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

7. The issue here concerns the interplay of Section 2(24)(x) of the Act read with Section 36(1)(va) of the Act alongside provisions of the Employees‟ Provident Funds and Miscellaneous Provisions Act, 1952 (especially Regulation 38 of the Employees‟ Provident Funds Scheme, 1952) and the provisions of the Employees‟ State Insurance Act, 1948. The AO had brought

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/-

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/- 2 4) That it is not correct to say that the amendment to second provision to section 40(a)(ia) with effect from 1.4.2013 is not applicable. It is settled

UTKAL GRAMYA/ GRAMEEN BANK,SAMBALPUR vs. ITO (TDS), SAMBALPUR

In the result, appeals of the assessee i

Bench: Shri C.M. Garg, Jm & Shri L.P. Sahu, Am आयकर अपीऱ सं./Ita No.190 To 192/Ctk/2019 (नििाारण वषा / Assessment Year :2010-2011 To 2012-2013) Utkal Gramya/Grameen Bank, Vs. Ito(Tds), Sambalpur Dhanupalli, Dist-Sambalpur-768005 Tan No. : Bbnb 00759 D (अऩीलाथी /Appellant) (प्रत्यथी / Respondent) .. ननधाारिती की ओर से /Assessee By : Shri P.K.Mishra, Advocate िाजस्व की ओर से /Revenue By : Shri J.K.Lenka, Dr

TDS) within the time-limit specified in sub-section (2) of section 197A, that was a distinct omission or default for which a penalty 9 ITA Nos.190-192/CTK/2019 is prescribed Section 273B provides that no penalty shall be imposed under any of the clauses of sub-section (2) of section 272A for the delay, if the assessee proves that there

UTKAL GRAMYA/ GRAMEEN BANK,SAMBALPUR vs. ITO (TDS), SAMBALPUR

In the result, appeals of the assessee i

Bench: Shri C.M. Garg, Jm & Shri L.P. Sahu, Am आयकर अपीऱ सं./Ita No.190 To 192/Ctk/2019 (नििाारण वषा / Assessment Year :2010-2011 To 2012-2013) Utkal Gramya/Grameen Bank, Vs. Ito(Tds), Sambalpur Dhanupalli, Dist-Sambalpur-768005 Tan No. : Bbnb 00759 D (अऩीलाथी /Appellant) (प्रत्यथी / Respondent) .. ननधाारिती की ओर से /Assessee By : Shri P.K.Mishra, Advocate िाजस्व की ओर से /Revenue By : Shri J.K.Lenka, Dr

TDS) within the time-limit specified in sub-section (2) of section 197A, that was a distinct omission or default for which a penalty 9 ITA Nos.190-192/CTK/2019 is prescribed Section 273B provides that no penalty shall be imposed under any of the clauses of sub-section (2) of section 272A for the delay, if the assessee proves that there

UTKAL GRAMYA/ GRAMEEN BANK,SAMBALPUR vs. ITO (TDS), SAMBALPUR

In the result, appeals of the assessee i

Bench: Shri C.M. Garg, Jm & Shri L.P. Sahu, Am आयकर अपीऱ सं./Ita No.190 To 192/Ctk/2019 (नििाारण वषा / Assessment Year :2010-2011 To 2012-2013) Utkal Gramya/Grameen Bank, Vs. Ito(Tds), Sambalpur Dhanupalli, Dist-Sambalpur-768005 Tan No. : Bbnb 00759 D (अऩीलाथी /Appellant) (प्रत्यथी / Respondent) .. ननधाारिती की ओर से /Assessee By : Shri P.K.Mishra, Advocate िाजस्व की ओर से /Revenue By : Shri J.K.Lenka, Dr

TDS) within the time-limit specified in sub-section (2) of section 197A, that was a distinct omission or default for which a penalty 9 ITA Nos.190-192/CTK/2019 is prescribed Section 273B provides that no penalty shall be imposed under any of the clauses of sub-section (2) of section 272A for the delay, if the assessee proves that there

MAHANADI COALFIELDS LTD.,SAMBALPUR vs. DCIT, CIRCLE-2(1), SAMBALPUR

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

Bench: Shri C.M. Garg, Jm & Shri L.P. Sahu, Am आयकर अपीऱ सं./Ita No.174/Ctk/2018 (नििाारण वषा / Assessment Year : 2015 - 2016) Mahanadi Coalfields Ltd., Vs. Dcit, Circle-2(1), Sambalpur Jagriti Vihar, Burla, Sambalpur स्थायी ऱेखा सं./Pan No. : Aabcm 5188 P (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. यनधागररती की ओर से /Assessee By : Shri S.S.Podar, Ca राजस्व की ओर से /Revenue By : Shri S.M.Keshkamat, Citdr सुनवाई की तारीख / Date Of Hearing : 15/01/2020 घोषणा की तारीख/Date Of Pronouncement : 05/06/2020 आदेश / O R D E R Per L.P.Sahu, Am :

7. That the Authorities below would have allowed the total credit of TDS. 8. That the authorities below would have accepted the returned income. 9. That the appellant craves leave to add, amend or alter the aforesaid grounds of appeal before or at the time of hearing of the appeal. 2. In addition to the above grounds of appeal

GRAM VIKAS TRUST,BERHAMPUR vs. ITO, EXEMPTION WARD, BERAMPUR

In the result, both the appeals filed by the assessee for AYs 2014-

Bench: Shri Duvvuru Rl Reddy(Kz) & Shri Rakesh Mishra

7 and uploaded Form No. 10 on 30.09.2016. The CPC, vide intimation u/s 143(1) of the Act disallowed the exemption claimed u/s 11(2) of the Act by making an addition of ₹ 10,45,000/- and raising tax liability of ₹ 1,82,680/- and tax demand of ₹ 1,70,633/- after adjustment of TDS refund claim for that year

GRAM VIKAS TRUST,BERHAMPUR vs. ITO,EXEMPTION WARD, BERAMPUR

In the result, both the appeals filed by the assessee for AYs 2014-

Bench: Shri Duvvuru Rl Reddy(Kz) & Shri Rakesh Mishra

7 and uploaded Form No. 10 on 30.09.2016. The CPC, vide intimation u/s 143(1) of the Act disallowed the exemption claimed u/s 11(2) of the Act by making an addition of ₹ 10,45,000/- and raising tax liability of ₹ 1,82,680/- and tax demand of ₹ 1,70,633/- after adjustment of TDS refund claim for that year

ITO, ANGUL WARD, ANGUL vs. NCC-SMASL-JRT(JV), ANGUL

TDS was claimed. The case was taken up for scrutiny and during the course of assessment proceedings, the AO observed that the assessee has claimed direct expenses of Rs.25,97,41,438/- i.e. the amount equivalent to the gross receipts of the assessee-JV. The said amount was paid to three Joint Ventures constituents who had executed the work

ITO, ANGUL WARD, , ANGUL vs. M/S. NCC SMASL JRT(JV),, ANGUL

TDS was claimed. The case was taken up for scrutiny and during the course of assessment proceedings, the AO observed that the assessee has claimed direct expenses of Rs.25,97,41,438/- i.e. the amount equivalent to the gross receipts of the assessee-JV. The said amount was paid to three Joint Ventures constituents who had executed the work

DCIT, CORPORATE CIRCLE-1(2), BHUBANESWAR vs. M/S. ORISSA STATE CIVIL SUPPLIES CORPORATION LTD., BHUBANESWAR

In the result, the appeal of the Revenue is dismissed

Bench: Shri Chandra Mohan Garg, Jm & Shri L.P. Sahu, Am आयकर अऩीऱ सं./Ita No.61/Ctk/2017 (नििाारण वषा / Assessment Year :2010-2011) Dcit, Corporate Circle-1(2), Vs. M/S Orissa State Civil Bhubaneswar Supplies Corporation Ltd Unit-8,Gopabandhu Nagar Bhubaneswar स्थायी ऱेखा सं./ Pan No. : Aaaco 2570 J (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

Section 40(a)(ia) of the Act for non-deduction of TDS under the particular provisions of the Income Tax Act, 1961 i.e. u/s.194H of the Act, therefore, the order of the AO should be restored. 7. On the other hand, ld.AR relied on the order of CIT(A) and submitted that the CIT(A) has rightly deleted the addition

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

2,21,506/- Rabindra Sarani, Less: Tds- P a g e 7 | 31 Assessment Year : 2018-19 Kolkata 22,151/-) P a g e 8 | 31 Assessment Year : 2018-19 6. He further drew our attention to page 46 of the paper book, which was the further enquiry by the AO in the course of ‘e’ assessment, wherein, details

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

2 n (14). Therefore, the receipt arising out of sale proceeds from such agricultural land are exempted from tax. Therefore, the claim of exemption by the Assessee being true and correct, needs to b€ accepted and it is requested not to draw any adverse inference on this issue. P a g e 5 | 47 Assessment Year : 2017-18 4. That

MAHANADI METAL AND CHEMICALS PRIVATE LIMITED,ROURKELA vs. ITO, WARD-1, ROURKELA

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

Bench: Shri C.M. Garg, Jm & Shri L.P. Sahu, Am आयकर अपीऱ सं./Ita No.496/Ctk/2017 (नििाारण वषा / Assessment Year : 2010 - 2011) M/S Mahanadi Metal & Vs. Ito, Ward-1, Rourkela Chemicals Private Limited, T/4/26/Civil Township, Rourkela-769004 स्थायी ऱेखा सं./Pan No. : Aaccm 4844 R (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. यनधागररती की ओर से /Assessee By : Shri Parimal Kumar Jain, Ca राजस्व की ओर से /Revenue By : Shri Subhendu Dutta, Dr सुनवाई की तारीख / Date Of Hearing : 16/01/2020 घोषणा की तारीख/Date Of Pronouncement : 18/03/2020 आदेश / O R D E R Per L.P.Sahu, Am : This Is An Appeal Filed By The Assessee Against Order Of Cit(A), Sambalpur, Dated 04.09.2017 For The Assessment Year 2010-2011, On The Following Grounds Of Appeal :- 1. On The Fact & Under Circumstances Of The Case The Commissioner (Appeals) Was Not Justified In Holding The Nature Of Expenses Of S/ 957144 Under The Head Commission Instead Of Contract Work. (Para 4). 2. On The Fact & Under Circumstances Of The Case The Commissioner (Appeals) Erred In Understanding The Accounting Entry Of Discount Of Rs. 16,91,687 & Wrongly Treated The Bogus Sundry Creditor. (Para8) 3. On The Fact & Under Circumstances Of The Case The Commissioner (Appeals) Was Not Justified In Rejection Of Additional Evidence & Confirming The Disallowance Of Rs. 999390 For Non-Submission Of Vat Return, (Para-9) 4. On The Fact & Under Circumstances Of The Case The Commissioner (Appeals) Was Unjustified For Not Sending For Remand The Case & Confirming The Addition Of Rs.2799978. 2 2. Brief Facts Of The Case Are That The Assessee Filed Return Of Income

TDS chapter. As per Section 194H of the Act, the assessee should have been deducted @10% on the entire payments made but he has deducted only 2% instead of 10% and the authorities below have rightly applied the provisions of Section 40A(3) of the Act for payments exceeding Rs.20,000/- in cash. Therefore, this ground of appeal should

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

2(15) are / perfectly capable of carrying out business and/or commercial transactions. There are no physical/legal infirmities in this regard. In the case of Ram Laxman Sugar Mills-v-CIT 66 ITR 613 SC, it has been held that A Hindu undivided family is undoubtedly a "person" within the meaning of the Indian Income-tax Act. In various cases that

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

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

Bench: Shri Chandra Mohan Garg & Laxmi Prasad Sahu

2(15) are / perfectly capable of carrying out business and/or commercial transactions. There are no physical/legal infirmities in this regard. In the case of Ram Laxman Sugar Mills-v-CIT 66 ITR 613 SC, it has been held that A Hindu undivided family is undoubtedly a "person" within the meaning of the Indian Income-tax Act. In various cases that

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.

TDS) Circle, seeking permission for getting the deduction of tax at source u/s 194-I at a lower rate of 5.5% which has been issued and the assessee has admittedly deducted tax at source on wheeling P a g e 6 | 19 Assessment Year :2010-2011 and transmission charges at a lower rate as per the certificate issued

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.

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. 7. In the result, appeal of the assessee stands allowed. Order dictated and pronounced

DCIT, CORPORATE CIRCLE- 1(2), BHUBANESWAR vs. M/S. NATIONAL ALUMINIUM COMPANY LTD., BHUBANESWAR

In the result, all the appeals of the assessee and Revenue along

Bench: Shri C.M. Garg, Jm & Shri L.P. Sahu, Am आयकर अऩीऱ सं./Ita No.338/Ctk/2017 आयकर अऩीऱ सं./Ita No.39/Ctk/2019 आयकर अऩीऱ सं./Ita No.01/Ctk/2020 (नििाारण वषा / Assessment Years :2009-2010, 2015-2016 & 2016-2017) National Aluminium Company Limited, Vs. Acit, Corporate Circle-1(2), Bhubaneswar Nalco Bhawan, P/1, Nayapalli, Bhubaneswar Pan No. : Aaacn 7449 M & आयकर अऩीऱ सं./Ita No.331/Ctk/2017 आयकर अऩीऱ सं./Ita No.69/Ctk/2019 आयकर अऩीऱ सं./Ita No.65/Ctk/2020 (नििाारण वषा / Assessment Years :2009-2010, 2015-2016 & 2016-2017) National Aluminium Company Limited, Vs. Dcit/Acit, Nalco Bhawan, P/1, Nayapalli, Corporate Circle-1(2), Bhubaneswar Bhubaneswar Pan No. : Aaacn 7449 M & Cross Objection No.11/Ctk/2019 Cross Objection No.02/Ctk/2020 (Arising Out Of Ita Nos.69/Ctk/2019 & 65/Ctk/2020) (नििाारण वषा / Assessment Years :2015-2016 & 2016-2017) National Aluminium Company Limited, Vs. Dcit/Acit, Nalco Bhavan, P/1, Nayapalli, Corporate Circle-1(2), Bhubaneswar Bhubaneswar Pan No. : Aaacn 7449 M (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. ननधााररती की ओर से /Assessee By Shri A.K.Sabat & B.K.Mahapatra, Cas : राजस्व की ओर से /Revenue By Shri M.K.Gautam, Cit Dr : सुनवाई की तारीख / Date Of Hearing : 06/10/2020 घोषणा की तारीख/Date Of Pronouncement : 28/10/2020 आदेश / O R D E R Per Bench : These Are The Cross Appeals Filed By The Assessee & Revenue & Cross Objections By The Assessee, Against The Separate Orders Of The Cit(A)-1, Bhubaneswar, Dated 30.12.2017, 27.12.2018 & 24.10.2019

section 195 is wrong, incorrect contrary to facts on record, arbitrary, unjustified, erroneous and bad in law. d. The A.Q having not specified on which amount the TDS were not made and which are required to be made by NALCO and merely on a working made by A.O himself without any material on record and evidence, but on the basis