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

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

INCOME TAX OFFICER WARD-1, BARIPADA, BARIPADA vs. MAYURBHANJ CENTRAL COOPERATIVE BANK LIMITED, BARIPADA

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

Bench: Before Shri George Mathan, Judicial & Manish Agarwal Manish Agarwal

TDS. However, since the assessee is a co- operative bank, therefore, this exemption is not applicable to it. He further stated that from 1.6.2015, this anomaly has been removed and it is clearly provided that the cooperative banks are not eligible for this exemption. He accordingly, submitted that the assessee bank has not deducted tax at source on the payment

INCOME TAX OFFICER WARD-1 BARIPADA, BARIPADA vs. MAYURBHANJ CENTRAL COOPERATIVE BANK LIMITED, BARIPADA

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

Bench: Before Shri George Mathan, Judicial & Manish Agarwal Manish Agarwal

TDS. However, since the assessee is a co- operative bank, therefore, this exemption is not applicable to it. He further stated that from 1.6.2015, this anomaly has been removed and it is clearly provided that the cooperative banks are not eligible for this exemption. He accordingly, submitted that the assessee bank has not deducted tax at source on the payment

INCOME TAX OFFICER, WARD-1, BARIPADA, BARIPADA vs. MAYURBHANJ CENTRAL CO-OPERATIVE BANK LIMITED, BARIPADA

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

Bench: Before Shri George Mathan, Judicial & Manish Agarwal Manish Agarwal

TDS. However, since the assessee is a co- operative bank, therefore, this exemption is not applicable to it. He further stated that from 1.6.2015, this anomaly has been removed and it is clearly provided that the cooperative banks are not eligible for this exemption. He accordingly, submitted that the assessee bank has not deducted tax at source on the payment

INCOME TAX OFFICER, BARIPADA vs. MAYURBHANJ CENTRAL COOPERATIVE BANK LIMITED, BARIPADA

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

Bench: Before Shri George Mathan, Judicial & Manish Agarwal Manish Agarwal

TDS. However, since the assessee is a co- operative bank, therefore, this exemption is not applicable to it. He further stated that from 1.6.2015, this anomaly has been removed and it is clearly provided that the cooperative banks are not eligible for this exemption. He accordingly, submitted that the assessee bank has not deducted tax at source on the payment

INCOME TAX OFFICER, WARD-1, BARIPADA, BARIPADA vs. MAYURBHANJ CENTRAL CO-OPERATIVE BANK LIMITED, BARIPADA

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

Bench: Before Shri George Mathan, Judicial & Manish Agarwal Manish Agarwal

TDS. However, since the assessee is a co- operative bank, therefore, this exemption is not applicable to it. He further stated that from 1.6.2015, this anomaly has been removed and it is clearly provided that the cooperative banks are not eligible for this exemption. He accordingly, submitted that the assessee bank has not deducted tax at source on the payment

SAROJ KUMAR SWAIN,KHORDA vs. INCOME TAX OFFICER, KHORDA WARD, KHORDA, KHORDA

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

Bench: Shri George Mathanआयकर अपील सं/Ita No. 162/Ctk/2025 (िनधा"रण वष" / Assessment Year : 2017-2018) Saroj Kumar Swain Vs Ito, Khurda Ward,Khurda At/P.O:- Banga, Kudiary, Delanga, Jatni, Khurda, 752050 Pan No. : Azlps 4330 H (अपीलाथ" /Appellant) .. (""यथ" / Respondent) िनधा"रती क" ओर से /Assessee By : Shri, S.K. Agrawalla, Ar राज"व क" ओर से /Revenue By : Shri Vijay Singh, Sr. D.R. सुनवाई क" तारीख / Date Of Hearing : 24/09/2025 घोषणा क" तारीख/Date Of Pronouncement : 24/09/2025 आदेश / O R D E R

cash deposits in the assessee’s bank account to an extent of Rs.17,65,000/- during the demonetization period and had consequently treated the same as deposit of specified bank notes and treated the same as undisclosed income of the assessee. It was the submission that the assessee had deposited only Rs.1,44,000/- in specified bank notes

HADIBANDHU PRADHAN,ANGUL vs. INCOME TAX OFFICER, ANGUL WARD, ANGUL, ANGUL

In the result, appeal stands partly allowed

Bench: Before Shri George Mathan, Judicialassessment Year : 2017-18 Hadibandhu Pradhan Hadibandhu Pradhan, S/O- Vs. Income Tax Officer, Income Tax Officer, Udayanath Pradhan, At/Po: Udayanath Pradhan, At/Po: Angul Ward, Angul Angul Ward, Angul Dera, Talcher, Dist: Angul Dera, Talcher, Dist: Angul- 759103 Pan/Gir No Pan/Gir No.Adwpp 5210 A (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri P.K.Mishra, Adv P.K.Mishra, Adv Revenue By : Shri S.C.Mohanty, Ld Sr Dr : Shri S.C.Mohanty, Ld Sr Dr Date Of Hearing : 02/0 04/2024 Date Of Pronouncement : 02/0 /04/2024 O R D E R This Is An Appeal Filed By The Assessee Aga This Is An Appeal Filed By The Assessee Against The Order Of The Ld Inst The Order Of The Ld Cit(A), Nfac, Delhi Cit(A), Nfac, Delhi Dated 20.9.2023 In Appeal No. In Appeal No.Cit(A),Bhubaneswar- 2/10141/2019 2/10141/2019-19 For The Assessment Year 2017-18 .

cash. The transaction admittedly has not gone through. Obviously, the assessee has received back the money, which represents the advance given on 17.6.2016 & 18.6.2016, need not be in the same demonetization currency. Thus, one cannot take the stand that same currency has to be deposited and if this presumption is considered, then obviously, the amount deposited by the assessee

KENDRAPARA URBAN CO-OPERATIVE BANK LTD.,KENDRAPADA vs. PR.COMMISSIONER OF INCOME TAX, CUTTACK

In the result, appeal of the assessee stands allowed

Bench: Shri George Mathan & Shri Arun Khodpiaआयकर अऩीऱ सं/Ita No.163/Ctk/2020 (ननधाारण वषा / Assessment Year :2015-2016) Kendrapara Urban Co-Operative Vs Pr.Cit, Cuttack Bank Ltd., College Square, Tinimuhani, Kendrapara-754211 Pan No. :Aaatk 8347 E (अऩीऱाथी /Appellant) .. (प्रत्यथी / Respondent) ननधााररती की ओर से /Assessee By : Shri P.C.Sethi, Advocate राजस्व की ओर से /Revenue By : Shri M.K.Gautam, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 30/01/2023 घोषणा की तारीख/Date Of Pronouncement : 30/01/2023 आदेश / O R D E R Per Bench : This Is An Appeal Filed By The Assessee Against The Order Of The Ld Pr.Cit, Cuttack, Dated 24.03.2020, Passed In Din & Order No.Itba/Com/F/17/2019-20/1026884702(1) For The Assessment Year 2015-2016. 2. The Appeal Of The Assessee Is Barred By 8 Days. The Assessee Through Its Secretary Has Filed An Application Dated 13.07.2020 Stating Therein Sufficient Reasons For Condonation Of Delay, To Which Ld. Cit-Dr Did Not Object. In View Of The Above, Delay Of 8 Days In Filing The Present Appeal Is Condoned & The Appeal Of The Assessee Is Heard Finally. 3. It Was Submitted By The Ld. Ar That The Original Assessment In The Case Of The Assessee Was Completed U/S.143(3) Of The Act On 20.11.2017. It Was The Submission That The Assessment Was A Limited Scrutiny

deposited large amount of cash in savings bank account. 03. Large interest expenses relatable to exempt income (u/s.14A) 4. It was the submission that the ld. Pr.CIT invoked his powers u/s.263 of the Act for the purpose of examining the issues in relation to the exemption under the provision of bad and doubtful debts u/s.36(1)(viia