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

Section 40(a)(ia) of the income tax act is not applicable. 6. That in any view of the matter disallowance of Rs. 1,79

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

Section 40(a)(ia) of the income tax act is not applicable. 6. That in any view of the matter disallowance of Rs. 1,79

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

Section 40(a)(ia) of the income tax act is not applicable. 6. That in any view of the matter disallowance of Rs. 1,79

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

Section 40(a)(ia) of the income tax act is not applicable. 6. That in any view of the matter disallowance of Rs. 1,79

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.

79,080/- on 22.01.2022. Thereafter, the return was processed by the CPC, Bengaluru on 17.10.2022, wherein the total income was worked out at Rs.7,59, 83,430/-. A disallowance was made for a sum of Rs.43,04,355/-, as being hit by section

SANJANA,ALLAHABAD vs. ITO, WARD- 1 (5), ALLAHABAD

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

section 147 of the Act. 11. BECAUSE after having verified all payments made by the appellant, there remains no scope of disallowance on ITA Nos.50, 51, 52, 53 & 54/ALLD/2023 & ITA Nos.5, 6, 7, 8 & 9/ALLD/2023 Page 8 of 79

SANJANA,ALLAHABAD vs. ITO, WARD-1(5), ALLAHABAD

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

section 147 of the Act. 11. BECAUSE after having verified all payments made by the appellant, there remains no scope of disallowance on ITA Nos.50, 51, 52, 53 & 54/ALLD/2023 & ITA Nos.5, 6, 7, 8 & 9/ALLD/2023 Page 8 of 79

SANJANA,ALLAHABAD vs. ITO, WARD- 1(5), ALLAHABAD

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

section 147 of the Act. 11. BECAUSE after having verified all payments made by the appellant, there remains no scope of disallowance on ITA Nos.50, 51, 52, 53 & 54/ALLD/2023 & ITA Nos.5, 6, 7, 8 & 9/ALLD/2023 Page 8 of 79

YOGI SATYAM,ALLAHABAD vs. ITO, WARD- 1(5), ALLAHABAD

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

section 147 of the Act. 11. BECAUSE after having verified all payments made by the appellant, there remains no scope of disallowance on ITA Nos.50, 51, 52, 53 & 54/ALLD/2023 & ITA Nos.5, 6, 7, 8 & 9/ALLD/2023 Page 8 of 79

SANJANA,ALLAHABAD vs. ITO, WARD-1(5), ALLAHABAD

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

section 147 of the Act. 11. BECAUSE after having verified all payments made by the appellant, there remains no scope of disallowance on ITA Nos.50, 51, 52, 53 & 54/ALLD/2023 & ITA Nos.5, 6, 7, 8 & 9/ALLD/2023 Page 8 of 79

YOGI SATYAM,ALLAHABAD vs. ITO, WARD- 1(5), ALLAHABAD

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

section 147 of the Act. 11. BECAUSE after having verified all payments made by the appellant, there remains no scope of disallowance on ITA Nos.50, 51, 52, 53 & 54/ALLD/2023 & ITA Nos.5, 6, 7, 8 & 9/ALLD/2023 Page 8 of 79

SANJANA,ALLAHABAD vs. ITO, WARD- 1 (5), ALLAHABAD

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

section 147 of the Act. 11. BECAUSE after having verified all payments made by the appellant, there remains no scope of disallowance on ITA Nos.50, 51, 52, 53 & 54/ALLD/2023 & ITA Nos.5, 6, 7, 8 & 9/ALLD/2023 Page 8 of 79

YOGI SATYAM,ALLAHABAD vs. ITO, WARD-1(5), ALLAHABAD

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

section 147 of the Act. 11. BECAUSE after having verified all payments made by the appellant, there remains no scope of disallowance on ITA Nos.50, 51, 52, 53 & 54/ALLD/2023 & ITA Nos.5, 6, 7, 8 & 9/ALLD/2023 Page 8 of 79

YOGI SATYAM,ALLAHABAD vs. ITO, WARD- 1 (5), ALLAHABAD

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

section 147 of the Act. 11. BECAUSE after having verified all payments made by the appellant, there remains no scope of disallowance on ITA Nos.50, 51, 52, 53 & 54/ALLD/2023 & ITA Nos.5, 6, 7, 8 & 9/ALLD/2023 Page 8 of 79

YOGI SATYAM,ALLAHABAD vs. ITO, WARD- 1 (5), ALLAHABAD

The appeals are partly allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

section 147 of the Act. 11. BECAUSE after having verified all payments made by the appellant, there remains no scope of disallowance on ITA Nos.50, 51, 52, 53 & 54/ALLD/2023 & ITA Nos.5, 6, 7, 8 & 9/ALLD/2023 Page 8 of 79

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

In the result the appeal of the assessee is partly allowed

disallowance of commission on sales Rs.11,20,165/-. 4. Aggrieved with the said additions, the assessee went in appeal before the ld. CIT(A). Before the ld. CIT(A), it challenged the order passed under section 153A(b) dated 20.12.2011, as being passed without jurisdiction. It denied its liability to be assessed under block assessment in the absence

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

In the result the appeal of the assessee is partly allowed

disallowance of commission on sales Rs.11,20,165/-. 4. Aggrieved with the said additions, the assessee went in appeal before the ld. CIT(A). Before the ld. CIT(A), it challenged the order passed under section 153A(b) dated 20.12.2011, as being passed without jurisdiction. It denied its liability to be assessed under block assessment in the absence

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

In the result the appeal of the assessee is partly allowed

disallowance of commission on sales Rs.11,20,165/-. 4. Aggrieved with the said additions, the assessee went in appeal before the ld. CIT(A). Before the ld. CIT(A), it challenged the order passed under section 153A(b) dated 20.12.2011, as being passed without jurisdiction. It denied its liability to be assessed under block assessment in the absence