SHREE PRASAD JEWELLERS,ROURKELA vs. INCOME TAX OFFICER, WARD-1, ROURKELA

In the result, appeal of the assessee is allowed

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.177/Ctk/2025 (नििाारण वर्ा / Assessment Year : 2017-2018) Shree Prasad Jewellers, Vs Ito, Ward-1, Rourkela Sai Bihar, Sundargarh-770001 Pan No. :Abgfs 9081 E (अपीलार्थी /Appellant) (प्रत्यर्थी / Respondent) .. नििााररती की ओर से /Assessee By : Shri S.K.Agarwalla, Ar राजस्व की ओर से /Revenue By : Shri Vijay Singh, Sr.Dr सुनवाई की तारीख / Date Of Hearing : 02/12/2025 घोषणा की तारीख/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. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, Dated 18.09.2025 For The Assessment Year 2013-2014. 2. At The Outset, We Found That The Appeal Of The Assessee Is Delayed By 10 Days. In This Regard, The Assessee Has Filed Condonation Of Application Along With Affidavit Stating Sufficient Reasons For Condonation Of Delay, Which Are Not Found To Be False. Ld. Sr. Dr Did Not Object To Condone The Delay. Accordingly, We Condone The Delay Of 10 Days Delay & Proceed To Dispose Off The Appeal. 3. The Ld. Ar During The Course Of Hearing Submitted A Chart Stating Therein The Surviving Period Of Notice Issued U/S.148 Of The Act & Submitted That As Per The Decision Of The Hon’Ble Supreme Court In The Case

condone the delay of 10 days delay and proceed to dispose off the appeal. 3. The ld. AR during the course of hearing submitted a chart stating therein the surviving period of notice issued u/s.148 of the Act and submitted that as per the decision of the Hon’ble Supreme Court in the case 2 of Ashish Agarwal, reported

M/S. NALCO MINES EMPLOYEES UNION,KORAPUT vs. PR.CIT-1, SAMBALPUR

In the result, appeal of the assessee is disposed off with the directions to the competent authority –ld

Bench: S/Shri Chandra Mohan Garg & Manish Boradassessment Years: 2012-13 To 2017-18 Shri Pramod Kumar Moharana, Vs. Pr. Cit-1, Bhubaneswar.Of Nalco Mines Employees‟ Union, At: D-9, Sector-1, Nalco Township, Damanjodi,Dist: Koraput Pan/Gir No.Aclpm 0589 M (Appellant) .. ( Respondent) Assessee By : Shri Basudev Panda, Sr. Advocate Revenue By : Shri S.C.Mohanty Addl. Cit (Dr) Date Of Hearing : 27 /10/ 2021 Date Of Pronouncement : 23/12/2021 O R D E R Per Bench This Is An Appeal Filed By The Assessee Against The Order U/S.119(2)(B) Of The Income Tax Act, 1961 Of The Pr. Cit(A)-1, Bhubaneswar For The Assessment Years 2012-13 To 2017-18. Application Of Applicant/Assessee For Condonation Of Delay :- 2. Ld. Senior Counsel On Application Dated 28.03.2021 Submitted That The Hon‟Ble High Court Of Orissa Was Pleased To Direct To File Appeal Before The Tribunal For Adjudication & The Matter Was Disposed Of Vide W.P.(C) No.24445/2020, Dated 05.01.2021 & I.A.No.250/2021 Vide Dated 17.03.2021 For Consideration Of Explanation Of Assessee For The Delay In P A G E 1 | 20 Assessment Years: 2012-13 To 2017-18

condonation of delay and separately furnished to be allowed in toto. 13. Accordingly, ld. Senior Counsel submitted that the issue regarding population of the particular place since was already considered by competent authorities were accepted by the Hon'ble Tribunal as well as the Hon'ble Court and further scrutiny and review of the matter is beyond of the jurisdiction

URMILA KISHAN,ANGUL vs. COMMISSIONER OF INCOME-TAX (APPEALS), NATIONAL FACELESS APPEAL CENTRE (NFAC)

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: Shri Duvvuru Rl Reddy(Kz) & Shri Rakesh Mishra

condone the delay and admit the appeal for adjudication. 2. The assessee is in appeal before the Tribunal raising the following grounds of appeal which are more in the nature of submissions than the grounds of appeal but are reproduced as under: “1. Unjustified Addition of Unsecured Loans u/s 68 of the Act, Ld. AO has erred in facts

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, SAMBALPUR vs. SMT. INDRANI PATNAIK, ROURKELA

In the result, all the four appeals of the Revenue are dismissed

condone\nthe delay and admit the appeal for hearing.\n3. As the facts and circumstances are similar in ITA Nos. 179 &\n181/CTK/2020, hence, for brevity we will take ITA No.179/CTK/2020\nfor A.Y. 2009-10 and decide the issues accordingly.\nΑ.Υ. 2009-10\nITA No. 179/СТК/2020\n4. The first issue raised by the Revenue in ground

DEPUTY COMMISSIONER OF INCOME TAX, CENTAL CIRCLE, SAMBALPUR vs. SMT. INDRANI PATNAIK, ROURKELA

In the result, all the four appeals of the Revenue are dismissed

condone\nthe delay and admit the appeal for hearing.\n3. As the facts and circumstances are similar in ITA Nos. 179 &\n181/CTK/2020, hence, for brevity we will take ITA No.179/CTK/2020\nfor A.Y. 2009-10 and decide the issues accordingly.\nΑ.Υ. 2009-10\nITA No. 179/CTK/2020\n4. The first issue raised by the Revenue in ground

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, SAMBALPUR vs. SMT. INDRANI PATNAIK, ROURKELA

In the result, all the four appeals of the Revenue are dismissed

condone\nthe delay and admit the appeal for hearing.\n3. As the facts and circumstances are similar in ITA Nos. 179 &\n181/CTK/2020, hence, for brevity we will take ITA No.179/CTK/2020\nfor A.Y. 2009-10 and decide the issues accordingly.\nΑ.Υ. 2009-10\nITA No. 179/СТК/2020\n4. The first issue raised by the Revenue in ground

DEPUTY COMMISSIONER OF INCOME TAX, CENTAL CIRCLE, SAMBALPUR vs. SMT. INDRANI PATNAIK, ROURKELA

In the result, all the four appeals of the Revenue are dismissed

condone\nthe delay and admit the appeal for hearing.\n3. As the facts and circumstances are similar in ITA Nos. 179 &\n181/CTK/2020, hence, for brevity we will take ITA No.179/CTK/2020\nfor A.Y. 2009-10 and decide the issues accordingly.\nΑ.Υ. 2009-10\nITA No. 179/СТК/2020\n4. The first issue raised by the Revenue in ground

SMT. MAMTA SHARMA,BARGARH vs. PRINCIPAL CIT (CENTRAL) , VISAKHAPATNAM

In the result, appeal of the assessee is allowed

Bench: S/Shrichandra Mohan Garg & Manish Boradassessment Year :2012-13 Smt. Mamta Sharma, Ward Vs. Pr. Cit(Central), Visakhapatnam No.10, Near Govt. Bus Stand, Dist: Baragarh Pan/Gir No.Agvps 4382 G (Appellant) .. ( Respondent) Assessee By : Shri P.K.Mishra, Ar Revenue By : Shri M.K.Gautam, Cit (Dr) Date Of Hearing : 21/10/ 2021 Date Of Pronouncement :10/12/2021 O R D E R

condone the delay and admit the appeal for adjudication. 5. The assessee has raised the revised corrected grounds of appeal, which read as under; “1. For that, impugned order passed U/s.263 of the Act is without jurisdiction and without the authority of law, as the conditions for initiation of 263 proceedings are not fulfilled, as such, the impugned

BHAWANIPATNA CENTRAL CO-OPERATIVE BANK LTD,MAHAVIRPADA, BHAWANIPATNA vs. ASSTT. CIT,RANGE-1, SAMBALPUR

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

Bench: Before Shri George Mathan, Judicial & Manish Agarwal Manish Agarwalassessment Year : 2018-19

condonation of delay. Ld AR drew our attention to para 15 of the Form No.35, wherein, the assessee has given the following reasons for the delay: “In the peculiar circumstances of the case and more particularly on adopting the cost cutting measure, no specific person was entrusted with the day to day income tax work as it happens in other

M/S. NORTH EASTERN ELECTRICITY SUPPLY COMPANY OF ODISHA LIMITED,BHUBANESWAR vs. ACIT, CIRCLE-1(2), BHUBANESWAR

In the result, appeals of both the assessees stand partly allowed

condone the delay of respective days in respective appeals of the assessee being M/s North Eastern Electricity Supply Co. Ltd. and appeals are heard along with other assessee i.e. M/s Western Electricity Supply Co. Ltd. finally. 3. It was submitted by the ld. AR that the main issue in both the assessee’s appeals is against the action

M/S. NORTH ELECTRICITY SUPPLY COMPANY OF ODISHA,BHUBANESWAR vs. ACIT,CIRCLE-1(2), BHUBANESWAR

In the result, appeals of both the assessees stand partly allowed

condone the delay of respective days in respective appeals of the assessee being M/s North Eastern Electricity Supply Co. Ltd. and appeals are heard along with other assessee i.e. M/s Western Electricity Supply Co. Ltd. finally. 3. It was submitted by the ld. AR that the main issue in both the assessee’s appeals is against the action

WESTERN ELECTRICITY SUPPLY COMPANY OF ORISSA LTD.,SAMBALPUR vs. ACIT, CIRCLE-1(2), BHUBANESWAR

In the result, appeals of both the assessees stand partly allowed

condone the delay of respective days in respective appeals of the assessee being M/s North Eastern Electricity Supply Co. Ltd. and appeals are heard along with other assessee i.e. M/s Western Electricity Supply Co. Ltd. finally. 3. It was submitted by the ld. AR that the main issue in both the assessee’s appeals is against the action

M/S. WESTERN ELECTRICITY SUPPLY COMPANY OF ORISSA LTD.,SAMBALPUR vs. ACIT, CIRCLE-1(2), BHUBANESWAR

In the result, appeals of both the assessees stand partly allowed

condone the delay of respective days in respective appeals of the assessee being M/s North Eastern Electricity Supply Co. Ltd. and appeals are heard along with other assessee i.e. M/s Western Electricity Supply Co. Ltd. finally. 3. It was submitted by the ld. AR that the main issue in both the assessee’s appeals is against the action

DHANESWAR RATH INSTITUTE OF ENGINEERING AND MEDICAL SCIENCES,CUTTACK vs. CIT(EXEMPTION), HYDERABAD

In the result, appeal of the assesse is allowed

condone the delay of 198 days and admit the appeal for adjudication. 5. The sole grievance raised in the grounds of appeal is that the CIT(Exemptions), Hyderabad has passed the revision order u/s.263 of the Act, in a hurriedly manner without providing reasonable opportunity of hearing to the assessee. 6. Facts of the case are that the assessee

SADHANA FOUNDATION,BHUBANESWAR vs. ITO (EXEMPTION) BHUBANESWAR, BHUBANESWAR

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

Bench: Shri Duvvuru Rl Reddy(Kz) & Shri Rakesh Mishra

section 143(1) of the Act. The Ld. Addl./Joint CIT(A) dismissed the appeal as the same was delayed by 900 days and the Ld. AR submitted that if the COVID period is excluded, the delay is only of 235 days but the appeal was dismissed in limine. The intimation is dated 31 March 2019 but is stated

PASUPATI FEEDS,CUTTACK vs. PRINCIPAL CIT(CENTRAL), VISAKHAPATNAM

In the result, cross objections filed by the assessee for assessment years 2008-09 to 2010-2011 are allowed and that the appeals of revenue are dismissed

Bench: S/ S/Shri Chandra Mohan Garg, Judicial & Manish Borad & Manish Borad & Manish Boradit(Ss)A Nos.45 To 47/Ctk/20 /Ctk/2018 Assessment Year Assessment Years : 2008-09 To 2010 09 To 2010-2011 Acit, Central Circle, Acit, Central Circle, Vs. M/S. Pasupati Feeds, Kota Sahi, M/S. Pasupati Feeds, Kota Sahi, Cuttack Tangi, Cuttack Tangi, Cuttack Pan/Gir No. No.Aaefp 4117 F (Appellant (Appellant) .. ( Respondent Respondent) C.O.Nos.33 To 35/Ctk/2018 C.O.Nos.33 To 35/Ctk/2018 (Arising Out Of It (Arising Out Of It(Ss)A Nos.45 To 47/Ctk/2018) A Nos.45 To 47/Ctk/2018) Assessment Years: 2008 Assessment Years: 2008-09 To 2010 09 To 2010-2011

31,88,860/- - 2011-12 2012-13 8,65,64,973/- 63,21,416/- 64,92,373/ 64,92,373/- - 2012-13 2013-14 7,98,68,487/- 69,96,381/- 59,90,136/ 69,61,374/- - 2013-14 2014-15 8,18,89,655/- 56,81,850/- 61,41,724/ 61,41,724/- - TOTAL

PASUPATI FEEDS,CUTTACK vs. PRINCIPAL CIT(CENTRAL), VISAKHAPATNAM

In the result, cross objections filed by the assessee for assessment years 2008-09 to 2010-2011 are allowed and that the appeals of revenue are dismissed

Bench: S/ S/Shri Chandra Mohan Garg, Judicial & Manish Borad & Manish Borad & Manish Boradit(Ss)A Nos.45 To 47/Ctk/20 /Ctk/2018 Assessment Year Assessment Years : 2008-09 To 2010 09 To 2010-2011 Acit, Central Circle, Acit, Central Circle, Vs. M/S. Pasupati Feeds, Kota Sahi, M/S. Pasupati Feeds, Kota Sahi, Cuttack Tangi, Cuttack Tangi, Cuttack Pan/Gir No. No.Aaefp 4117 F (Appellant (Appellant) .. ( Respondent Respondent) C.O.Nos.33 To 35/Ctk/2018 C.O.Nos.33 To 35/Ctk/2018 (Arising Out Of It (Arising Out Of It(Ss)A Nos.45 To 47/Ctk/2018) A Nos.45 To 47/Ctk/2018) Assessment Years: 2008 Assessment Years: 2008-09 To 2010 09 To 2010-2011

31,88,860/- - 2011-12 2012-13 8,65,64,973/- 63,21,416/- 64,92,373/ 64,92,373/- - 2012-13 2013-14 7,98,68,487/- 69,96,381/- 59,90,136/ 69,61,374/- - 2013-14 2014-15 8,18,89,655/- 56,81,850/- 61,41,724/ 61,41,724/- - TOTAL

M/S- RAWAT BALAJI (JOINT VENTURE),JHARSUGUDA vs. PRILNCIPAL, 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