ALLAHABAD DEVELOPMENT AUTHORITY,ALLAHABAD vs. ACIT (EXEMPTION), LUCKNOW

In the result all three appeals of the Assessee are partly allowed

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

section 20(2) of the 1973 Act, mandate that the funds of the authority are to be applied towards meeting the expenses of the authority in the administration of that Act and for no other purpose. iv. The contention of the Revenue that the assessee was a commercial enterprise which had undertaken various civil construction work on behalf of State

SBW UDYOG LIMITED,,PRAYAGRAJ vs. DCIT, CIR-1,, ALLAHABAD

In the result, the appeal of the assessee is dismissed

Bench: Sh.Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y.2021-22 Sbw Udyog Limited, Vs. Deputy Commissioner Of Income 44, Thornhill Road, Prayagraj Tax, Circle-1, Prayagraj Pan:Aadcs2883B (Appellant) (Respondent) Assessee By: Sh. N.C. Agrawal, C.A. Revenue By: Sh. A.K. Singh, Sr. Dr Date Of Hearing: 18.12.2024 Date Of Pronouncement: 13 .03.2025 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed Against The Orders Of The Ld. Cit(A) Under Section 250 Of The Income Tax Act, 1961 On 31.01.2024, Dismissing The Appeal Of The Assessee Against The Orders Of The Cpc Bengaluru, Under Section, 143(1) Dated 17.10.2022. Subsequently, The Said Appeal Was Migrated To The Nfac & Later On, The Appeal Proceedings Were Transferred To The Additional / Jcit(A), Aurangabad, Who Has Dismissed The Appeal Of The Assessee. The Grounds Of Appeal Preferred By The Assessee Are As Under:- “1. Because, Income Tax Department, Ministry Of Finance, Government Of India Has Observed In The Notice Under Section 250 Of The Income Tax Act, 1961, Which Reads As Under:- "The Income Tax Department Recognizes & Is Sensitive To The Hardships Being Faced By Taxpayers In Coping With The Challenges Posed By Covid-19 Pandemic." Consequently, Appeal Is Liable To Be Allowed.

2,346.00 16.09.2020 Paid to Director, ESI Indore AUGUST, ESI 539.00 15.09.2020 539.00 16.09.2020 2020 Total 43,04,355.00 3. The assessee submitted before the ld. CIT(A), that section 36(1)(va) of the Act was to be read with section 43B of the Act and contribution of Provident Fund and ESI paid till the filing of the return

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

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

ARUP BANERJI,ALLAHABAD vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1 , ALLAHABAD

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

Bench: SH. SUBHASH MALGURIA, JUDICIAL MEMBER AND SH. NIKHIL CHOUDHARY (Accountant Member)

2 A.Y. 2015-16 Arup Banerji contract notes and broker statement had been furnished by the assessee as well as the brokers in compliance to the notice issued under section 133(6) seeking the copy of the contract notes and the brokers statement of account. The assessee also submitted that in the previous assessment years, the dispute of setting

DEPUTY COMMISSIONER OF INCOME TAX, ALLAHABAD vs. NAVJEEVAN PEDIATRICS PRIVATE LIMITED, 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

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

MINTO COLONIZERS PRIVATE LIMITED,ALLAHABAD vs. DCIT CENTRAL CIRCLE , ALLAHABAD, 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

VANDANA BANSAL L/H OF LATE DR. ASHWANI KUMAR BANSAL, ,ALLAHABAD vs. ACIT, CENTRAL CIRCLE,, 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

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

ARPIT HOSPITAL PRIVATE LIMITED,,ALLAHABAD vs. DCIT, CENTRAL CIRCLE,, 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

MINTO DEVELOPERS PVT. LTD.,ALLAHABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE , 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

VANDANA BANSAL L/H OF LATE DR. ASHWANI KUMAR BANSAL, ,ALLAHABAD vs. ACIT, CENTRAL CIRCLE,, 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

VANDANA BANSAL L/H OF LATE DR. ASHWANI KUMAR BANSAL, ,ALLAHABAD vs. ACIT, CENTRAL CIRCLE,, 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

DEPUTY COMMISSIONER OF INCOME TAX, 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

VANDANA BANSAL L/H OF LATE DR. ASHWANI KUMAR BANSAL, ,ALLAHABAD vs. ACIT, CENTRAL CIRCLE,, 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