M/S- SBEP-GRIL(JOINT VENTURE),JHARSUGUDA vs. PRINCIPAL CIT, SAMBALPUR

In the result, appeal of the assessee in ITA No

Bench: Shri C.M. Garg, Jm & Shri Manish Borad, Am आयकर अपीऱ सं./Ita Nos.193/Ctk/2019 (नििाारण वषा / Assessment Year :2014-2015) M/S Rawats-Balaji(Jv), Vs Pr.Cit, Sambalpur At/Po-Belpahar(Rs), Dist : Jharsuguda Pan No. : Aabar 9061 J Tan No. : Bbnr01647 C & आयकर अपीऱ सं./Ita Nos.194/Ctk/2019 (नििाारण वषा / Assessment Year :2014-2015) M/S Sbepl-Gril(Jv), Vs Pr.Cit, Sambalpur At/Po-Belpahar(Rs), Dist : Jharsuguda Pan No. : Aafas 2639 R Tan No. : Bbns04348 B & आयकर अपीऱ सं./Ita Nos.195/Ctk/2019 (नििाारण वषा / Assessment Year :2014-2015) Shree Balaji Engicons Pvt Ltd Vs Pr.Cit, Sambalpur At/Po-Belpahar(Rs), Dist : Jharsuguda Pan No. : Aagcs 4292 P Tan No. : Bbns00091 A (अऩीलाथी /Appellant) (प्रत्यथी / Respondent) .. ननधाारिती की ओर से /Assessee By : Shri Satyanarayan Agarwal, Ar िाजस्व की ओर से /Revenue By : Shri M.K.Gautam, Citdr सुनवाई की तािीख / Date Of Hearing : 26/10/2021 घोषणा की तािीख/Date Of Pronouncement : 23/12/2021 आदेश / O R D E R Per Bench: These Three Appeals Have Been Filed By Three Different Assessees Against The Order Passed By The Pr.Cit, Sambalpur, U/S.263 Of The Act, All Dated 30.03.2019 For The Assessment Year 2014-2015. 2

condone the delay and admit all the three appeals for adjudication. 4. Since similar and identical issues involved in all the three appeals of the assessees, therefore they are heard altogether and disposed off by this consolidated order en masse. 5. Ld. Assessee‟s Representative (AR) drew our attention towards two paper books of the assessee spread over 475 pages

SHREE BALAJI ENGICONS PVT. LTD,JHARSUGUDA vs. PRINCIPAL CIT, SAMBALPUR

In the result, appeal of the assessee in ITA No

Bench: Shri C.M. Garg, Jm & Shri Manish Borad, Am आयकर अपीऱ सं./Ita Nos.193/Ctk/2019 (नििाारण वषा / Assessment Year :2014-2015) M/S Rawats-Balaji(Jv), Vs Pr.Cit, Sambalpur At/Po-Belpahar(Rs), Dist : Jharsuguda Pan No. : Aabar 9061 J Tan No. : Bbnr01647 C & आयकर अपीऱ सं./Ita Nos.194/Ctk/2019 (नििाारण वषा / Assessment Year :2014-2015) M/S Sbepl-Gril(Jv), Vs Pr.Cit, Sambalpur At/Po-Belpahar(Rs), Dist : Jharsuguda Pan No. : Aafas 2639 R Tan No. : Bbns04348 B & आयकर अपीऱ सं./Ita Nos.195/Ctk/2019 (नििाारण वषा / Assessment Year :2014-2015) Shree Balaji Engicons Pvt Ltd Vs Pr.Cit, Sambalpur At/Po-Belpahar(Rs), Dist : Jharsuguda Pan No. : Aagcs 4292 P Tan No. : Bbns00091 A (अऩीलाथी /Appellant) (प्रत्यथी / Respondent) .. ननधाारिती की ओर से /Assessee By : Shri Satyanarayan Agarwal, Ar िाजस्व की ओर से /Revenue By : Shri M.K.Gautam, Citdr सुनवाई की तािीख / Date Of Hearing : 26/10/2021 घोषणा की तािीख/Date Of Pronouncement : 23/12/2021 आदेश / O R D E R Per Bench: These Three Appeals Have Been Filed By Three Different Assessees Against The Order Passed By The Pr.Cit, Sambalpur, U/S.263 Of The Act, All Dated 30.03.2019 For The Assessment Year 2014-2015. 2

condone the delay and admit all the three appeals for adjudication. 4. Since similar and identical issues involved in all the three appeals of the assessees, therefore they are heard altogether and disposed off by this consolidated order en masse. 5. Ld. Assessee‟s Representative (AR) drew our attention towards two paper books of the assessee spread over 475 pages

RONALD EDUCATIONAL & CHARITABLE TRUST,GANJAM vs. CHEIF CIT, BHUBANESWAR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

condoned so as to make way for the cause of substantial justice. We accordingly hold that assessee’s impugned delay (supra) is neither intentional nor deliberate but due to circumstances beyond its control. Cases are now taken up for adjudication on merits. 4. We advert to the sole identical issue of section 10(23C)(vi) approval raised in assessee

ROLAND EDUCATIONAL & CHARITABLE TRUST,GANJAM vs. CHEIF CIT, BHUBANESWAR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

condoned so as to make way for the cause of substantial justice. We accordingly hold that assessee’s impugned delay (supra) is neither intentional nor deliberate but due to circumstances beyond its control. Cases are now taken up for adjudication on merits. 4. We advert to the sole identical issue of section 10(23C)(vi) approval raised in assessee

ROLAND INSTITUTE OF PHARMACEUTICAL SCIENCES,GANJAM vs. CHEIF CIT, BHUBANESWAR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

condoned so as to make way for the cause of substantial justice. We accordingly hold that assessee’s impugned delay (supra) is neither intentional nor deliberate but due to circumstances beyond its control. Cases are now taken up for adjudication on merits. 4. We advert to the sole identical issue of section 10(23C)(vi) approval raised in assessee

ROLAND EDUCATIONAL & CHARITABLE TRUST,GANJAM vs. CHEIF CIT, BHUBANESWAR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

condoned so as to make way for the cause of substantial justice. We accordingly hold that assessee’s impugned delay (supra) is neither intentional nor deliberate but due to circumstances beyond its control. Cases are now taken up for adjudication on merits. 4. We advert to the sole identical issue of section 10(23C)(vi) approval raised in assessee

ROLAND INSTITUTE OF PHARMACEUTICAL SCIENCES,GANJAM vs. CHEIF CIT, BHUBANESWAR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

condoned so as to make way for the cause of substantial justice. We accordingly hold that assessee’s impugned delay (supra) is neither intentional nor deliberate but due to circumstances beyond its control. Cases are now taken up for adjudication on merits. 4. We advert to the sole identical issue of section 10(23C)(vi) approval raised in assessee

ROLAND EDUCATIONAL & CHARITABLE TRUST,GANJAM vs. CHEIF CIT, BHUBANESWAR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

condoned so as to make way for the cause of substantial justice. We accordingly hold that assessee’s impugned delay (supra) is neither intentional nor deliberate but due to circumstances beyond its control. Cases are now taken up for adjudication on merits. 4. We advert to the sole identical issue of section 10(23C)(vi) approval raised in assessee

ROLAND EDUCATIONAL & CHARITABLE TRUST,BERHAMPUR vs. DCIT, BERHAMPUR CIRCLE, BERHAMPUR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

condoned so as to make way for the cause of substantial justice. We accordingly hold that assessee’s impugned delay (supra) is neither intentional nor deliberate but due to circumstances beyond its control. Cases are now taken up for adjudication on merits. 4. We advert to the sole identical issue of section 10(23C)(vi) approval raised in assessee

ROLAND INSTITUTE OF PHARMACEUTICAL SCIENCES,GANJAM vs. CHEIF CIT, BHUBANESWAR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

condoned so as to make way for the cause of substantial justice. We accordingly hold that assessee’s impugned delay (supra) is neither intentional nor deliberate but due to circumstances beyond its control. Cases are now taken up for adjudication on merits. 4. We advert to the sole identical issue of section 10(23C)(vi) approval raised in assessee

ROLAND EDUCATIONAL & CHARITABLE TRUST,GANJAM vs. CHEIF CIT, BHUBANESWAR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

condoned so as to make way for the cause of substantial justice. We accordingly hold that assessee’s impugned delay (supra) is neither intentional nor deliberate but due to circumstances beyond its control. Cases are now taken up for adjudication on merits. 4. We advert to the sole identical issue of section 10(23C)(vi) approval raised in assessee

ROLAND EDUCATIONAL & CHARITABLE TRUST,GANJAM vs. CHEIF CIT, BHUBANESWAR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

condoned so as to make way for the cause of substantial justice. We accordingly hold that assessee’s impugned delay (supra) is neither intentional nor deliberate but due to circumstances beyond its control. Cases are now taken up for adjudication on merits. 4. We advert to the sole identical issue of section 10(23C)(vi) approval raised in assessee

ROLAND EDUCATIONAL & CHARITABLE TRUST,BERHAMPUR vs. DCIT, BERHAMPUR CIRCLE, BERHAMPUR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

condoned so as to make way for the cause of substantial justice. We accordingly hold that assessee’s impugned delay (supra) is neither intentional nor deliberate but due to circumstances beyond its control. Cases are now taken up for adjudication on merits. 4. We advert to the sole identical issue of section 10(23C)(vi) approval raised in assessee

ROLAND EDUCATIONAL & CHARITABLE TRUST,BERHAMPUR vs. DCIT, BERHAMPUR CIRCLE, BERHAMPUR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

condoned so as to make way for the cause of substantial justice. We accordingly hold that assessee’s impugned delay (supra) is neither intentional nor deliberate but due to circumstances beyond its control. Cases are now taken up for adjudication on merits. 4. We advert to the sole identical issue of section 10(23C)(vi) approval raised in assessee

ROLAND INSTITUTE OF PHARMACEUTICAL SCIENCES,GANJAM vs. CHEIF CIT, BHUBANESWAR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

condoned so as to make way for the cause of substantial justice. We accordingly hold that assessee’s impugned delay (supra) is neither intentional nor deliberate but due to circumstances beyond its control. Cases are now taken up for adjudication on merits. 4. We advert to the sole identical issue of section 10(23C)(vi) approval raised in assessee

ROLAND INSTITUTE OF PHARMACEUTICAL SCIENCES,GANJAM vs. CHEIF CIT, BHUBANESWAR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

condoned so as to make way for the cause of substantial justice. We accordingly hold that assessee’s impugned delay (supra) is neither intentional nor deliberate but due to circumstances beyond its control. Cases are now taken up for adjudication on merits. 4. We advert to the sole identical issue of section 10(23C)(vi) approval raised in assessee

PARADIP PORT AUTHORITY,JAGATSINGHPUR vs. DCIT,CIRCLE-1(1), CUTTACK

In the result, all the three appeals of the assessee are allowed

delay should be condoned. 5. Consequent upon the order of the Hon'ble High Court of Orissa and after due consideration of the submission of the assessee, the total income of the assessee was computed as Rs.Nil after allowing the benefit of exemption u/s 11 of the Act for all the subject assessment years. Copy of the order dated

PARADIP PORT AUTHORITY,JAGATSINGHPUR vs. DCIT,CIRCLE-1(1), CUTTACK

In the result, all the three appeals of the assessee are allowed

delay should be condoned. 5. Consequent upon the order of the Hon'ble High Court of Orissa and after due consideration of the submission of the assessee, the total income of the assessee was computed as Rs.Nil after allowing the benefit of exemption u/s 11 of the Act for all the subject assessment years. Copy of the order dated