SECRETARY, PUBLIC SERVICE COMMISSION, UTTAR PRADESH,ALLAHABAD vs. IT OFFICER, T.D.S., ALLAHABAD

In the result appeal filed by assessee in ITA no

Bench: Shri.Vijay Pal Rao & Shri Ramit Kocharassessment Year: 2013-14 Assessment Year: 2014-15 The Ito (Tds), V. Public Service Commission 38, M.G. Marg, Civil Lines, (Lok Sewa Aayog), Allahabad,Up Uttar Pradesh, Stanley Road, Allahabad,Up Tan: Aldl00365B (Appellant) (Respondent) Assessment Year: 2013-14 Assessment Year: 2014-15 The Secretary, V. The Income Tax Officer (Tds), Public Service Commission Aaykar Bhawan, (Lok Sewa Aayog), 38, M.G. Marg, Uttar Pradesh, Allahabad,Up Stanley Road Allahabad,Up Tan: Aldl00365B (Appellant) (Respondent)

TDS on these payments as is mandated under the provisions of Section 197 of the 1961 Act. Provisions of Section 119 of the 1961 Act empowers CBDT to grant exemption from rigours of provisions of the 1961 Act to redress genuine hardship of the taxpayers. The assessee has also filed additional evidences before tribunal(pb/page 8

ITO(TDS),, ALLAHABAD vs. LOK SEWA AYOG,, ALLAHABAD

In the result appeal filed by assessee in ITA no

Bench: Shri.Vijay Pal Rao & Shri Ramit Kocharassessment Year: 2013-14 Assessment Year: 2014-15 The Ito (Tds), V. Public Service Commission 38, M.G. Marg, Civil Lines, (Lok Sewa Aayog), Allahabad,Up Uttar Pradesh, Stanley Road, Allahabad,Up Tan: Aldl00365B (Appellant) (Respondent) Assessment Year: 2013-14 Assessment Year: 2014-15 The Secretary, V. The Income Tax Officer (Tds), Public Service Commission Aaykar Bhawan, (Lok Sewa Aayog), 38, M.G. Marg, Uttar Pradesh, Allahabad,Up Stanley Road Allahabad,Up Tan: Aldl00365B (Appellant) (Respondent)

TDS on these payments as is mandated under the provisions of Section 197 of the 1961 Act. Provisions of Section 119 of the 1961 Act empowers CBDT to grant exemption from rigours of provisions of the 1961 Act to redress genuine hardship of the taxpayers. The assessee has also filed additional evidences before tribunal(pb/page 8

ITO(TDS),, ALLAHABAD vs. LOK SEWA AYOG,, ALLAHABAD

In the result appeal filed by assessee in ITA no

Bench: Shri.Vijay Pal Rao & Shri Ramit Kocharassessment Year: 2013-14 Assessment Year: 2014-15 The Ito (Tds), V. Public Service Commission 38, M.G. Marg, Civil Lines, (Lok Sewa Aayog), Allahabad,Up Uttar Pradesh, Stanley Road, Allahabad,Up Tan: Aldl00365B (Appellant) (Respondent) Assessment Year: 2013-14 Assessment Year: 2014-15 The Secretary, V. The Income Tax Officer (Tds), Public Service Commission Aaykar Bhawan, (Lok Sewa Aayog), 38, M.G. Marg, Uttar Pradesh, Allahabad,Up Stanley Road Allahabad,Up Tan: Aldl00365B (Appellant) (Respondent)

TDS on these payments as is mandated under the provisions of Section 197 of the 1961 Act. Provisions of Section 119 of the 1961 Act empowers CBDT to grant exemption from rigours of provisions of the 1961 Act to redress genuine hardship of the taxpayers. The assessee has also filed additional evidences before tribunal(pb/page 8

SECRETARY, PUBLIC SERVICE COMMISSION, UTTAR PRADESH,ALLAHABAD vs. IT OFFICER, T.D.S., ALLAHABAD

In the result appeal filed by assessee in ITA no

Bench: Shri.Vijay Pal Rao & Shri Ramit Kocharassessment Year: 2013-14 Assessment Year: 2014-15 The Ito (Tds), V. Public Service Commission 38, M.G. Marg, Civil Lines, (Lok Sewa Aayog), Allahabad,Up Uttar Pradesh, Stanley Road, Allahabad,Up Tan: Aldl00365B (Appellant) (Respondent) Assessment Year: 2013-14 Assessment Year: 2014-15 The Secretary, V. The Income Tax Officer (Tds), Public Service Commission Aaykar Bhawan, (Lok Sewa Aayog), 38, M.G. Marg, Uttar Pradesh, Allahabad,Up Stanley Road Allahabad,Up Tan: Aldl00365B (Appellant) (Respondent)

TDS on these payments as is mandated under the provisions of Section 197 of the 1961 Act. Provisions of Section 119 of the 1961 Act empowers CBDT to grant exemption from rigours of provisions of the 1961 Act to redress genuine hardship of the taxpayers. The assessee has also filed additional evidences before tribunal(pb/page 8

KESARWANI MARKETING(P) LTD.,ALLAHABAD vs. JT.CIT,, ALLAHABAD

In the result appeal filed by assessee in ITA No

Bench: Shri Vijay Pal Rao & Shri Ramit Kochar

8. That in any view of the matter a sum of Rs. 2,40,428.00 out of the assessment order, as maintained by the Commissioner of Income Tax (Appeals) as per Para 11.2 of his order on the basis of incorrect allegation of inflating of expenses is totally incorrect in so far as the disallowances was made in adhoc manner

M/S KESARWANI MARKETING (P) LTD.,ALLAHABAD vs. JT.CIT (OSD), ALLAHABAD

In the result appeal filed by assessee in ITA No

Bench: Shri Vijay Pal Rao & Shri Ramit Kochar

8. That in any view of the matter a sum of Rs. 2,40,428.00 out of the assessment order, as maintained by the Commissioner of Income Tax (Appeals) as per Para 11.2 of his order on the basis of incorrect allegation of inflating of expenses is totally incorrect in so far as the disallowances was made in adhoc manner

M/S KESARWANI <ARKETING (P) LTD,,ALLAHABAD vs. JT.CIT (OSD),, ALLAHABAD

In the result appeal filed by assessee in ITA No

Bench: Shri Vijay Pal Rao & Shri Ramit Kochar

TDS). The assessee made contentions that the additions are not sustainable and need to be deleted. The ld. CIT(A) dismissed the appeal of the assessee, by holding that contents of trial balance cannot be disbelieved unless otherwise proved. Reference was drawn to Section 292C, and ld. CIT(A) held that the assessee failed to reconcile the difference. Aggrieved

M/S KESARWANI MARKETING (P) LTD,,ALLAHABAD vs. JT. C.IT,(OSD), ALLAHABAD

In the result appeal filed by assessee in ITA No

Bench: Shri Vijay Pal Rao & Shri Ramit Kochar

TDS). The assessee made contentions that the additions are not sustainable and need to be deleted. The ld. CIT(A) dismissed the appeal of the assessee, by holding that contents of trial balance cannot be disbelieved unless otherwise proved. Reference was drawn to Section 292C, and ld. CIT(A) held that the assessee failed to reconcile the difference. Aggrieved

M/S KESARWANI MARKETING (P) LTD,,ALLAHABAD vs. JT.CIT,(OSD), ALLAHABAD

In the result appeal filed by assessee in ITA No

Bench: Shri Vijay Pal Rao & Shri Ramit Kochar

TDS). The assessee made contentions that the additions are not sustainable and need to be deleted. The ld. CIT(A) dismissed the appeal of the assessee, by holding that contents of trial balance cannot be disbelieved unless otherwise proved. Reference was drawn to Section 292C, and ld. CIT(A) held that the assessee failed to reconcile the difference. Aggrieved

M/S KESARWANI MARKETING(P).LTD.,ALLAHABAD vs. JT. CIT(OSD),, ALLAHABAD

In the result appeal filed by assessee in ITA No

Bench: Shri Vijay Pal Rao & Shri Ramit Kochar

TDS). The assessee made contentions that the additions are not sustainable and need to be deleted. The ld. CIT(A) dismissed the appeal of the assessee, by holding that contents of trial balance cannot be disbelieved unless otherwise proved. Reference was drawn to Section 292C, and ld. CIT(A) held that the assessee failed to reconcile the difference. Aggrieved

SMT. VIJAY LUXMI GUPTA (THROUGH LEGAL HEIR SHRI MUKESH GUPTA),ALLAHABAD vs. INCOME TAX OFFICER, WARD-1(4), ALLAHABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao

8 as income of the assessee. The income shown in the TDS certificates has either to be taxed in the hands of the joint venture or in the hands of the individual co-joint venturer. As the joint venture has not filed return of income and claimed credit for TDS certificates and the TDS certificates have not been doubted, credit

M/S MILLENIUM CONSULTANTS& SERVICE PROVIDERS,,ALLAHABAD vs. DCIT, ALLAHABAD

In the result, appeal filed by the assessee is partly allowed

Bench: Shri Vijay Pal Rao & Shri Ramit Kochar

TDS and remit it in government account within the time limit prescribed under the Section. He further contended that the amendment made under Section 40 (a) (ia) by the Finance Act, 2010, clearly states that the amendment has the retrospective effect from the Assessment Year 2010-11 and it cannot be held to be retrospective from the Assessment Year

M/S DEORA ELECTRIC WORKS,ALLAHABAD vs. DY. COMMISSIONER OF INCOME TAX, CIRCLE -1, ALLAHABAD

In the result, both appeals i

section 148 were validly initiated by the ld. AO. Accordingly, the appeal of the assessee is dismissed. 8. Now coming to the Departmental Appeal, we observe that the ld. CIT(A) has quite clearly observed that the ld. AO has made the disallowance without considering the TDS

DY. COMMISSIONER OF INCOME TAX, CIRCLE -1, ALLAHABAD vs. M/S DEORA ELECTRIC WORKS, ALLAHABAD

In the result, both appeals i

section 148 were validly initiated by the ld. AO. Accordingly, the appeal of the assessee is dismissed. 8. Now coming to the Departmental Appeal, we observe that the ld. CIT(A) has quite clearly observed that the ld. AO has made the disallowance without considering the TDS

SAVLA AGENCIES,ALLAHABAD vs. JCIT, RANGE-I, , ALLAHABAD

In the result, the appeal of the assessee is partly allowed

Bench: Shri.Vijay Pal Raoassessment Year: 2011-12 Savla Agencies, V. Joint Commissioner Of Income Tax, 26, M.G. Marg, Civil Lines, Range-I, Allahabad Allahabad-211001 Pan-Aawfs0816J (Appellant) (Respondent) Appellant By: Mr. Tanmay Sadh, Adv Respondent By: Mr. A.K. Singh, Sr. Dr Date Of Hearing: 05.01.2023 Date Of Pronouncement: 06.01.2023 O R D E R

section 40(b)(iv) of the Income Tax Act. It further provides that such interests shall be calculated and credited to the account of the each partner at the close of the accounting year which means that the interest will be credited only at the end of the accounting year / financial year and does not mean that the interest will

M/S. SUBHASH STONE INDUSTRIES (P) LTD.,NAINITAL vs. DCIT, CENTRAL CIRCLE, ALLAHABAD

In the result, appeal filed by the assessee in ITA no

Bench: Shri Vijay Pal Rao & Shri Ramit Kochar

TDS Rs.1,19,950/- e) Disallowance of Proportionate Expenses Rs.1,55,700/- ----------------- Total Rs. 6,26,650/- 5 Assessment Year: 2008-09 M/s Subhash Stone Industries Private Limited (Formerly Rajluxmi Stone Crushers Private Limited) v. Deputy Commissioner of Income Tax, Central Circle, Allahabad ------------------- Hence, an addition of Rs. 6,26,650/- was made by the AO to the income

LATE SRI ZIA USMANI THROUGH L/H AND WIFE SMT. MEHVISH USMANI,ALLAHABAD vs. COMMISSIONER OF INCOME TAX (APPEALS), ALLAHABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao

8. Because the appellant reserves the right to add/alter/rescind any ground of appeal. 3. Ground No. 1 to 3 are regarding validity of the penalty order passed u/s 271(1)(c) on the ground that the Assessing Officer has not initiated the penalty proceedings for a definite default or a correct charge against the assessee

M/S DEORA ELECTRIC WORKS,,ALLAHABAD vs. JT.CIT,, ALLAHABAD

In the result, the appeal of the assessee is partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudharyassessment Year: 2010-11 M/S Deora Electric Works V. The Jcit 58-A, Sardar Patel Marg Range – I Allahabad Allahabad Pan:Aadfd7479B (Appellant) (Respondent) Appellant By: Shri Praveen Godbole, C.A. Respondent By: Shri A. K. Singh, Sr. D.R. Date Of Hearing: 17 01 2025 Date Of Pronouncement: 20 03 2025 O R D E R

TDS, it was submitted that the same was not made according to the bonafide belief that tax deduction was not required for the amounts below Rs.50,000/-. Regarding the payments disallowable under section 40A(3) of the Act, it was submitted that these were made after office hours at various sites. Regarding the difference in amount of bank guarantee