PRAMOD KUMAR AGARWALLA,ANGUL vs. ITO, ANGUL WARD, ANGUL

In the result, appeal of the assessee is partly allowed

Bench: Shri N.S.Sainiआयकर अपीऱ सं./Ita No.12/Ctk/2017 (नििाारण वषा / Assessment Year :2012-2013) Pramod Kumar Agarwalla, Vs. Ito Angul Ward-Angul Prop: Pramod Trading Co., Shankar Cinema Road, Angul- 759122 स्थायी लेखा सं./जीआइआर सं./ Pan/Gir No. : Aaxpa 8746 Q (अपीऱाथी /Appellant) (प्रत्यथी / Respondent) .. निर्ााररती की ओर से /Assessee By : Shri D.K.Sheth, Ar राजस्व की ओर से /Revenue By : Shri S.K.Bandyopadhyay, Dr सुनवाई की तारीख / Date Of Hearing : 13/12/2017 घोषणा की तारीख/Date Of Pronouncement 26/12/2017 आदेश / O R D E R This Is An Appeal Filed By The Assessee Against The Order Of The Cit(A)-2, Bhubaneswar, Dated 22.08.2016. 2. Ground No.1 Of The Appeal Is Directed Against The Order Of Cit(A) Confirming The Disallowance Of Payment Of Interest To Loan Creditors Rs.8,16,618/- U/S.40(A)(Ia) Of The Act For Non-Deduction Of Tds. 3. Brief Facts Of The Case Are That The Ao Made Addition Of Rs.8,16,618/- By Disallowing Interest U/S.40(A)(Ia) Of The Act For Non- Deduction Of Tax At Source. The Ao Observed That On Growing Through The Ledger Copy Of Unsecured Loan It Was Found That The Amount Of Interest Paid/Credited To The Payee Exceeded The Minimum Amount Not Chargeable To Tax And, Therefore, He Did Not Accept The Explanation Of The Assessee That Since The Assessee Had Collected Form No.15G For Non-Deduction Of Tax From The Payee, Hence, No Tds Was Deducted From The Payments Of Interest Made. According To The Ao Column No.4 Of The Form No.15G Read

TDS was deducted from the payments made, therefore, he disallowed the deduction of interest expenditure of Rs.8,16,618/-. On appeal, the CIT(A) confirmed the action of AO. Before us, no material was brought on record by the AR of the assessee to show that even where interest payment exceeded the taxable limit of income still Form No.15G could

RUKMANI INFRA PROJECTS PVT. LTD.,BHUBANESWAR vs. ACIT, CIRCLE-1(2), BHUBANESWAR

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

Bench: Shri Chandra Mohan Garg, Jm & Shri Arun Khodpia, Am आयकर अपीऱ सं./Ita No.358/Ctk/2017 (नििाारण वषा / Assessment Year :2013-2014) Rukmani Infra Projects Ltd., Vs Acit, Circle-1(2), Bhubaneswar Plot No.251, District Centre, C.S.Pur, Bhubaneswar-16 Pan No. : Aaecr 1585 L (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. यनधागररती की ओर से /Assessee By : None : Shri Manoj Kumar Goutam, Cit-Dr राजस्व की ओर से /Revenue By सुनवाई की तारीख / Date Of Hearing : 08/03/2022 घोषणा की तारीख/Date Of Pronouncement : 30/03/2022 आदेश / O R D E R Per Arun Khodpia, Am : This Appeal Filed By The Assessee Has Been Directed Against The Order Passed By The Ld. Cit(A)-1, Bhubaneswar, Dated 16.06.2017, For The Assessment Year 2013-2014. 2. Brief Facts Of The Case Extracted From The Available Records Are That, The Assessee, A Company Incorporated Under The Companies Act, 1956, Engaged In The Business Of Erection, Commissioning, Technical & Maintenance Service To Different Power Plants. The Return Of Income For The Ay 2013-14 Was Filed By The Assessee On 01.10.2013 Declaring A Total Income Of Rs.1,65,91,030/-. The Case Of The Assessee Was Selected Under Cass. Notice U/S 143(2) & 143(1) Were Issued & Served On The Assessee. Assessment Proceedings Were Completed By The Ao & Concluded With An Addition Of Rs.3,58,95,574/- Under Four Different

deposit of TDS without considering the ground reality of the facts. The assessee has saved working capital which has more interest than the above. Hence the addition is liable to be quashed. 6. That the Appellant craves the leave of the Hon'ble Bench to add, alter, amend, modify, substitute, delete and/or rescind all or any of the grounds

M/S. BALASORE CO-OPERATIVE URBAN BANK LTD.,BALASORE vs. ACIT, BALASORE CIRCLE, BALASORE

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

Bench: Shri C.M. Garg, Jm & Shri L.P. Sahu, Am आयकर अऩीऱ सं./Ita No.467/Ctk/2017 (नििाारण वषा / Assessment Year :2012-2013) M/S Balasore Cooperative Bank Vs. Acit, Balasore Circle, Limited, Balasore Bibekananda Marg, Balasore-756001 Pan No. : Aaccb 7823 M (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. ननधााररती की ओर से /Assessee By : Shri S.N.Sahu/Somnath Sahoo,Advs राजस्व की ओर से /Revenue By : Shri M.K.Gautam, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 13/08/2020 घोषणा की तारीख/Date Of Pronouncement : 12/10/2020 आदेश / O R D E R Per L.P.Sahu, Am: This Is An Appeal Filed By The Assessee Against The Order Passed By The Cit(A), Cuttack, Dated 04.08.2017, For The Assessment Year 2012-2013, On The Following Grounds Of Appeal :- 1) That The Order Of The Id. Cit(Appeals) Confirming The Additions & Disallowances Made By The A.O. Is Illegal, Arbitrary, Unjustified & Not In Accordance With Law. 2) That The Addition Of Rs. 36,79,148/- U/S. 40(A)(Ia) Of The I.T. Act, 1961 Confirmed By Cit(Appeals) To The Extent Of Rs. 36,30,998/- Is Illegal, Arbitrary, Uncalled For & Not In Accordance With Law & The Same Should Have Been Deleted By The Learned Cit(Appeals). 3) That The Disallowance U/S 40(A)(Ia) Of Rs. 36,79,148/- As Detailed Below Is Illegal, Arbitrary & Unjustified & Hence Should Have Been Deleted By The Learned Cit(A) As The Genuineness Is Not In Doubt. Non-Deduction Of Tds Is A Separate Issue. A) Commission Payment To Dlds Collection Agents Rs. 33,45,248/- B) Legal Expenses Rs. 2,52,000/- C) Audit Fees Rs. 81,900/-

depositing the TDS. The amendment has been made in the second proviso of Section 40(a)(ia) of the Act w.e.f. 01.04.2013 and, therefore, it is applicable for the A.Y.2013-2014 onwards. For this purpose, we would like to rely on the decision of Hon’ble Apex Court in the case of Shree Choudhary Transport Company Vs. ITO [2020] 118 taxmann.com

CHANDI FILLING STATION,CUTTACK vs. PRINCIPAL CIT-1, BHUBANESWAR

In the result, appeal of the assessee stands partly allowed

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaassessment Year: 2017-18 Chandi Chandi Filling Filling Station, Station, Vs. Pr. Cit-1, Manguli, Cuttack Manguli, Cuttack Bhubaneswar Bhubaneswar Pan/Gir No Pan/Gir No.Aacfc 8350 K (Appellant) ) .. ( Respondent Respondent)

cash deposits in the bank in denomination of 1,000 and 500 during the demonetization period. The assessee duly explained that specified currency was allowed by the notification issued by RBI for petrol pumps and medicine dealers to accept the specified currency during the demonetization period. In consequence to the survey, the case was selected for scrutiny assessment proceedings. Notices

MAMATA DEVI CHOPRA, PROP- M.M.TRADING CO.,CUTTACK vs. PR.CIT-1, BHUBANESWAR

In the result, appeal of the assessee stands allowed

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaassessment Year : 2017-18 Mamata Devi Chopra, Prop. Mamata Devi Chopra, Prop. Vs. Pr. Cit-1, M.M.Trading Co. Town Hall M.M.Trading Co. Town Hall Bhubaneswar. Bhubaneswar. Road, Cuttack Road, Cuttack Pan/Gir No. Pan/Gir No.Aaopc 5213 H (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri Pramod Kumar Jesty, Ar Pramod Kumar Jesty, Ar Revenue By : Shri M.K.Gautam, M.K.Gautam, Cit Dr Date Of Hearing : 9/02 2/2023 Date Of Pronouncement : 9/02 2/2023 O R D E R Per Bench This Is An Appeal Filed By The Assessee Against The Order Of The Ld This Is An Appeal Filed By The Assessee Against The Order Of The Ld This Is An Appeal Filed By The Assessee Against The Order Of The Ld Pr. Cit Passed U/S.263 Of Cit Passed U/S.263 Of The Act Dated 25.3.2022 25.3.2022 In Appeal No. Itba/Rev/F/Rev5/2021 Itba/Rev/F/Rev5/2021-22/1041530059(1) For The Assessment Year For The Assessment Year 2017- 18. 2. Shri Pramod Kumar Jesty, Ld Ar Appeared For The Assessee & Shri Shri Pramod Kumar Jesty, Ld Ar Appeared For The Assessee & Shri Shri Pramod Kumar Jesty, Ld Ar Appeared For The Assessee & Shri M.K.Gautam, Ld Cit Dr Appeared For The Revenue. M.K.Gautam, Ld Cit Dr Appeared For The Revenue.

deposited in the bank account was clearly out of the cash available in its books and this has also been examined by the Assessing Officer in its right perspective. Consequently, the action of the Pr. CIT in invoking his powers u/s.263 on this issue is unsubstantiated and quashed. 7. Coming to the issue of loan from M/s. Mangalchand Milapchand

NISHA DATA COM LIMITED,ROURKELA vs. INCOME TAX OFFICER WARD-3 ROURKELA, ROURKELA

In the result, both the appeals filed for AY 2011-12 and AY 2012-

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

cash deposits were made by 28 parties from different stations and the deposits were not income and the income had been offered for tax. The non-deduction of TDS

NISHA DATA COM LIMITED,ROURKELA vs. INCOME TAX OFFICER WARD-3 ROURKELA, ROURKELA

In the result, both the appeals filed for AY 2011-12 and AY 2012-

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

cash deposits were made by 28 parties from different stations and the deposits were not income and the income had been offered for tax. The non-deduction of TDS

KALPANA MISHRA,BHUBANESWAR vs. ITO, WARD 5(4), BHUBANESWAR, BHUBANESWAR

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

Bench: Shri George Mathan & Shri Manish Agarwalआयकर अपील संसंसंसं/Ita No.491/Ctk/2024 (िनधा"रण िनधा"रण िनधा"रण वष" िनधा"रण वष" वष" / Assessment Year : 2016-2017) वष" Kalpana Mishra, Vs Ito Ward-5(4), Bhubaneswar Plot No.B-87/A, Chandaka Industrial Estate, Patia, Bhubaneswar-751024 Pan No. :Alfpm 2864 E (अपीलाथ" अपीलाथ" अपीलाथ" /Appellant) अपीलाथ" (""यथ" ""यथ" ""यथ" / Respondent) ""यथ" .. िनधा"रती िनधा"रती क" िनधा"रती िनधा"रती क" क" ओर क" ओर ओर सेसेसेसे /Assessee By ओर : Shri B.R.Pattnaik, Ca राज"व राज"व क" राज"व राज"व क" क" ओर क" ओर ओर सेसेसेसे /Revenue By ओर : Shri S.C.Mohanty, Sr. Dr सुनवाई क" तारीख / Date Of Hearing : 28/01/2025 घोषणा क" तारीख/Date Of Pronouncement : 28/01/2025 आदेश आदेश / O R D E R आदेश आदेश Per Bench : This Is An Appeal Filed By The Assessee Against The Order Dated 07.03.2024, Passed By The Cit(A), National Faceless Appeal Centre (Nfac), Delhi In Din & Order No.Itba/Nfac/S/250/2023- 24/1062168195(1) For The Assessment Year 2016-2017, On The Following Grounds :- 1. Hon'Ble Cit(Appeals), Nfac Has Erred In Law & On Facts In Confirming The Action Of The Learned Ao Even Though The Learned Ao Has Exceeded His Jurisdiction In A Limited Scrutiny Case Selected Under Cass Only To Examine Whether The Investment & Income Relating To Securities Transactions Are Duly Disclosed Or Not & Added A Sum Of Rs.44,00,000.00 U/S 68 Of The Income Tax Act, 1961, Without Obtaining Prior Administrative Approval Of The Concerned Pr. Cit/Cit As Prescribed In Circular F. No. 225/402/2018/Ita.Ii, Dated 28- 11-2018 & Instruction No.5/2016 [F.No.225/269/2015-

TDS and Name and address of Principal Tax deductors, if any. 3.1.29. The appellant, vide 5th 142(1) notice dated 23.10.2018, was asked for the 1 time to explain the source of investment in Kotak Securities, and this point was reiterated in all the subsequent 142(1) notices. 3.1.30. At the cost of repetition, it must be mentioned here that

SMT. PURNIMA DAS,BHUBANESWAR vs. PR. CIT-1,, BHUBANESWAR

Bench: S/Shri George Mathan & Arun Khodpiaassessment Year : 2017-18 Smt. Purnima Das, C/O. Vs. Pr. Cit, Bhubaneswar-1. Biswajit Das, At-9, Budha Nagar, Budheswari, Bhubaneswar. Pan/Gir No.Aazpd0112 B (Appellant) .. ( Respondent) Assessee By : Shri P.K.Mishra, Ar Revenue By : Shri M.K.Gautam, Cit Dr Date Of Hearing : 16/02/2023 Date Of Pronouncement : 16/02/2023 O R D E R Per Bench This Is An Appeal Filed By The Assessee Against The Order Of The Ld Pr.Cit Passed U./S.263 Of The Act, Dated 12.3.2022 In Appeal No. Itba/Rev/F/Reev5/2021-22/10540634159(1) For The Assessment Year 2017-18. 2. Shri P.K.Mishra, Ld Ar Appeared For The Assessee Assisted By Ms.Sugyanee Kuanr & Ms. Simran Samal, Intern From Birla School Of Law (Bgu), Bhubaneswar & Shri M.K.Gautam, Ld Cit Dr Appeared For The Revenue Assisted By Shri Dharmashoka Panda, Intern From Birla School Of Law (Bgu), Bhubaneswar. 3. It Was Submitted By Ld Ar That The Assessee Is An Individual, Who Is A Professor Of Mathematics At P.N.College, Khurda. The Assessee Had Filed Her Return Of Income For The Relevant Assessment Year On 5.8.2017

cash during demonetization period. When, Government declared ban on utilization of old denomination of Rs.500/- and Rs.1,000/-, your Assessee had no other option than to deposit it in bank. Further, your Assessee submits herewith copies of Agreement towards Booking of flat, possession letter, purchase deed and sale deed of flat and the confirmation letter received from the so called

INDERPAL SINGH CHHABRA,ROURKELA vs. ACIT, ROURKELA

In the result, appeal of the assessee is allowed

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.450/Ctk/2024 (नििाारण वर्ा / Assessment Year : 2018-2019) Inderpal Singh Chhabra Vs Acit, Circle Rourkela Prop: Essar Enterprises Daily Market, C/O Crazy Cool, Main Rd, Po/Ps : Rourkela, Dist : Sundargarh Pan No. :Ajlpc 6337 J (अपीलार्थी /Appellant) (प्रत्यर्थी / Respondent) .. नििााररती की ओर से /Assessee By : Shri P.K.Mishra & Shri Baidyanath Behera, Advocates राजस्व की ओर से /Revenue By : Shri Sanjay Kumar, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 08/04/2025 घोषणा की तारीख/Date Of Pronouncement : 08/04/2025 आदेश / O R D E R Per Bench : This Is An Appeal Filed By The Assessee Against The Order Of The Ld Cit(A), Nfac, Delhi Dated 04.09.2024 In Din & Order No.Itba/Nfac/S/250/2024-25/1068345718(1)), For The Assessment Year 2018-19. 2. Shri P.K.Mishra, Advocate Appeared On Behalf Of The Assessee. Shri Sanjay Kumar, Ld Cit Dr Represented On Behalf Of The Revenue. 3. The Assessee Is Engaged In The Transportation Of Coal & Trading In Coals. It Was Submitted By Ld Ar That The Original Return Filed By The Assessee Came To Be Processed U/S.143(3) Of The Act By The Nfac & The Assessment Came To Be Completed On 10.02.2021 Accepting The Returned Income. Ld Ar Drew Our Attention To Page 3 Of The Paper Book

deposited for relevant expenses debited to P&L account and also file copy of TDS returnalong with challans 12. Please furnish Month wise and party wise sales & purchases with complete postal address. 13. Please provide the details of opening & closing stock quantity & quality wise and basis of valuation of closing stock, supported with documentary evidence. 14. Please furnish copy

DEPUTY COMMISSIONER OF INCOME TAX, CORPORATE CIRCLER-1(1), BHUBANESWAR, BHUBANESWAR vs. M/S.LAND & WATER PROJECTS PVT. LIMITED, BHUBANESWAR

In the result, appeal of the Revenue is dismissed

Bench: Shri S.S.Godara, Jm & Shri L.P. Sahu, Am (Through : Virtual Hearing) आयकर अपीऱ सं./Ita No.424/Ctk/2018 (नििाारण वषा / Assessment Year :2013-2014) Dcit, Corporate Circle-1(1), Vs. M/S Land & Water Projects Bhubaneswar Pvt. Ltd., Plot No.14(W), Ashok Nagar Bhubaneswar-751002 स्थायी ऱेखा सं./Panno. : Aabcl 6312 N (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. राजस्व की ओर से /Revenue By : Shri Subhendu Dutta, Dr ननधााररती की ओर से /Assessee By : Shri P.C.Sethi, Advocate

TDS not deposited), employees contribution to EPF of Rs.1,61,987/- and employee contribution of ESIC of Rs.27,209/- (not paid) in the total income. After test checked of the bills/vouchers produced by the assessee and also verifying the depreciation claimed by the assessee, completed the assessment making following additions i) disallowance on account of unexplained cash

SRI CHITTARANJAN JENA,PIPIL vs. ITO WARD, PURI

In the result, appeal of the assessee stands partly allowed for statistical purposes

Bench: Before Shri George Mathan, Judicialassessment Year : 2017-18 Chitaranjan Ranjan Jena, Jena, Vs. Ito, Ward, Puri. Ito, Ward, Puri. Pubasasan, K Pubasasan, Kausal Ganga, Pipili, Bhubaneswar. Pipili, Bhubaneswar. Pan/Gir No. Pan/Gir No.Ajpkj 5787 A (Appellant (Appellant) .. ( Respondent Respondent)

TDS. 7. Ld AR submitted that the Ground No.7 is general ground raised and consequently, this issue should be considered by the Tribunal. 8. I have considered the rival submissions. As rightly pointed out by ld Sr DR that no specific ground in respect of the interest has been raised and it has also been pointed

BRIG.NARAYAN NAYAK,BHUBANESWAR vs. DCIT, CIRCLE-5(1), BHUBANESWAR

In the result, ITA No.30/CTK/2017 is partly allowed for

Bench: Shri C.M. Garg, Jm & Shri L.P. Sahu, Am आयकर अपीऱ सं./Ita No.30/Ctk/2017 & आयकर अपीऱ सं./Ita No.230/Ctk/2019 (नििाारण वषा / Assessment Year :2012-2013) Brig. Narayan Nayak, Vs. Dcit, Circle-5(1), Prop: M/S Industrial Security & Bhubaneswar Allied Services, F3-F5, Id Market, Irc Village, Nayapalli, Bhubanesar-751015 स्थायी लेखा सं./Pan No. : Abapn 3373 Q (अऩीलाथी /Appellant) (प्रत्यथी / Respondent) .. ननधाारिती की ओर से /Assessee By : Shri P.K.Sahoo, Ca िाजस्व की ओर से /Revenue By : Shri Subhendu Dutta, Dr सुनवाई की तािीख / Date Of Hearing : 25/02/2020 घोषणा की तािीख/Date Of Pronouncement : 05/06/2020 आदेश / O R D E R Per L.P.Sahu, Am: The Assessee Has Filed The Above Two Appeals, One Is Against The Order Passed By The Cit(A)-2, Dated 27.10.2016 Arising Out Of The Order Passed By The Ao U/S.143(3) Of The Act & Another Is Against The Order Passed By The Cit(A)-2, Bhubaneswar, Dated 14.04.2019 Arising Out Of The Order Passed By The Ao U/S.271(1)(C) Of The Act. 2. First We Shall Take Up The Appeal Of The Assessee In Ita No.30/Ctk/2017, Wherein The Assessee Has Raised The Following Grounds :-

cash credit is illegal, bad in law, contrary to the rule and circumstances of the case. During the course of hearing before the Assessing officer, Identity cards (I. Card) of employees were produced. The unsecured loan accepted from employees is very nominal and that is treated as a security money kept with the employer and paid back when they left

BRIG. NARAYAN NAYAK,BHUBANESWAR vs. ACIT-5(1), BHUBANESWAR

In the result, ITA No.30/CTK/2017 is partly allowed for

Bench: Shri C.M. Garg, Jm & Shri L.P. Sahu, Am आयकर अपीऱ सं./Ita No.30/Ctk/2017 & आयकर अपीऱ सं./Ita No.230/Ctk/2019 (नििाारण वषा / Assessment Year :2012-2013) Brig. Narayan Nayak, Vs. Dcit, Circle-5(1), Prop: M/S Industrial Security & Bhubaneswar Allied Services, F3-F5, Id Market, Irc Village, Nayapalli, Bhubanesar-751015 स्थायी लेखा सं./Pan No. : Abapn 3373 Q (अऩीलाथी /Appellant) (प्रत्यथी / Respondent) .. ननधाारिती की ओर से /Assessee By : Shri P.K.Sahoo, Ca िाजस्व की ओर से /Revenue By : Shri Subhendu Dutta, Dr सुनवाई की तािीख / Date Of Hearing : 25/02/2020 घोषणा की तािीख/Date Of Pronouncement : 05/06/2020 आदेश / O R D E R Per L.P.Sahu, Am: The Assessee Has Filed The Above Two Appeals, One Is Against The Order Passed By The Cit(A)-2, Dated 27.10.2016 Arising Out Of The Order Passed By The Ao U/S.143(3) Of The Act & Another Is Against The Order Passed By The Cit(A)-2, Bhubaneswar, Dated 14.04.2019 Arising Out Of The Order Passed By The Ao U/S.271(1)(C) Of The Act. 2. First We Shall Take Up The Appeal Of The Assessee In Ita No.30/Ctk/2017, Wherein The Assessee Has Raised The Following Grounds :-

cash credit is illegal, bad in law, contrary to the rule and circumstances of the case. During the course of hearing before the Assessing officer, Identity cards (I. Card) of employees were produced. The unsecured loan accepted from employees is very nominal and that is treated as a security money kept with the employer and paid back when they left

M/S KHANDELWAL STEEL & PIPES,BHUBANESWAR vs. ACIT, CUTTACK

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

Bench: Shri C.M. Garg, Jm & Shri L.P. Sahu, Am आयकर अपीऱ सं./Ita No.138/Ctk/2019 (नििाारण वषा / Assessment Year :2012-2013) M/S Khandelwal Steel & Pipes, Vs. Dcit, Circle-4(1), 614, Bomikhal, Cuttack Puri Rd Bhubaneswar Bhubanewswar-751010 स्थायी लेखा सं./Panno. : Aagfk 7718 R (अऩीलाथी /Appellant) (प्रत्यथी / Respondent) .. ननधाारिती की ओर से /Assessee By : Shri Shadiram Sharma, Advocate िाजस्व की ओर से /Revenue By : Shri J.K.Lenka, Dr

deposited TDS amount only in the previous year in which such payment was made to the government. [Para 16]” 9. On careful perusal of the amendment brought to the Section 40(a)(ia) of the Act by the Finance Act, 2014 w.e.f. 01.04.2015, it is clear that the intent of legislature to reduce the hardship, it is proposed that

SISKHA 'O' ANUSANDHAN,BHUBANESWAR vs. CIT (EXEMPTION), , HYDERABAD

In the result, appeal of the assessee is allowed

Bench: Shri George Mathan & Shri Arun Khodpiaआयकर अऩीऱ सं/Ita No.91/Ctk/2022 (ननधाारण वषा / Assessment Year :2017-2018) Siksha ‘O’ Anusandhan Vs Cit(Exemption), Hyderabad Plot No.224, Dharma Vihar, Khandagiri, Bhubaneswar Pan No. :Aabts 1525 R (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

cash deposits made during demonetization period and explanations offered in course of assessment, Ld. Assessing officer being satisfied completed the assessment by accepting the return of income of the assessee. 4. That there after the CIT(exemption) Hyderabad called for the assessment record of the A/Y -2017-18 for examination and after examination found the order dated 25.07.2019 passed

KISHAN MOTORS,BHUBANESWAR vs. ITO, WARD-4(3), BHUBANESWAR

In the result, appeal in ITA No

Bench: Shri Chandra Mohan Garg & Laxmi Prasad Sahu

TDS on payments made to residents as specified in section 40(a)(ia) of the Act, the disallowance shall be restricted to 30% of the amount of expenditure claimed. The Hon’ble Supreme Court in the case of Allied Motors (P) Ltd. [1997] 224 ITR 677 (SC) has held that amendment was remedial in nature, designed to eliminate unintended

ACIT, RORUKELA CIRCLE, ROURKELA vs. INDRANI PATNAIK, ROURKELA

In the result, appeals of the revenue for assessment years 2012-13 &

Bench: Shri Chandra Mohan Garg & Laxmi Prasad Sahu

TDS was deducted and deposited into the government account and the copies of income tax returns in support of the tax being deposited by the commission agents. It is also not in dispute that the similar commission payment has been made in earlier years and also in the present assessment year. 17. As regards to the decisions relied upon