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

bogus purchases as unexplained expenditure u/s.69C of the Act and had made an addition thereafter. It was the further submission that on similar lines sales to certain concerns were also treated as unexplained cash credits and additions had been made on such sales. It was the further submission that on the basis of information received from DDIT(Inv.), Unit

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

purchased shares worth Rs.25,00,000/- and Rs.3,22,00,000/- respectively from Tribhuvan Tradecom Private Limited were not found on the website of MCA. Thus receipts to the extent of Rs.3,47,00,000/- in the hands of Tribhuvan Tradecom Private Limited have remained unexplained. c) The A.O. also reported to the CIT(A) that Tribhuvan Tradecom Private Limited

M/S.BALLURAM STEELS PVT. LIMITED,ROURKELA vs. PRINCIPAL CIT, CENTRAL CIRCLE, VISAKHAPATNAM

In the result, appeal of the assessee is allowed

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.291/Ctk/2025 ("नधा"रण वष" / Assessment Year : 2018-2019) M/S Balluram Steels Pvt. Ltd, Vs Pr.Cit, Central Circle, 1St Floor, Purohit Market Complex Visakhapatnam Main Road, Rourkela-769012 Pan No. :Aaccb 7253 P (अपीलाथ" /Appellant) (""यथ" / Respondent) .. "नधा"रती क" ओर से /Assessee By : Shri P.K.Mishra, Ar राज"व क" ओर से /Revenue By : Shri Ashim Kumar Chakraborty, Cit-Dr सुनवाई क" तार"ख / Date Of Hearing : 02/12/2025 घोषणा क" तार"ख/Date Of Pronouncement : 02/12/2025 आदेश / O R D E R Per Bench : This Is An Appeal Filed By The Assessee Against The Order Passed By The Ld. Pr.Cit(Central), Visakhapatnam, Dated 28.03.2025 For The Assessment Year 2018-2019. 2. It Was Submitted By The Ld. Ar That In The Course Of Assessment U/S.147 Of The Act, The Ao Had Disbelieved The Transaction Of The Purchase Of Iron Ore & Had Invoked The Provisions Of Section 37(1) Of The Act & Had Made The Disallowance Of Purchases. It Was The Submission That The Ld. Pr.Cit Has Invoked His Powers U/S.263 Of The Act & Had Directed That The Provisions Of Sectiion 37(1) Of The Act Is Not To Be Applied But The Provisions Of Section 69C Of The Act Are To Be Applied. It Was The Submission That The Issue Is Now Squarely Covered By The Decision Of The Coordinate Bench Of The Tribunal In The Case Of Bajrang Steel & Alloys Private Limited, Passed

69(C) of the Act, was well within the purview of the learned CIT(A), insofar as, obviously the AO should also have been granted another opportunity to represent its case before the learned CIT(A). It is admitted fact the learned AO in the show-cause notice has referred to the provision

ASHWIN KUMAR AGARWAL,CUTTACK vs. DCIT ASMNT CIRCLE-2(1)CUTTACK, CUTTACK

In the result, appeal of the assessee is allowed

69,000/- was made on account of capital introduction by the assessee as unexplained credit in the hands of the firm which therefore, established that the assessee has not been able to prove the genuineness of the source of the capital introduced in the partnership firm. The Id Sr. DR further submitted that the Id CIT(A) while confirming

BAJRANG STEEL & ALLOYS PRIVATE LIMITED,SUNDARGARH vs. PRINCIPAL COMMISSIONER OF INCOME TAX, SAMBALPUR

In the result, appeal of the assessee is allowed

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.553/Ctk/2024 (निर्धारण वर्ा / Assessment Year : 2018-2019) Bajrang Steel & Alloys Private Vs Pcit, Sambalpur Limited Plot No:- 31, Kalunga, Near Kalunga High School, Sundergarh, 770031 Pan No. : Aaacm 2123 M (अपीलधर्थी /Appellant) .. (प्रत्यर्थी / Respondent) निर्धाररती की ओर से /Assessee By : Miss Sarmila Agarwal, Ca रधजस्व की ओर से /Revenue By : Shri Ashim Kumar Chakraborty, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 22/09/2025 घोषणा की तारीख/Date Of Pronouncement : 22/09/2025

bogus purchases. It was submission that the Ld. PCIT invoked its power u/s.263 of the Act on the ground that the AO in the show cause notice proposed the addition u/s 69C of the Act but had made the addition u/s. 37(1) of the Act in the course of assessment. The 2 Ld. PCIT issued show cause notice

TARINI MINERALS PVT. LTD.,ROURKELA vs. ACIT, ROURKELA

In the result, appeal of the assessee is allowed

Bench: Shri Chandra Mohan Garg & Laxmi Prasad Sahuassessment Year : 2012-13

bogus. Ld A.R. referred to page 3 of the APB i.e. ledger account of Zodiac Enterprises from 1.4.2011 to 31.3.2012, wherein, it has been shown as at 1.4.2011, the amount of Rs.17,36,046/- in opening balance as well as closing balance, therefore, same amount has been brought forward from the preceding year

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

purchasers. Further, non-service of letters to the buyers or non-compliance of the letters by the buyers does not show that the payment of commission was not genuine when the relative sale was considered genuine and accepted by the department. Further, non- P a g e 21 | 68 Smt. Indrani Patnaik A-6, Commercial Estate, Civil Township, Rourkela furnishing

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

purchasers. Further, non-service of letters to the buyers or non-compliance of the letters by the buyers does not show that the payment of commission was not genuine when the relative sale was considered genuine and accepted by the department. Further, non- P a g e 21 | 68 Smt. Indrani Patnaik A-6, Commercial Estate, Civil Township, Rourkela furnishing

ITO, BHADRAK WARD, BHADRAK vs. DEEPANSU MOHAPATRA, BHADRAK

In the result, Appeals of the revenue in in ITANos

Bench: Shri C.M. Garg, Jm & Shri Manish Borad, Am

bogus LTCG. Reliance was placed on following decisions: 1. Suman Poddar vs. ITO (2019) 112 taxmann.com 330 (SC) 2. Sanjay Bimalchand Jain vs. Pr. CIT (2018) 89 taxmann.com 196(Bombay) 3. Pooja Ajmani vs. ITO (2019) 106 Taxmann.com 65(Delhi- Tri.) 4. Satish Kishore vs. ITO (2019) 110 taxmann.com 307 (Delhi-Tribunal.) 5. Anip Rastogi vs. ITO in ITANo.3809/Del/2018 (I.T.A.T

ITO, BHADRAK WARD, BHADRAK vs. HIMANSU MOHAPATRA, BHADRAK

In the result, Appeals of the revenue in in ITANos

Bench: Shri C.M. Garg, Jm & Shri Manish Borad, Am

bogus LTCG. Reliance was placed on following decisions: 1. Suman Poddar vs. ITO (2019) 112 taxmann.com 330 (SC) 2. Sanjay Bimalchand Jain vs. Pr. CIT (2018) 89 taxmann.com 196(Bombay) 3. Pooja Ajmani vs. ITO (2019) 106 Taxmann.com 65(Delhi- Tri.) 4. Satish Kishore vs. ITO (2019) 110 taxmann.com 307 (Delhi-Tribunal.) 5. Anip Rastogi vs. ITO in ITANo.3809/Del/2018 (I.T.A.T

ITO, BHADRAK WARD, BHADRAK vs. HIMANSU MOHAPATRA, BHADRAK

In the result, Appeals of the revenue in in ITANos

Bench: Shri C.M. Garg, Jm & Shri Manish Borad, Am

bogus LTCG. Reliance was placed on following decisions: 1. Suman Poddar vs. ITO (2019) 112 taxmann.com 330 (SC) 2. Sanjay Bimalchand Jain vs. Pr. CIT (2018) 89 taxmann.com 196(Bombay) 3. Pooja Ajmani vs. ITO (2019) 106 Taxmann.com 65(Delhi- Tri.) 4. Satish Kishore vs. ITO (2019) 110 taxmann.com 307 (Delhi-Tribunal.) 5. Anip Rastogi vs. ITO in ITANo.3809/Del/2018 (I.T.A.T

ITO, BHADRAK WARD, BHADRAK vs. ANUPAMA MOHAPATRA, BHADRAK

In the result, Appeals of the revenue in in ITANos

Bench: Shri C.M. Garg, Jm & Shri Manish Borad, Am

bogus LTCG. Reliance was placed on following decisions: 1. Suman Poddar vs. ITO (2019) 112 taxmann.com 330 (SC) 2. Sanjay Bimalchand Jain vs. Pr. CIT (2018) 89 taxmann.com 196(Bombay) 3. Pooja Ajmani vs. ITO (2019) 106 Taxmann.com 65(Delhi- Tri.) 4. Satish Kishore vs. ITO (2019) 110 taxmann.com 307 (Delhi-Tribunal.) 5. Anip Rastogi vs. ITO in ITANo.3809/Del/2018 (I.T.A.T

ITO, BHADRAK WARD, BHADRAK vs. ANUPAMA MOHAPATRA, BHADRAK

In the result, Appeals of the revenue in in ITANos

Bench: Shri C.M. Garg, Jm & Shri Manish Borad, Am

bogus LTCG. Reliance was placed on following decisions: 1. Suman Poddar vs. ITO (2019) 112 taxmann.com 330 (SC) 2. Sanjay Bimalchand Jain vs. Pr. CIT (2018) 89 taxmann.com 196(Bombay) 3. Pooja Ajmani vs. ITO (2019) 106 Taxmann.com 65(Delhi- Tri.) 4. Satish Kishore vs. ITO (2019) 110 taxmann.com 307 (Delhi-Tribunal.) 5. Anip Rastogi vs. ITO in ITANo.3809/Del/2018 (I.T.A.T

ITO, BHADRAK WARD, BHADRAK vs. SITANSU SEKHAR MOHAPATRA, BHADRAK

In the result, Appeals of the revenue in in ITANos

Bench: Shri C.M. Garg, Jm & Shri Manish Borad, Am

bogus LTCG. Reliance was placed on following decisions: 1. Suman Poddar vs. ITO (2019) 112 taxmann.com 330 (SC) 2. Sanjay Bimalchand Jain vs. Pr. CIT (2018) 89 taxmann.com 196(Bombay) 3. Pooja Ajmani vs. ITO (2019) 106 Taxmann.com 65(Delhi- Tri.) 4. Satish Kishore vs. ITO (2019) 110 taxmann.com 307 (Delhi-Tribunal.) 5. Anip Rastogi vs. ITO in ITANo.3809/Del/2018 (I.T.A.T

ITO, BHADRAK WARD, BHADRAK vs. DEEPANSU MOHAPATRA, BHADRAK

In the result, Appeals of the revenue in in ITANos

Bench: Shri C.M. Garg, Jm & Shri Manish Borad, Am

bogus LTCG. Reliance was placed on following decisions: 1. Suman Poddar vs. ITO (2019) 112 taxmann.com 330 (SC) 2. Sanjay Bimalchand Jain vs. Pr. CIT (2018) 89 taxmann.com 196(Bombay) 3. Pooja Ajmani vs. ITO (2019) 106 Taxmann.com 65(Delhi- Tri.) 4. Satish Kishore vs. ITO (2019) 110 taxmann.com 307 (Delhi-Tribunal.) 5. Anip Rastogi vs. ITO in ITANo.3809/Del/2018 (I.T.A.T

ITO, BHADRAK WARD, BHADRAK vs. AMRUTA PREETAM MOHAPATRA, BHADRAK

In the result, Appeals of the revenue in in ITANos

Bench: Shri C.M. Garg, Jm & Shri Manish Borad, Am

bogus LTCG. Reliance was placed on following decisions: 1. Suman Poddar vs. ITO (2019) 112 taxmann.com 330 (SC) 2. Sanjay Bimalchand Jain vs. Pr. CIT (2018) 89 taxmann.com 196(Bombay) 3. Pooja Ajmani vs. ITO (2019) 106 Taxmann.com 65(Delhi- Tri.) 4. Satish Kishore vs. ITO (2019) 110 taxmann.com 307 (Delhi-Tribunal.) 5. Anip Rastogi vs. ITO in ITANo.3809/Del/2018 (I.T.A.T

ITO, BHADRAK WARD, BHADRAK vs. KISHORE KUMAR MOHAPATRA, BHADRAK

In the result, Appeals of the revenue in in ITANos

Bench: Shri C.M. Garg, Jm & Shri Manish Borad, Am

bogus LTCG. Reliance was placed on following decisions: 1. Suman Poddar vs. ITO (2019) 112 taxmann.com 330 (SC) 2. Sanjay Bimalchand Jain vs. Pr. CIT (2018) 89 taxmann.com 196(Bombay) 3. Pooja Ajmani vs. ITO (2019) 106 Taxmann.com 65(Delhi- Tri.) 4. Satish Kishore vs. ITO (2019) 110 taxmann.com 307 (Delhi-Tribunal.) 5. Anip Rastogi vs. ITO in ITANo.3809/Del/2018 (I.T.A.T

ITO, BHADRAK WARD , BHADRAK vs. PARBATI MOHAPATRA, BHADRAK

In the result, Appeals of the revenue in in ITANos

Bench: Shri C.M. Garg, Jm & Shri Manish Borad, Am

bogus LTCG. Reliance was placed on following decisions: 1. Suman Poddar vs. ITO (2019) 112 taxmann.com 330 (SC) 2. Sanjay Bimalchand Jain vs. Pr. CIT (2018) 89 taxmann.com 196(Bombay) 3. Pooja Ajmani vs. ITO (2019) 106 Taxmann.com 65(Delhi- Tri.) 4. Satish Kishore vs. ITO (2019) 110 taxmann.com 307 (Delhi-Tribunal.) 5. Anip Rastogi vs. ITO in ITANo.3809/Del/2018 (I.T.A.T

ITO, BHADRAK WARD, BHADRAK vs. SMT. KUNTALA MOHAPATRA, BHADRAK

In the result, Appeals of the revenue in in ITANos

Bench: Shri C.M. Garg, Jm & Shri Manish Borad, Am

bogus LTCG. Reliance was placed on following decisions: 1. Suman Poddar vs. ITO (2019) 112 taxmann.com 330 (SC) 2. Sanjay Bimalchand Jain vs. Pr. CIT (2018) 89 taxmann.com 196(Bombay) 3. Pooja Ajmani vs. ITO (2019) 106 Taxmann.com 65(Delhi- Tri.) 4. Satish Kishore vs. ITO (2019) 110 taxmann.com 307 (Delhi-Tribunal.) 5. Anip Rastogi vs. ITO in ITANo.3809/Del/2018 (I.T.A.T