DCIT, CORPORATE CIRCLE-1(1), BHUBANESWAR vs. M/S. GRIDCO LIMITED, BHUBANESWAR

In the result, appeal of the revenue stands dismissed

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaassessment Year :2010-2011 2011 Dcit, Corporate Circle Dcit, Corporate Circle-1(1), Vs. Grid Corporation Of Orissa Grid Corporation Of Orissa Bhubaneswar Bhubaneswar Ltd., Ltd., Gridco Gridco House, House, Janapath, Bhubaneswar Janapath, Bhubaneswar. Pan/Gir No. Pan/Gir No.Aabcg 5398 P (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : S/Shri Ved Jain/P.Venugopal Rao /P.Venugopal Rao, Ars Revenue By : Shri M.K.Gautam, M.K.Gautam, Cit Dr Date Of Hearing : 20/0 02/2023 Date Of Pronouncement : 20/0 /02/2023 O R D E R Per Bench This Is An Appeal Filed By The Revenue Against The Order Of The Ld Against The Order Of The Ld Cit(A)-1, Bhubaneswar, 1, Bhubaneswar, Dated 9.5.2016 In Appeal No. In Appeal No.0493/14-15 For The Assessment Year Assessment Year 2010-2011. 2. S/Shri Ved Jain & P.Venugopal Rao, S/Shri Ved Jain & P.Venugopal Rao, Ld Ar Ld Ars Appeared For The Assessee & Shri M.K.Gautam, Ld Cit Dr Appeared For The Revenue. Assessee & Shri M.K.Gautam, Ld Cit Dr Appeared For The Revenue. Assessee & Shri M.K.Gautam, Ld Cit Dr Appeared For The Revenue.

10. Section 194J of the Act has only indicated that for the purpose of that section, fees for technical services would be as defined in section 9(1)(vii) of the Act. On considering that definition and what is involved in the proper transmission of the electrical energy as involved in this case. I am satisfied that the transmission involves

NESCO EMPLOYEES GRATUITY FUND TRUST,BALASORE vs. ITO, WARD-1, BALASORE, BALASORE

In the result, appeal of the assessee is allowed for statistical\npurposes

TDS. The CPC processed the return u/s\n143(1) of the Act on 02.01.2018 and disallowed the claim of exemption and\nraised a demand. Against the intimation, a rectification application u/s 154\nwas filed on behalf of the assessee by its authorized representative on\n24.08.2023 stating therein that the trust was eligible for exemption and that\nit was claimed wrongly

OMM SHREE REALCON PVT. LTD,BHUBANESWAR vs. PR.CIT-1, BHUBANESWAR

In the result, appeal of the assessee stands allowed

Bench: Before S/Shri George Mathan, Judicial & And Rajesh Kumarassessment Year : 2018-19 Om Shree Realcon Pvt Ltd., Om Shree Realcon Pvt Ltd., Vs. Pr. Cit- Bhubaneswar Bhubaneswar-1 Plot No.418, Forest Park, 8, Forest Park, Bhubaneswar. Bhubaneswar. Pan/Gir No. Pan/Gir No.Aabco 3118 P (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri S.K.Sarangi, Ca S.K.Sarangi, Ca Revenue By : Shri M.K.Gautam, Pr. Cit (Osd) Pr. Cit (Osd) Date Of Hearing : 28 /0 06/2023 Date Of Pronouncement : 28 /0 /06/2023 O R D E R Per Bench

10. Copy of Form 26AS and reconciliation of details as per Form 26AS and as per profit & loss account, wherever necessary. 11. Copy of TDS return filed for relevant period alongwith copy of TDS entry register. 12. Ledger –advance for land, other current assets, interest, architect fees. 13. Project-wise detail of break up of salary *& wages debited

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

10. Please provide the list of sundry debtors and sundry creditors with name, address and PAN 11. Provide details of TDS deducted and 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

ARCHITECTURE AND ENGINEERING CONSULTANCY SERVICES PRIVATE LIMITED,BHUBANESWAR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2 BHUABENSWAR, BHUBANESWAR

10-Aug-2018\nCentralized Processing Cell TDS Reconciliation Analysis and Correction Enabling System\nForm 26AS\nAnnual Tax Statement under Section

M/S. GRID CORPORATION OF ORISSA LIMITED,BHUBANESWAR vs. ACIT-(TDS), BHUBANESWAR

In the result, appeal of the assessee stands allowed

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaassessment Year : 2009-2010 2010 Grid Corporation Of Orissa Grid Corporation Of Orissa Vs. Acit (Tds), Acit (Tds), Ltd., Ltd., Gridco Gridco House, House, Bhubaneswar. Bhubaneswar. Janapath, Bhubaneswar. Janapath, Bhubaneswar. Pan/Gir No. Pan/Gir No.Aabcg 5398 P (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : S/Shri Ved Jain/P.Venugopal Rao /P.Venugopal Rao, Ars Revenue By : Shri M.K.Gautam, M.K.Gautam, Cit Dr Date Of Hearing : 20/0 02/2023 Date Of Pronouncement : 20/0 /02/2023 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 Cit(A)-1, Bhubaneswar, 1, Bhubaneswar, Dated 12.7.2019 In Appeal No. In Appeal No.0035/17-18 For The Assessment Year The Assessment Year 2009-2010. 2. S/Shri Ved Jain & P.Venugopal Rao, S/Shri Ved Jain & P.Venugopal Rao, Ld Ar Ld Ars Appeared For The Assessee & Shri M.K.Gautam, Ld Cit Dr Appeared For The Revenue. Assessee & Shri M.K.Gautam, Ld Cit Dr Appeared For The Revenue. Assessee & Shri M.K.Gautam, Ld Cit Dr Appeared For The Revenue.

10 | 11 Assessment Year : 2009-2010 in the issuance of the refund under section 244A(2) as also on the ground that the issue is highly debatable issue, we are of the view that the order passed u/s.154 is unsustainable and consequently, the order of the Assessing Officer and that of the ld CIT(A) stands quashed

INCOME TAX OFFICER, WARD-1, ROURKELA, ROURKELA ODISHA vs. CHANDAN TRANSCONS PVT LTD, ROURKELA ODISHA

In the result, appeals of the revenue stand dismissed

Bench: Before Shri George Mathan, Judicial & Manish Agarwal Manish Agarwalita Nos.14 & 15 /Ctk/2024 24 Assessment Year Assessment Years : 2008-09 & 2009 09 & 2009-2010 M/S. Chandan Trans M/S. Chandan Trans-Cons Pvt Vs. Dcit, Rourkela Circle, Rourkela Dcit, Rourkela Circle, Rourkela Ltd., At-Ff/2, Civil Township, Ff/2, Civil Township, Rourkela, Dist: Sundargarh Rourkela, Dist: Sundargarh Pan/Gir No Pan/Gir No.Aaccc 5185 B (Appellant (Appellant) .. ( Respondent Respondent)

section 40(a)(ia) of the Act, 30% disallowance is liable to be made only in respect of Rs.2,70,239/-. In respect of ITA No.15/CTK/2024 for A.Y. 2009- 10, as no TDS

M/S. CHANDAN TRANS-CONS PVT. LTD,ROURKELA vs. DCIT, ROURKELA CIRCLE, ROURKELA

In the result, appeals of the revenue stand dismissed

Bench: Before Shri George Mathan, Judicial & Manish Agarwal Manish Agarwalita Nos.14 & 15 /Ctk/2024 24 Assessment Year Assessment Years : 2008-09 & 2009 09 & 2009-2010 M/S. Chandan Trans M/S. Chandan Trans-Cons Pvt Vs. Dcit, Rourkela Circle, Rourkela Dcit, Rourkela Circle, Rourkela Ltd., At-Ff/2, Civil Township, Ff/2, Civil Township, Rourkela, Dist: Sundargarh Rourkela, Dist: Sundargarh Pan/Gir No Pan/Gir No.Aaccc 5185 B (Appellant (Appellant) .. ( Respondent Respondent)

section 40(a)(ia) of the Act, 30% disallowance is liable to be made only in respect of Rs.2,70,239/-. In respect of ITA No.15/CTK/2024 for A.Y. 2009- 10, as no TDS

INCOME TAX OFFICER, WARD 1, ROURKELA, ROURKELA, ODISHA vs. CHANDAN TRANSCONS PRIVATE LIMITED, ROURKELA, ODISHA

In the result, appeals of the revenue stand dismissed

Bench: Before Shri George Mathan, Judicial & Manish Agarwal Manish Agarwalita Nos.14 & 15 /Ctk/2024 24 Assessment Year Assessment Years : 2008-09 & 2009 09 & 2009-2010 M/S. Chandan Trans M/S. Chandan Trans-Cons Pvt Vs. Dcit, Rourkela Circle, Rourkela Dcit, Rourkela Circle, Rourkela Ltd., At-Ff/2, Civil Township, Ff/2, Civil Township, Rourkela, Dist: Sundargarh Rourkela, Dist: Sundargarh Pan/Gir No Pan/Gir No.Aaccc 5185 B (Appellant (Appellant) .. ( Respondent Respondent)

section 40(a)(ia) of the Act, 30% disallowance is liable to be made only in respect of Rs.2,70,239/-. In respect of ITA No.15/CTK/2024 for A.Y. 2009- 10, as no TDS

M/S. CHANDAN TRANS-CONS PVT. LTD,ROURKELA vs. DCIT,ROURKELA CIRCLE, ROURKELA

In the result, appeals of the revenue stand dismissed

Bench: Before Shri George Mathan, Judicial & Manish Agarwal Manish Agarwalita Nos.14 & 15 /Ctk/2024 24 Assessment Year Assessment Years : 2008-09 & 2009 09 & 2009-2010 M/S. Chandan Trans M/S. Chandan Trans-Cons Pvt Vs. Dcit, Rourkela Circle, Rourkela Dcit, Rourkela Circle, Rourkela Ltd., At-Ff/2, Civil Township, Ff/2, Civil Township, Rourkela, Dist: Sundargarh Rourkela, Dist: Sundargarh Pan/Gir No Pan/Gir No.Aaccc 5185 B (Appellant (Appellant) .. ( Respondent Respondent)

section 40(a)(ia) of the Act, 30% disallowance is liable to be made only in respect of Rs.2,70,239/-. In respect of ITA No.15/CTK/2024 for A.Y. 2009- 10, as no TDS

GANESH ORES PRIVATE LIMITED,CIVIL TOWNSHIP,ROURKELA vs. ASST COMMISSIONER OF INCOME TAX, ROURKELA CIRCLE,ROURKELA

In the result, appeals of the assessee stand partly allowed for statistical purposes

Bench: Before Shri George Mathan, Judicial & Manish Agarwal Manish Agarwalita Nos.44 & 45 /Ctk/2024 24 Assessment Years : 2015-16 & 2016 16 & 2016-17

TDS had also been deducted on the interest paid, the addition as made by the AO is liable to be deleted. 5. It was also the submission that the Assessing Officer having made the addition during the assessment year 2015-16, did not consider the corresponding effect in the assessment year 2016-17, when the same had been repaid

GANESH ORES PRIVATE LIMITED,CIVIL TOWNSHIP ROURKELA vs. ASST COMMISSIONER OF INCOME TAX, ROURKELA CIRCLE,ROURKELA

In the result, appeals of the assessee stand partly allowed for statistical purposes

Bench: Before Shri George Mathan, Judicial & Manish Agarwal Manish Agarwalita Nos.44 & 45 /Ctk/2024 24 Assessment Years : 2015-16 & 2016 16 & 2016-17

TDS had also been deducted on the interest paid, the addition as made by the AO is liable to be deleted. 5. It was also the submission that the Assessing Officer having made the addition during the assessment year 2015-16, did not consider the corresponding effect in the assessment year 2016-17, when the same had been repaid

M/S. BAJRANGBALI STEEL INDUSTRIES PVT. LTD,ROURKLA vs. ACIT, CENTRAL CIRCLE, SAMBALPUR

In the result, appeals of the assessee in IT(SS)A No

Bench: Shri George Mathan & Shri Arun Khodpiaआयकर अऩीऱ (तऱाशियाां और अशिग्रहण)/It(Ss)A Nos.31 To 33/Ctk/2022 (ननधाारण वषा / Assessment Year : 2016-2017 To 2018-2019) M/S Bee Pee Rollers Pvt. Ltd., Vs Acit, Central Circle, Sambalpur Lal Building, Kachery Road, Rourkela, Sundergarh, Odisha-769012 Pan No. :Aabcb 3593 P & आयकर अऩीऱ (तऱाशियाां और अशिग्रहण)/It(Ss)A Nos.34 To 39/Ctk/2022 & आयकर अऩीऱ/Ita No.109/Ctk/2022 (ननधाारण वषा / Assessment Year : 2014-2017 To 2020-2021) M/S Bajrangbali Steel Industries Pvt. Vs Acit, Central Circle, Sambalpur Ltd., Lal Building, Kachery Road, Rourkela, Sundergarh, Odisha-769012 Pan No. :Aabcb 3594 L & आयकर अऩीऱ (तऱाशियाां और अशिग्रहण)/It(Ss)A Nos.40 To 44/Ctk/2022 (ननधाारण वषा / Assessment Year : 2014-2015 To 2018-2019) M/S Bajrangbali Re-Rollers Pvt. Ltd. Vs Acit, Central Circle, Sambalpur Lal Building, Kachery Road, Rourkela, Sundergarh, Odisha-769012 Pan No. :Aaccb 6678 A (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. ननधााररती की ओर से /Assessee By : Shri S.K.Tulsiyan, Advocate With Shri B.K. Tibrewal, Ca & Ms. Nisha Rachh, Ca Shri M.K.Gautam, Pr.Cit(Osd) राजस्व की ओर से /Revenue By : सुनवाई की तारीख / Date Of Hearing : 28/03/2023 घोषणा की तारीख/Date Of Pronouncement : 28/03/2023

section 142(2) are important and assessment is not to be done on the 22 IT(SS)A No.31-44/CTK/2022 & ITA No.109/CTK/2022 basis of information. Information is only a starting point of investigation. It is incumbent upon the Assessing officer as the assessing authority has to do independent examination of the information. Unfortunately, this independent examination is conspicuous by its absence

PRAFULLA KUMAR ROUTRAY,BHUBANESWAR vs. ACIT, INTERNATIONAL TAXATION, BHUBANESWAR, BHUBANESWAR

In the result, the appeal filed by the assessee is dismissed

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

10,000/- as unexplained money under Section 69A as made by the learned Assessing Officer is not correct on the facts and in the circumstances of the case. 4. For that disallowance of cost of acquisition of the property at Rs. 1,57,53,865/-and claim of deduction of Rs.82,46,135/- u/s.54 totalling to Rs.2

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

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