M/S. ALTRADE MINERALS PVT. LIMITED,ROURKELA vs. ACIT,CENTRAL CIRCLE, SAMBALPUR, SAMBALPUR

In the result, appeal of the assessee is partly allowed

Bench: Before Shri George Mathanmember & Manish Agarwal Manish Agarwalassessment Year : 2011-12 M/S. Altrade Minerals Pvt /S. Altrade Minerals Pvt Vs. Asst. Asst. Commissioner Commissioner Of Of Ltd., C/O. Kadmawala & Co., C/O. Kadmawala & Co., Income Tax, Central Circle, Income Tax, Central Circle, C.A., C.A., Budhram Budhram Oram Oram Sambalpur Market, Market, Kachery Kachery Road, Road, Rourkela. Pan/Gir No. No.Aafca 7136 F (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri M.R.Sahu, Ca Revenue By : Shri S.C.Mohanty, Sr Dr : Shri S.C.Mohanty, Sr Dr Date Of Hearing : 16/12/20 2024 Date Of Pronouncement : 16/12/20 024

TDS: In view of above discussions including that of judicial precedents, it is requested kindly allow Rs.66,103/-being the interest on tax suffered by the deductor because such interest does not come under the definition of tax as defined u/s.2(43) and it is compensatory in nature and allowable u/s 37 of the I.T Act, 1961. (11). Grounds

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

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 of appeal, submit

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

BISWAJIT DAS,BHUBANESWAR vs. ITO, WARD-1(1), BHUBANESWAR, BHUBANESWAR

In the result, the appeal filed by the revenue is dismissed and the

Bench: Shri N.S Saini & Shri Aby T. Varkeyassessment Year :2010-2011

28 shall be computed in accordance with the provisions of section 30 to 43D. From the above provisions in the statute, it thus clear that the profit of the undertaking in the case of the appellant has to be computed in accordance with the provisions of the section 30 to 43D., i.e., including the provisions of section

ITO, WARD-2(2), BHUBANESWAR, BHUBANESWAR vs. BISWAJIT DAS, BHUBANESWAR

In the result, the appeal filed by the revenue is dismissed and the

Bench: Shri N.S Saini & Shri Aby T. Varkeyassessment Year :2010-2011

28 shall be computed in accordance with the provisions of section 30 to 43D. From the above provisions in the statute, it thus clear that the profit of the undertaking in the case of the appellant has to be computed in accordance with the provisions of the section 30 to 43D., i.e., including the provisions of section

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 :

28 3.23. It is a well settled principal decided in the case of Reform Flour Mills P Ltd vs. CIT [1978] 114ITR 227(Cal.) that section .145(1) does not postulate any agreement or contract regarding the method of accounting to be employed by a tax payer. This section also does not lay any embargo on him to alter

PARADEEP PHOSPHATES LTD.,BHUBANESWAR vs. JCIT, RANGE-1, BHUBANESWAR, BHUBANESWAR

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

2) is based on the "principle of proportionality". The said sub-section gets attracted only in cases where the payment made is a composite payment in which a certain proportion of payment has an element of "income" chargeable to tax in India. It is in this context that the Supreme Court stated, "If no such application is filed, income

REGIONAL COLLEGE OF ENGINEERING & MANAGEMENT,BHUBANESWAR vs. ITO, WARD-2(2), BHUBANESWAR

In the result, appeal of the assessee is allowed

Bench: Shri C.M. Garg, Jm & Shri L.P. Sahu, Am आयकर अऩीऱ सं./Ita No.94/Ctk/2016 (नििाारण वषा / Assessment Year :2008-2009 Regional College Of Engineering & Vs. Ito Ward-2(2), Bhubaneswar Management, Plot No.18, Sector-A, Zone-B, Mancheswar Industrial Estate, Bhubaneswar-751010 Pan No. : Aaaar 1386 H (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. ननधााररती की ओर से /Assessee By : Shri Sunil Mishra, Advocate राजस्व की ओर से /Revenue By : Shri Subhendu Datta, Dr सुनवाई की तारीख / Date Of Hearing : 20/08/2020 घोषणा की तारीख/Date Of Pronouncement : 21/08/2020 आदेश / O R D E R Per L.P.Sahu, Am: This Is An Appeal Filed By The Assessee Against The Order Of The Cit(A)-3, Bhubaneswar, Dated 28.12.2015 For The Assessment Year 2008-2009, On The Following Grounds Of Appeal :- 1. That, The Learned Cit (A) Has Committed Serious Error In Not Allowing The Appeal Of The Appellant Against The Order Of The Learned Ao Passed U/S 154 Of The Income Tax Act Dated 15.10.2014 . 2. That, The Learned Cit (A) Has Committed Serious Error In Not Accepting That The Denial Of "Emption To A Charitable Trust Granted Registration U/S 12Aa Of The Income Tax Act Is A Mistake Apparent From Record As Envisaged U/S 154 Of The Income Tax Act, 1961. 3. That, The Learned Cit (A) Has Committed Serious Error In Holding That The Mistake Of Disallowance For Violation Of Provision Of Section 40(A)(Ia) Of The Income Tax Act Is Not A Mistake Apparent From Record In The Case Of A Charitable Trust Registered U/S 12Aa Of The Income Tax Act.

28 and not otherwise. Hence, provisions of section 40(a) are not applicable in case of charitable trust or institution where income and expenditure is computed in terms of section 11. 8. Accordingly, we do not find any merit in the orders passed by the Assessing Officer as well as by the CIT(A) and delete the disallowance made under

SUBHALAXMI AGENCIES PVT. LTD.,NAYAGARH vs. JCIT, RAMGE-2, BHUBANESWAR

In the result, appeal of the revenue is partly allowed and that of

Bench: S/Shri N.S Saini & Pavan Kumar Gadale

section 194C(5) of the Act, which provides that in such cases no TDS was to be deducted from the payments made for transportation of goods and, therefore, no disallowance can be made u/s.40(a)(ia) of the Act for non-deduction of TDS from such payments. We find that the assessee before the CIT(A) relied on the decision

LATEST GENERATION ENTERTAINMENT PVT. LTD.,CUTTACK vs. DCIT, CPC-TDS,

In the result, both the appeals filed by the assessee are allowed

Bench: S/Shri N.S Saini & Pavan Kumar Gadale

28 /08/ 2017 O R D E R Per N.S.Saini, AM These are appeals filed by the assessee against the separate orders of the CIT(A)- Cuttack both dated 25.1.2016 for the assessment years 2013-14 & 2014-15. 2. In both the appeals, the grievance of the assessee is that the CIT(A) erred in confirming the levy of fees

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

TDS Certificates against claim of interest income and copy of Form No.16 to justify salary income for your Honour's reference and record. Since the Assessee has explained all the queries in detail and substantiated all her claims made in the return of income with sufficient documentary evidences, it is requested to accept the same and to complete the Assessment

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

28 /0 /06/2023 O R D E R Per Bench This is an appeal filed by the assessee ag This is an appeal filed by the assessee against the order passed ainst the order passed u/s.263 of the Act by the ld Pr.CIT u/s.263 of the Act by the ld Pr.CIT-Bhubaneswar-1 dated 27.3.2023 in Appeal No. ITBA/REV/F/REV5/2022 ITBA/REV/F/REV5/2022-23/1051381275

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

In the result, appeal of the assessee i

Bench: Shri N.S.Saini, Am & Shri Pavan Kumar Gadale, Jm आयकर अऩीऱ सं./Ita No.339 & 340/Ctk/2016 Dcit, Corporate Circle1(2)/ Vs. National Aluminium Company Acit, Circle-2(2), Limited, Bhubaneswar Nalco Bhavan, P/1, Nayapalli, Bhubaneswar स्थायी लेखा सं./ जीआइआर सं./ Pan/Gir No. : Aaacn 7449 M (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. & आयकर अऩीऱ सं./Ita No.352 & 353/Ctk/2016 & Ita No.374/Ctk/2014 (नििाारण वषा / Assessment Year :2010-11, 2012-13 & 2011-12) National Aluminium Company Vs. Jcit Range-2/ Limited, Acit, Corporate Circle-1(2) Nalco Bhavan, P/1, Nayapalli, Bhubaneswar Bhubaneswar स्थायी लेखा सं./ जीआइआर सं./ Pan/Gir No. : Aaacn 7449 M (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. & Cross Objection No.01/Ctk/2015 & 25/Ctk/2016 (Arising Out Of Ita Nos.376/Ctk/14 & Ita No.340/Ctk/2016) (नििाारण वषा / Assessment Year :2011-2012 & 2012-2013) National Aluminium Company Vs. Acit, Circle-2(2)/ Limited, Dcit, Corporate Circle- Nalco Bhavan, P/1, Nayapalli, 1(2), Bhubaneswar Bhubaneswar स्थायी लेखा सं./ जीआइआर सं./ Pan/Gir No. : Aaacn 7449 M (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

TDS and upon grant of such a certificate, the Payer is required to make payment without TDS. These provisions are largely used by foreign banks operating in India for receiving payments from their customers without TDS. Section 195(6) was introduced by the Finance Act, 2008 (with effect from 1.4.2008) providing that the Payer shall furnish the information relating

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

2. Brief facts of the case are that the assessee filed return of income on 21.01.2011 declaring income from business at Rs.7,95,422/- after claiming brought forward loss of Rs.4,01,142/- resulting the net income disclosed at Rs.3,94,280/-, however, the tax was paid u/s.115JB of the I.T.Act at a total income of Rs.9,28

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

28,438/-.” 5. Grounds raised in A.Y,. 2013-14 read as under: “1. Whether on the facts and in the circumstances of the case, the Ld. CIT (A) is justified in deleting the addition made by Assessing Officer towards 'disallowance of donation” to the tune of Rs.1,75,00,000/-. P a g e 2 | 68 Smt. Indrani Patnaik

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

28,438/-.” 5. Grounds raised in A.Y,. 2013-14 read as under: “1. Whether on the facts and in the circumstances of the case, the Ld. CIT (A) is justified in deleting the addition made by Assessing Officer towards 'disallowance of donation” to the tune of Rs.1,75,00,000/-. P a g e 2 | 68 Smt. Indrani Patnaik

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.

2 (Varanasi-Trib), wherein, it has been held that whether the assessee routes GST through the profit and loss account or not, still the provisions of section 43B is applicable. In the present case, as the assessee has not deducted TDS u/s.194J on payments to OPTCL, the same is hit by the provisions of section

ACIT, CORPORATE CIRCLE-1(2), BHUBANESWAR vs. 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

NATIONAL ALUMINIUM COMPANY LIMITED,BHUBANESWAR vs. ACIT, CORPORATE CIRCLE-1(2), 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