 0765/2016-17, 0769/2016- 17,0775/2016 17,0775/2016-17, 0782/2016-17, Dated 18.9.2019 No. Dated 18.9.2019 No. 0780/2016-17 & 0788/2016-17 17 For The Assessment Years 2009 2009-10 To 2015-16, Respectively. Respectively. 2. S/Shri Shri D.Parida/C. D.Parida/C.Parida, Ld Ars Appeared Appeared For For The The Assessee & Shri M.K.Gautam, Ld Cit Dr Appeared For The Assessee & Shri M.K.Gautam, Ld Cit Dr Appeared For The Assessee & Shri M.K.Gautam, Ld Cit Dr Appeared For The Revenue.

For Appellant: Shri D.Parida, CA/C.ParidaFor Respondent: Shri M.K.Gautam, CIT
Section 132Section 153BSection 156

…Nos.415 to 421/CTK/2019 Assessment Years : 2009-10 to 2015-16 made on the last ,daY illegal. In the circumstances, respectfully following the principles and the ratio laid down by the Hon'ble Madras High Court in the case of CIT Vs. Hi-Tech Arai Ltd. (2010) 321 ITR 477, we differ from the decision taken by the Coordinate Bench in the case of Durga Condev Pvt. Ltd. (supra) as also the decision of Shanti Lai Godawat & Ors. Vs. ACIT (2009) 126 TTJ (Jodh) 135. Here, we may specifically mention that in the case of Durga Condev Pvt. Ltd. (supra), though one of us is co-signatory in that order still we differ from the…

SUJATA PANDA,BERHAMPUR vs. ACIT, CENTARAL CIRCLE-1, BHUBANESWAR

In the result, appeals of the assessee are allowed

ITA 416/CTK/2019[2010-11]Status: HeardITAT Cuttack18 Nov 2022AY 2010-11

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaita Nos.415 To 421/Ctk/20 /Ctk/2019 Assessment Years : 2009-10 To 2015 10 To 2015-16 Sujata Panda Sujata Panda, The X Ray Vs. Acit, Acit, Central Central Circle Circle-1, Clinic, State Bank Of India, Clinic, State Bank Of India, Bhubaneswar Bhubaneswar Berhampur- -760001 Pan/Gir No. Pan/Gir No.Agppp 7126H (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri D.Parida, Ca/C.Parida, /C.Parida, Adv Revenue By : Shri M.K.Gautam, Cit , Cit Dr Date Of Hearing : 18/11 11/2022 Date Of Pronouncement : 18/11 11/2022 O R D E R Per Bench These Are Ese Are Appeals Filed By The Assessee Against The Against The Separate Orders Of The Ld Cit(A) Of The Ld Cit(A)-2, Bhubaneswar Dated 21.8.2019 21.8.2019 In Appeal No.0760/2016 0760/2016-17, Dated 17.9.2019, Nos. 0765/2016 0765/2016-17, 0769/2016- 17,0775/2016 17,0775/2016-17, 0782/2016-17, Dated 18.9.2019 No. Dated 18.9.2019 No. 0780/2016-17 & 0788/2016-17 17 For The Assessment Years 2009 2009-10 To 2015-16, Respectively. Respectively. 2. S/Shri Shri D.Parida/C. D.Parida/C.Parida, Ld Ars Appeared Appeared For For The The Assessee & Shri M.K.Gautam, Ld Cit Dr Appeared For The Assessee & Shri M.K.Gautam, Ld Cit Dr Appeared For The Assessee & Shri M.K.Gautam, Ld Cit Dr Appeared For The Revenue.

For Appellant: Shri D.Parida, CA/C.ParidaFor Respondent: Shri M.K.Gautam, CIT
Section 132Section 153BSection 156

…Nos.415 to 421/CTK/2019 Assessment Years : 2009-10 to 2015-16 made on the last ,daY illegal. In the circumstances, respectfully following the principles and the ratio laid down by the Hon'ble Madras High Court in the case of CIT Vs. Hi-Tech Arai Ltd. (2010) 321 ITR 477, we differ from the decision taken by the Coordinate Bench in the case of Durga Condev Pvt. Ltd. (supra) as also the decision of Shanti Lai Godawat & Ors. Vs. ACIT (2009) 126 TTJ (Jodh) 135. Here, we may specifically mention that in the case of Durga Condev Pvt. Ltd. (supra), though one of us is co-signatory in that order still we differ from the…

SUJATA PANDA,BERHAMPUR vs. ACIT, CENTARAL CIRCLE-1, BHUBANESWAR

In the result, appeals of the assessee are allowed

ITA 415/CTK/2019[2009-10]Status: HeardITAT Cuttack18 Nov 2022AY 2009-10

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaita Nos.415 To 421/Ctk/20 /Ctk/2019 Assessment Years : 2009-10 To 2015 10 To 2015-16 Sujata Panda Sujata Panda, The X Ray Vs. Acit, Acit, Central Central Circle Circle-1, Clinic, State Bank Of India, Clinic, State Bank Of India, Bhubaneswar Bhubaneswar Berhampur- -760001 Pan/Gir No. Pan/Gir No.Agppp 7126H (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri D.Parida, Ca/C.Parida, /C.Parida, Adv Revenue By : Shri M.K.Gautam, Cit , Cit Dr Date Of Hearing : 18/11 11/2022 Date Of Pronouncement : 18/11 11/2022 O R D E R Per Bench These Are Ese Are Appeals Filed By The Assessee Against The Against The Separate Orders Of The Ld Cit(A) Of The Ld Cit(A)-2, Bhubaneswar Dated 21.8.2019 21.8.2019 In Appeal No.0760/2016 0760/2016-17, Dated 17.9.2019, Nos. 0765/2016 0765/2016-17, 0769/2016- 17,0775/2016 17,0775/2016-17, 0782/2016-17, Dated 18.9.2019 No. Dated 18.9.2019 No. 0780/2016-17 & 0788/2016-17 17 For The Assessment Years 2009 2009-10 To 2015-16, Respectively. Respectively. 2. S/Shri Shri D.Parida/C. D.Parida/C.Parida, Ld Ars Appeared Appeared For For The The Assessee & Shri M.K.Gautam, Ld Cit Dr Appeared For The Assessee & Shri M.K.Gautam, Ld Cit Dr Appeared For The Assessee & Shri M.K.Gautam, Ld Cit Dr Appeared For The Revenue.

For Appellant: Shri D.Parida, CA/C.ParidaFor Respondent: Shri M.K.Gautam, CIT
Section 132Section 153BSection 156

…Nos.415 to 421/CTK/2019 Assessment Years : 2009-10 to 2015-16 made on the last ,daY illegal. In the circumstances, respectfully following the principles and the ratio laid down by the Hon'ble Madras High Court in the case of CIT Vs. Hi-Tech Arai Ltd. (2010) 321 ITR 477, we differ from the decision taken by the Coordinate Bench in the case of Durga Condev Pvt. Ltd. (supra) as also the decision of Shanti Lai Godawat & Ors. Vs. ACIT (2009) 126 TTJ (Jodh) 135. Here, we may specifically mention that in the case of Durga Condev Pvt. Ltd. (supra), though one of us is co-signatory in that order still we differ from the…

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