M/S UDVASIT BEROJGAR SAHAKARI SHRAM SAMVIDA SAMITI LTD.,,SONBHADRA vs. CIT (EXEMPTION), ALLAHABAD

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Shri.Vijay Pal Raoassessment Year: 2018-19

Section 36(1). By virtue of the Explanation below subclause (va), no deduction could be claimed if the contribution has not been paid, after collection from the employees by way of deduction from their salaries, within the due date under the EPF&MP Act. The deletion of a proviso under Section 43B cannot render otiose the Explanation under Section 36

COMMERCIAL AUTO SALES PVT. LTD.,,ALLAHABAD vs. ASSISTANT DIRECTOR OF INCOME TAX CENTRALIZED PROCESSING CENTRE, BENGALURU

In the result, appeal filed by the assessee is in ITA No

Bench: Shri Vijay Pal Rao & Shri Ramit Kochar

disallowance of aforesaid expenditure of Rs. 11,20,461/- , vide processing return of income u/s 143(1) of the 1961 Act , by invoking provision of Section 36(1)(va) read with Section 2(24)(x) of the 1961 Act , and the aforesaid amount stood added to the income of the assessee, vide orders dated 30.04.2020. 3. The assessee being aggrieved

ZILA SAHKARI BANK LTD,,MIRZAPUR vs. JT. C.I.T.,, MIRZAPUR

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

Bench: Shrivijay Pal Rao & Shri Ramit Kochar

disallowance as was made by the AO, the ld. CIT(A) observed that the assessee is not eligible for deduction under the second limb of Section 36(1)(viia)(a) of the 1961 Act which concerns itself with deduction computed @10% of aggregate average advances made by Rural Branches of assessee, keeping in view amended provisions of Section 36(1

ZILA SAHKARI BANK LTD.,MIRZAPUR vs. ASSTT. COMMISIONER OF INCOME TAX, MIRZAPUR

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

Bench: Shrivijay Pal Rao & Shri Ramit Kochar

disallowance as was made by the AO, the ld. CIT(A) observed that the assessee is not eligible for deduction under the second limb of Section 36(1)(viia)(a) of the 1961 Act which concerns itself with deduction computed @10% of aggregate average advances made by Rural Branches of assessee, keeping in view amended provisions of Section 36(1

DCIT, CIRCLE-II , ALLAHABAD vs. BHARAT PUMPS & COMPRESSORS LTD, ALLAHABAD

In the result, appeal filed by Revenue for ay: 2007-08 is allowed for statistical purposes

Bench: Shri.Vijay Pal Rao & Shri Ramit Kochar

Section 36(1)(va) read with Explanation 1 and Section 2(24)(x) of the 1961 Act. Similarly, Hon'ble Kerala High Court has also decided this issue in favour of Revenue in the case of CIT v. Merchem Limited reported in (2015) 378 ITR 443(Ker. HC) and also in Popular Vehicles and Services Private Limited

DCIT, CIRCLE-II , ALLAHABAD vs. BHARAT PUMPS & COMPRESSORS LTD, ALLAHABAD

In the result, appeal filed by Revenue for ay: 2007-08 is allowed for statistical purposes

Bench: Shri.Vijay Pal Rao & Shri Ramit Kochar

Section 36(1)(va) read with Explanation 1 and Section 2(24)(x) of the 1961 Act. Similarly, Hon'ble Kerala High Court has also decided this issue in favour of Revenue in the case of CIT v. Merchem Limited reported in (2015) 378 ITR 443(Ker. HC) and also in Popular Vehicles and Services Private Limited

VINOD KUMAR TANDON,ALLAHABAD vs. DCIT(CPC),, BEGALURU

In the result, appeal of the assessee is dismissed

disallowed under section 43-B which, as stated above, was inserted with effect from 1-4-1984 ** ** ** 22. It is important to note once again that, by the Finance Act, 2003, not only is the second proviso deleted but even the first proviso is sought to be amended by bringing about a uniformity in tax, duty, cess

TRIVENI GLASS LIMITED,ALLAHABAD vs. INCOME TAX OFFICER WARD 2(3), ALLAHABAD

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

Bench: Shri.Vijay Pal Rao& Shri Ramit Kochar

II(3), 38, M. G. Marg, Civil Lines, Allahabad- 211001, U.P. PAN:AAACT8795L (Appellant) (Respondent) Appellant by: Ms. Tanu Singhal, CA Respondent by: Shri A. K. Singh,Sr. DR Date of hearing: 19.07.2021& 10.09.2021 Date of pronouncement: 14.10.2021 O R D E R PER BENCH: These threeappeals bearing ITA numbers 19 to 21/Alld./2020 for assessment years

TRIVENI GLASS LIMITED,ALLAHABAD vs. INCOME TAX OFFICER WARD 2(3) , ALLAHABAD

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

Bench: Shri.Vijay Pal Rao& Shri Ramit Kochar

II(3), 38, M. G. Marg, Civil Lines, Allahabad- 211001, U.P. PAN:AAACT8795L (Appellant) (Respondent) Appellant by: Ms. Tanu Singhal, CA Respondent by: Shri A. K. Singh,Sr. DR Date of hearing: 19.07.2021& 10.09.2021 Date of pronouncement: 14.10.2021 O R D E R PER BENCH: These threeappeals bearing ITA numbers 19 to 21/Alld./2020 for assessment years

TRIVENI GLASS LIMITED,ALLAHABAD vs. INCOME TAX OFFICER WARD 2(3), ALLAHABAD

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

Bench: Shri.Vijay Pal Rao& Shri Ramit Kochar

II(3), 38, M. G. Marg, Civil Lines, Allahabad- 211001, U.P. PAN:AAACT8795L (Appellant) (Respondent) Appellant by: Ms. Tanu Singhal, CA Respondent by: Shri A. K. Singh,Sr. DR Date of hearing: 19.07.2021& 10.09.2021 Date of pronouncement: 14.10.2021 O R D E R PER BENCH: These threeappeals bearing ITA numbers 19 to 21/Alld./2020 for assessment years

ACIT CIRCLE-2, ALLAHABAD vs. M/S SHERWANI SUGAR SYNDICATE LTD., ALLAHABAD

In the result, appeal filed by the Revenue in ITA No

Bench: Shrivijay Pal Rao & Shri Ramit Kocharassessment Year: 1997-98 The Assistant Commissioner Of V. M/S Shervani Sugar Syndicate Income-Tax, Circle-2, Ltd., Allahabad, U.P. 28, South Road , Allahabad,U.P. Pan/Gir: 19-653-Cv-3480 New Pan: Not Available (Appellant) (Respondent)

36,440/- in Head Office Account, it was observed by AO that following interest are payable on loan : Interest Payable On: 1.) Loan for IRBI (Sugar) Rs. 1,11,168/- Neoli Sugar 2.) Loan for IRBI (Solvent) Rs. 1,31,096/- Solvent Oil 3.) Loan for IRBI (Sugar) Rs. 2,08,379/- Sugar 4.) FITL from IRBI(solvent

ASSISTANT COMMISSIONER OF INCOME TAX, ALLAHABAD vs. JYOTI MEDISERVICES LTD., ALLAHABAD

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

36 different assessment years in the cases of the aforesaid 11 different assessees. It was the contention of the learned Counsel for the assessee that considering the enormity of seized materials, digital data, submissions of the assessees, appraisal report provided by the Investigation Wing of Income Tax Department, reports under Rules 9 and 9A of ITSC(P) Rules, and other

JYOTI MEDISERVICES PRIVATE LIMITED,ALLAHABAD vs. DCIT, CENTRAL CIRCLE, ALLAHABAD, ALLAHABAD

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

36 different assessment years in the cases of the aforesaid 11 different assessees. It was the contention of the learned Counsel for the assessee that considering the enormity of seized materials, digital data, submissions of the assessees, appraisal report provided by the Investigation Wing of Income Tax Department, reports under Rules 9 and 9A of ITSC(P) Rules, and other

JYOTI MEDISERVICES PRIVATE LIMITED,,ALLAHABAD vs. DCIT, CENTRAL CIRCLE,, ALLAHABAD

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

36 different assessment years in the cases of the aforesaid 11 different assessees. It was the contention of the learned Counsel for the assessee that considering the enormity of seized materials, digital data, submissions of the assessees, appraisal report provided by the Investigation Wing of Income Tax Department, reports under Rules 9 and 9A of ITSC(P) Rules, and other

JYOTI MEDISERVICES PRIVATE LIMITED, ,ALLAHABAD vs. DCIT, CENTRAL CIRCLE, , ALLAHABAD

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

36 different assessment years in the cases of the aforesaid 11 different assessees. It was the contention of the learned Counsel for the assessee that considering the enormity of seized materials, digital data, submissions of the assessees, appraisal report provided by the Investigation Wing of Income Tax Department, reports under Rules 9 and 9A of ITSC(P) Rules, and other

KESARWANI & C0,,ALLAHABAD vs. JT CIT,, ALLAHABAD

In the result the appeal of the assessee is partly allowed

ii. On account of inflated expenses on the basis of print outs of CPU marked as KZ-1 – Rs. 20,76,268/-. iii. On account of repair and maintenance - Rs.10,120/-. iv. On account of disallowance of interest – Rs.33,570/-. v. On account of disallowance of diesel expenses – Rs.8,70,985/-. vi. On account of disallowance of commission on sales

KESARWANI & CO.,ALLAHABAD vs. JT.CIT,, ALLAHABAD

In the result the appeal of the assessee is partly allowed

ii. On account of inflated expenses on the basis of print outs of CPU marked as KZ-1 – Rs. 20,76,268/-. iii. On account of repair and maintenance - Rs.10,120/-. iv. On account of disallowance of interest – Rs.33,570/-. v. On account of disallowance of diesel expenses – Rs.8,70,985/-. vi. On account of disallowance of commission on sales

KESARWANI & C0.,ALLAHABAD vs. JT.CIT., ALLAHABAD

In the result the appeal of the assessee is partly allowed

ii. On account of inflated expenses on the basis of print outs of CPU marked as KZ-1 – Rs. 20,76,268/-. iii. On account of repair and maintenance - Rs.10,120/-. iv. On account of disallowance of interest – Rs.33,570/-. v. On account of disallowance of diesel expenses – Rs.8,70,985/-. vi. On account of disallowance of commission on sales

DEPUTY COMMISSIONER OF INCOME TAX(CENTRAL CIRCLE), ALLAHABAD vs. JEEVAN JYOTI CHARITABLE TRUST, ALLAHABAD

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

36 REVISED GROUNDS IN I.T.A. No.39/Alld/2019 38 I.T.A. No.40/Alld/2019 (Assessment year 2013-14) 41 REVISED GROUNDS IN I.T.A. No.40/Alld/2019 44 I.T.A. No.13/Alld/2025 (Assessment year 2011-12) I.T.A. No.14/Alld/2025 (Assessment year 2013-14) I.T.A. No.39/Alld/2025 (Assessment year 2011-12) I.T.A. No.40/Lkw/2025 (Assessment year 2012-13) I.T.A. No.41/Alld/2025 (Assessment year 2013-14) C.O. NO.02/Alld/2025 (in I.T.A. No.39/Alld/2025) C.O.No.03/Alld/2025 (in I.T.A. No.40/Allahabad/2025