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

x) read with Section 36 (1) (va) of the Act creates the impression that the employees' contribution would continue to be treated differently under a different head of deduction, as the head of deduction is separate under Section 43 B and Section 36 of the Act but on a broader reading of the amendments made to Section 43B repeatedly

M/S. VISION HABITATE & SERVICES PVT. LTD.,SAMBALPUR vs. PR. CIT, SAMBALPUR

In the result, the appeal of assessee is allowed

Bench: Shri C.M. Garg, Jm & Shri L.P. Sahu, Am आयकर अऩीऱ सं./Ita No.214/Ctk/2019 (नििाारण वषा / Assessment Year :2014-2015) M/S Vision Habitate & Services Vs. Pr. Cit, Sambalpur-768004 Private Limited, Kadambari Complex, Gole Bazar, Sambalpur-768001 Pan No. : Aadcn 4768 J (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. ननधााररती की ओर से /Assessee By : Shri B.N.Agrawal/Binod Agrawal, Ars राजस्व की ओर से /Revenue By : Shri M.K.Gautam, Citdr सुनवाई की तारीख / Date Of Hearing : 25/08/2020 घोषणा की तारीख/Date Of Pronouncement : 31/08/2020 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 Pr.Cit, Sambalpur, Dated 30.03.2019 For The A.Y.2014-2015 On The Following Grounds :- 1. That The Order U/S. 263 Is Bad In Law As Well As In Facts. 2. That The Order U/S. 263, Stated To Have Been Passed On 30.03.2019, Is Ante Dated & Barred By Limitation, Being Issued & Served Upon The Appellant On 30.04.2019, Which Is After The Expiry Of Period Of Limitation On 31.03.2019. 3. That The Assessment Order Dt.29.12.2016 Making An Addition Of Rs.27,51,100 To The Returned Income U/S.56(2)(Viib) Consequent Upon Valuation Of Book Value Of 4,510 Nos. Of Equity Shares @ Rs.739 Per Share As On 31.03.2013 Allotted On 31.03.2014 @ Rs.1,349 Per Share. Thus, The Difference Of Rs.610 Per Share Multiplied By 4,510 Nos. Of Shares Allotted Coming To Rs.27,51,100 Has Been Added As Above By The Id. Ao. The Said Valuation & The Consequential Addition Has Been Disputed By The Appellant In The Appeal In Form No.35 E-Filed Before The Id.

x 4,510 shares) u/s.56(2)(viib) in addition to Rs.27,51,100 already added by the Id. AO on the same ground. 5. That in the facts and circumstances of the case, the order of assessment made u/s. 143(3) could not be termed or held as erroneous and prejudicial to the interests of revenue within the meaning

ACIT, CENTRAL CIRCLE, SAMBALPUR, SAMBALPUR vs. M/S. SHREE BALAJI ENGICONS PVT. LTD., JHARSUGUDA

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

Bench: Shri George Mathan & Shri Manish Agarwalit(Ss)A No.77/Ctk/2023

TDS etc. and become a separate legal entity. Based on such JV Agreement, both the parties have executed the 48 IT(SS)A No.77 & ITA Nos.320,296,88, 141,89,142,13/CTK/2023 &CO No.02/CTK/2023 work awarded to them by the JV entity and share the receipts according to their contribution in the execution which has already been tabulated

M/S. SHREE BALAJI ENGICONS PVT. LTD.,BELPAHAR, JHARSUGUDA vs. DCIT, CENTRAL CIRCLE-1(1), SAMBALPUR, SAMBALPUR

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

Bench: Shri George Mathan & Shri Manish Agarwalit(Ss)A No.77/Ctk/2023

TDS etc. and become a separate legal entity. Based on such JV Agreement, both the parties have executed the 48 IT(SS)A No.77 & ITA Nos.320,296,88, 141,89,142,13/CTK/2023 &CO No.02/CTK/2023 work awarded to them by the JV entity and share the receipts according to their contribution in the execution which has already been tabulated

ASST. CIT, CENTRAL CIRCLE, SAMBALPUR, AAYAKAR BHAWAN, SAMBALPUR vs. SHREE BALAJI ENGICON LIMITED, BELPAHAR RS

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

Bench: Shri George Mathan & Shri Manish Agarwalit(Ss)A No.77/Ctk/2023

TDS etc. and become a separate legal entity. Based on such JV Agreement, both the parties have executed the 48 IT(SS)A No.77 & ITA Nos.320,296,88, 141,89,142,13/CTK/2023 &CO No.02/CTK/2023 work awarded to them by the JV entity and share the receipts according to their contribution in the execution which has already been tabulated

M/S. SHREE BALAJI ENGICONS PVT. LTD.,BELPAHAR, JHARSUGUDA vs. ACIT, CENTRAL CIRCLE-1(1), SAMBALPUR, SAMBALPUR

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

Bench: Shri George Mathan & Shri Manish Agarwalit(Ss)A No.77/Ctk/2023

TDS etc. and become a separate legal entity. Based on such JV Agreement, both the parties have executed the 48 IT(SS)A No.77 & ITA Nos.320,296,88, 141,89,142,13/CTK/2023 &CO No.02/CTK/2023 work awarded to them by the JV entity and share the receipts according to their contribution in the execution which has already been tabulated

ACIT, CENTRAL CIRCLE, SAMBALPUR, SAMBALPUR vs. M/S. SHREE BALAJI ENGICONS PVT. LTD., JHARSUGUDA

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

Bench: Shri George Mathan & Shri Manish Agarwalit(Ss)A No.77/Ctk/2023

TDS etc. and become a separate legal entity. Based on such JV Agreement, both the parties have executed the 48 IT(SS)A No.77 & ITA Nos.320,296,88, 141,89,142,13/CTK/2023 &CO No.02/CTK/2023 work awarded to them by the JV entity and share the receipts according to their contribution in the execution which has already been tabulated

M/S. SHREE BAALAJI ENGICONS LIMITED,JHARSUGUDA vs. DEPUTY COMMISSIONER OF INCOME TAX ( CENTRAL CIRCLE-1(1), SAMBALPUR

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

Bench: Shri George Mathan & Shri Manish Agarwalit(Ss)A No.77/Ctk/2023

TDS etc. and become a separate legal entity. Based on such JV Agreement, both the parties have executed the 48 IT(SS)A No.77 & ITA Nos.320,296,88, 141,89,142,13/CTK/2023 &CO No.02/CTK/2023 work awarded to them by the JV entity and share the receipts according to their contribution in the execution which has already been tabulated

ACIT, CENTRAL CIRCLE, SAMBALPUR, SAMBALPUR vs. M/S. SHREE BALAJI ENGICONS PVT. LTD., JHARSUGUDA

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

Bench: Shri George Mathan & Shri Manish Agarwalit(Ss)A No.77/Ctk/2023

TDS etc. and become a separate legal entity. Based on such JV Agreement, both the parties have executed the 48 IT(SS)A No.77 & ITA Nos.320,296,88, 141,89,142,13/CTK/2023 &CO No.02/CTK/2023 work awarded to them by the JV entity and share the receipts according to their contribution in the execution which has already been tabulated

SMT. PRAGYAN MOHANTY,BHUBANESWAR vs. ITO, BHUBANESWAR

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

Bench: Shri N.S Sainiassessment Year : 2011-12

2. Ground Nos. 1 and 6 of the appeal are general in nature and hence, require no separate adjudication by me. 3. In Ground No.2 of the appeal, the grievance of the assessee is that the CIT(A) erred in upholding the addition of Rs.2,56,805/-. Asse ssment Year : 20 11- 12 4. I have heard the rival submissions

TRIJAL ENTERPRISES,BHUBANESWAR vs. ACIT, CIRCLE- 4(1), BHUBANESWAR

Bench: S/Shri George Mathan & Arun Khodpiaassessment Year : 2016-17 Trijal Enterprises, Hall No.6, Vs. Acit, Circle-4(1), Fourth Floor, Bmc Bhawani Bhubaneswar Coom. Complex, Saheed Nagar, Bhubaneswar. Pan/Gir No.Aakft 6687 L (Appellant) .. ( Respondent) Assessee By : Shri P.K.Mishra,Ca P.K.Panda, Ars Revenue By : Shri M.K.Gautam, Cit Dr Date Of Hearing : 15/11/2022 Date Of Pronouncement : 15/11/2022 O R D E R Per Bench This Is An Appeal Filed By The Assessee Against The Order Of The Ld Cit(A)-1, Bhubaneswar Dated 22.6.2020 In Appeal No.0366/2018-19 For The Assessment Year 2016-17. 2. It Was Submitted By Ld Ar That The Assessee Is A Partnership Firm. The Partnership Firm Was Originally Constituted By Partnership Deed Dated 1.11.2015, Wherein, There Were Two Partners Namely; Shri Rajesh Polaki & Sri Malchit Chetan Kumar Patra. The Said Partnership Did Not Do Any Business. The Partnership Was Constituted For The Purpose Of Doing The Business Of Gold Jewellery. The Partnership Was Reconstituted On 1.3.2016, P A G E 1 | 37 Assessment Year : 2016-17

2 of his statement. He simply stated that everything was managed by brokers/agents in reply to question no.2 5 of his statement. b) Moreover in spite of such a huge investment, he was not able to produce receipts for rent payments, electricity bills and other evidences (utility bills) in support of business activities in reply to question no.26