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

80,09,435 under section RO-IA of the Act as claimed by M/s PNC Construction Co. Limited in respect of "Sagar Beene Project work executed by it on behalf of JV, NCC-PNC JV Findings as laid down by Hon'ble ITAT Agra, Bench in the case of PNC Construction Co. Ltd DCIT reported in (2013) 37 taxmann.com

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

80,09,435 under section RO-IA of the Act as claimed by M/s PNC Construction Co. Limited in respect of "Sagar Beene Project work executed by it on behalf of JV, NCC-PNC JV Findings as laid down by Hon'ble ITAT Agra, Bench in the case of PNC Construction Co. Ltd DCIT reported in (2013) 37 taxmann.com

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

80,09,435 under section RO-IA of the Act as claimed by M/s PNC Construction Co. Limited in respect of "Sagar Beene Project work executed by it on behalf of JV, NCC-PNC JV Findings as laid down by Hon'ble ITAT Agra, Bench in the case of PNC Construction Co. Ltd DCIT reported in (2013) 37 taxmann.com

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

80,09,435 under section RO-IA of the Act as claimed by M/s PNC Construction Co. Limited in respect of "Sagar Beene Project work executed by it on behalf of JV, NCC-PNC JV Findings as laid down by Hon'ble ITAT Agra, Bench in the case of PNC Construction Co. Ltd DCIT reported in (2013) 37 taxmann.com

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

80,09,435 under section RO-IA of the Act as claimed by M/s PNC Construction Co. Limited in respect of "Sagar Beene Project work executed by it on behalf of JV, NCC-PNC JV Findings as laid down by Hon'ble ITAT Agra, Bench in the case of PNC Construction Co. Ltd DCIT reported in (2013) 37 taxmann.com

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

80 without appreciating the fact that disallowance under section 14A r.w.r can not exceed the total exempt income, thus assessee prays restriction of the disallowance under section 14A r.w.r 8D the maximum equivalent to the exempt income earned by the assessee during the year under consideration. 9. That based on facts and circumstances of the case

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

Section 40(a)(ia) of the Income Tax Act, is illegal, arbitrary and liable to be annulled. 5. For that the disallowance of Rs.24,84,000.00 claimed as business expenditure, has been made under suspicious and frivolous grounds which is illegal and arbitrary and liable to be annulled. 6. For that the CIT(A) without affording adequate opportunity of hearing

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

Section 40(a)(ia) of the Income Tax Act, is illegal, arbitrary and liable to be annulled. 5. For that the disallowance of Rs.24,84,000.00 claimed as business expenditure, has been made under suspicious and frivolous grounds which is illegal and arbitrary and liable to be annulled. 6. For that the CIT(A) without affording adequate opportunity of hearing

MOTWANI CONSTRUCTIONS PVT. LIMITED,KHORDA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), BHUBANESWAR

In the result, appeal of the assesee is allowed

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.452/Ctk/2025 (नििाारण वर्ा / Assessment Year : 2013-2014) Motwani Constructions Pvt. Limited Vs Dcit, Circle-1(1), Cuttack At:- Ground Floor, Samabaya Bhawan, Janpath, Khurda 751022 Pan No. : Aagcm 2496 K (अपीलार्थी /Appellant) (प्रत्यर्थी / Respondent) .. नििााररती की ओर से /Assessee By : Shri S.K.Sarangi, Ar राजस्व की ओर से /Revenue By : Shri Vijay Singh, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 24/09/2025 घोषणा की तारीख/Date Of Pronouncement : 24/09/2025 आदेश / O R D E R Per Bench : This Is An Appeal Filed By The Assessee Against The Ld.Cit(A), National Faceless Appeal Centre(Nfac), Delhi Order Dated 13/08/2025 Passed In Appeal No. Nfac/2012-13/10027542 For The Assessment Year 2013-2014. 2. It Was Submitted By The Ld. Ar That In The Course Of Assessment, The Ao Had Disallowed The Salary Paid To The Director To An Extent Of Rs.15 Lakhs On The Ground That There Is A Delay In Deduction Of Tds & Payment Of The Same To The Credit Of The Government. It Was The Submission That The Returns Of The Directors Have Also Been Filed Wherein The Tds Has Been Claimed & The Credits Have Been Allowed. It Was The Submission That No Disallowance Is Called For In View Of The Decision Of The Hon’Ble

Section 271C of the Income-tax Act." 3. It was further submitted that the AO has disallowed Rs.52,000/- towards rent as no TDS has been deducted. It was the submission that on house rent of Rs.52,000/-, no TDS is called for, insofar as the threshold limit was Rs.1,80

CHINARI ROHINI SUBUDHI,BHUBANESWAR vs. ITO WARD 3(1), BHUBANESWAR

In the result, appeal of the assessee stands partly allowed

Bench: Before S/Shri George Mathan, Judicial & Girish Agrawalwalassessment Year : 2010-2011 2011 Sundeep Sundeep Haridas, Haridas, Prop. Prop. Vs. Dcit, Circle Dcit, Circle-1(1), Sundardas D Unsraj, College Sundardas D Unsraj, College Cuttack Square, Cuttack Square, Cuttack Pan/Gir No. Pan/Gir No.Aadp 5404 N (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri Mohit Sheth Mohit Sheth, Ar Revenue By : Shri Saroj Kumar Mahapatra, Cit : Shri Saroj Kumar Mahapatra, Cit Dr

TDS and non-production of Form 15H & 15G and consequently, application of provisions of section 40(a)(ia) of the Act. It was the submission that the second issue was in respect of donation of Rs.70,000/- which has been disallowed by the Assessing Officer. It was the submission by ld CIT DR that the issue of donation

GITA DEVI GUPTA,CUTTACK vs. DEPUTY COMMISSIONER OF INCOME TAX, CUTTACK

In the result, appeal of the assessee stands partly allowed

Bench: Before Shri George Mathan, Judicial & Manish Agarwal Manish Agarwalassessment Year :2017-18 Gita Devi Gupta, Pro. M/S. Gita Devi Gupta, Pro. M/S. Vs. Dcit, Assessment Circle Dcit, Assessment Circle D.D. Textiles, Nandi Sahi, D.D. Textiles, Nandi Sahi, 2(1), Cuttack 2(1), Cuttack Cuttack Pan/Gir No. No.Aazpg 8154 E (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri P.K.Mishra, Adv P.K.Mishra, Adv Revenue By : Shri S.C.Mohanty S.C.Mohanty, Sr Dr Date Of Hearing : 7/8/ /2024 Date Of Pronouncement : 7/8 /8/2024 O R D E R

section 201(1) of the Act has been raised against the assessee on account of non-deduction of TDS. It was the submission that one of the person Shri R.K.Poddar had also appeared before the AO and his statement was recorded on 5.9.2019 wherein he has confirmed the business with the assessee and the receipt of commission. Ld AR further

B.C. BHUYAN CONSTRUCTION PVT. LTD.,BHUBANESWAR vs. DCIT, CORPORATE CIRCLE- 1(1), BHUBANESWAR

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

Bench: Before S/Shri George Mathan, Judicial & Girish Agrawalwalassessment Year : 2014-15 B.C.Bhuyan Construction Pvt B.C.Bhuyan Construction Pvt Vs. Dcit, Corporate Circle Dcit, Corporate Circle - Ltd., Plot No.90, Palasuni, Ltd., Plot No.90, Palasuni, 1(1), Rasulgarh, Bhubaneswar Rasulgarh, Bhubaneswar Bhubaneswar Bhubaneswar Pan/Gir No. Pan/Gir No.Aadcb 3304 N (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri P.C.Sethi, Adv Revenue By Revenue By : Shri Saroj Kumar Mahapatra, Saroj Kumar Mahapatra, Pr. Cit Dr Date Of Hearing : 20/07 7/2023 Date Of Pronouncement : 20/0 /07/2023

TDS in respect of Director’s remuneration. v) addition of interest income as per 26AS 4. It was the submission that the ld CIT(A) did not consider any of the submission made by the assessee and had blindly upheld the order of the Assessing Officer. It was the submission that in respect of issue of depreciation on shuttering materials

M/S. FAYAJ INFRATECH PVT. LTD.,BHUBANESWAR vs. DCIT, CIRCLE- 1(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 : 2015-16 M/S. M/S. Fayaj Fayaj Infratech Infratech Pvt Pvt Vs. Dcit, Circle 1(1), Aayakar Dcit, Circle 1(1), Aayakar Ltd., C-56, 56, Baramunda Baramunda Bhavan, Bhubaneswar. Bhavan, Bhubaneswar. Housing Housing Board Board Colony, Colony, Bhubaneswar. Bhubaneswar. Pan/Gir No. Pan/Gir No.Aabcf 6797 R (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri K.K.Bal, Ar K.K.Bal, Ar Revenue By : Shri S.C.Mohanty, Sr. S.C.Mohanty, Sr. Dr Date Of Hearing : 11 /01 01/2023 Date Of Pronouncement : 11/01 /01/2023 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 11.12.2019 In Appeal No. In Appeal No. 0509/17-18 For The Assessment Year For The Assessment Year 2015-16. 2. Shri K.K.Bal, Ld Ar Appeared For The Assessee & Shri S.C.Mohanty, Shri K.K.Bal, Ld Ar Appeared For The Assessee & Shri S.C.Mohanty, Shri K.K.Bal, Ld Ar Appeared For The Assessee & Shri S.C.Mohanty, Ld Sr Dr Appeared For The Revenue. Ld Sr Dr Appeared For The Revenue.

TDS. He has also endorsed the appeal memo to that effect. Consequently, Ground No.6 of the appeal stands dismissed as not pressed. 5. Ground Nos.1 & 7 are general in nature and hence no separate adjudication is required. 6. In respect of the disallowance of the alleged bonus paid by applying the provisions of section

MAA JAGAT JANANI SEVA TRUST,NAMBIRA vs. ACIT (EXEMPTION CIRCLE), BHUBANESWAR

In the result, appeal of the assessee stands allowed

Bench: Before Shri George Mathan, Judicial & Manish Agarwal Manish Agarwalassessment Year : 2014-2015 2015 Maa Maa Jagat Jagat Janani Janani Seva Seva Vs. Asst. Asst. Commissioner Commissioner Of Of Trust, At- -Nambira, Po: Income Income Tax, Tax, Exemption Exemption Bamebari, Ps: Joda, Dist: Bamebari, Ps: Joda, Dist: Circle, Bhubaneswar Circle, Bhubaneswar Keonjhar Pan/Gir No Pan/Gir No.Aadtm 1575 H (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri P.K.Mishra, P.K.Mishra, Adv Revenue By : Shri Sanjay Kumar, Cit : Shri Sanjay Kumar, Cit Dr Date Of Hearing : 16/0 07/2024 Date Of Pronouncement : 16/0 /07/2024 O R D E R Per Bench This Is An Appeal Filed By The Assessee Against The Ord This Is An Appeal Filed By The Assessee Against The Ord This Is An Appeal Filed By The Assessee Against The Order Of The Ld Cit(A), Nfac, Delhi Cit(A), Nfac, Delhi Dated 7.6.2023 In Appeal No.Nfac/2013 Nfac/2013-14/10180318 For The Assessment Year For The Assessment Year 2014-15. 2. Shri P.K.Mishra, P.K.Mishra, Ld Ar Appeared For The Assessee & Shri The Assessee & Shri Sanjay Kumar, Ld Cit Kumar, Ld Cit Dr Appeared For The Revenue.

80,00,000 3. Ranjit Kumar Barik 60,00,000 4. Bhaktabandhu Mohanta 55,00,000 5. Jethuram Mahanta 50,00,000 6. Rajendra Barik 25,00,000 7. Ranjan Mahakud 25,00,000 8. M/s. Thriveni Earth Motors Pvt Ltd. 15,79,000 9. M/s. Biraja Chemical 11,70,000 10. M/s. A.K.Traders 22,00,000 11. Barbil Cricket

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

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

NATIONAL ALUMINIUM COMPANY LIMITED,BHUBANESWAR vs. PRINCIPAL CIT-1, BHUBANESWAR

In the result, appeal of the assessee stands allowed

Bench: Before S/Shri George Mathan, Judicial & Girish Agrawalassessment Year : 2016-17 National National Aluminium Aluminium Vs. Dcit, Circle Dcit, Circle -1(2), Company Limited., Nalco Company Limited., Nalco Bhubaneswar Bhubaneswar Bhawan, Bhawan, Nayapalli, Nayapalli, Bhubaneswar. Bhubaneswar. Pan/Gir No. Pan/Gir No.Aaacn 7449 M (Appellant) ) .. ( Respondent Respondent) Assessee By Assessee By : Shri Ved Jain, Ca & Shri P. Venugopal Rao, Ca Venugopal Rao, Ca Revenue By : Dr.Abani Kanta Nayak, Abani Kanta Nayak, Cit Dr Date Of Hearing : 30/11 11/2023 Date Of Pronouncement : 30/11 /11/2023 O R D E R Per Bench

section remaining of tax audit 43B unpaid on report which March 31st ever is Mar of the earlier previous year under audit 1 2 3 4 5 6 A Bonus 1,11,880 - 1,11,880 B Gratuity 8,60,13,944 - 8,60,13,944 Net paid as on the date of signing of audit report C Cont

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

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 of the persons who have given