SAHOO DISTRIBUTERS PRIVATE LIMITED,JAJPUR vs. ASSTT. CIT, CENTRAL CIRCLE, CUTTACK

In the result, appeals of the assessee stand partly allowed for statistical purposes

Bench: Before Shri George Mathanmember & Manish Agarwal

Section 40A(3) of the Act and in not considering the business exigency and application of Rule 6DD of I.T. Rules, the impugned addition made by the learned A.O. and confirmed by the learned CIT (Appeal) thus, being not sustainable in the eye of law, needs to be deleted in the interest of justice. 5. For that, when the reassessment

SAHOO DIOSTRIBUTERS PRIVATE LIMITED,JAJPUR vs. ASSTT.CIT, CENTRAL CIRCLE, CUTTACK

In the result, appeals of the assessee stand partly allowed for statistical purposes

Bench: Before Shri George Mathanmember & Manish Agarwal

Section 40A(3) of the Act and in not considering the business exigency and application of Rule 6DD of I.T. Rules, the impugned addition made by the learned A.O. and confirmed by the learned CIT (Appeal) thus, being not sustainable in the eye of law, needs to be deleted in the interest of justice. 5. For that, when the reassessment

SAHOO DISTRIBNUTORS (P) LIMITED,JAJPUR vs. ASSTT. CIT, CENTRAL CIRCLE, CUTTACK

In the result, appeals of the assessee stand partly allowed for statistical purposes

Bench: Before Shri George Mathanmember & Manish Agarwal

Section 40A(3) of the Act and in not considering the business exigency and application of Rule 6DD of I.T. Rules, the impugned addition made by the learned A.O. and confirmed by the learned CIT (Appeal) thus, being not sustainable in the eye of law, needs to be deleted in the interest of justice. 5. For that, when the reassessment

SAHOO DISTRIBUTERS PRIVATE LIMITED,JAJPUR vs. ASST,CIT, CENTRAL CIRCLE , AAYAKAR BHAWAN

In the result, appeals of the assessee stand partly allowed for statistical purposes

Bench: Before Shri George Mathanmember & Manish Agarwal

Section 40A(3) of the Act and in not considering the business exigency and application of Rule 6DD of I.T. Rules, the impugned addition made by the learned A.O. and confirmed by the learned CIT (Appeal) thus, being not sustainable in the eye of law, needs to be deleted in the interest of justice. 5. For that, when the reassessment

SAHOO DISTRIBUTERS PRIVATE LIMITED,JAJPUR vs. ASSTT. CIT, CENTRAL CIRCLE, CUTTACK

In the result, appeals of the assessee stand partly allowed for statistical purposes

Bench: Before Shri George Mathanmember & Manish Agarwal

Section 40A(3) of the Act and in not considering the business exigency and application of Rule 6DD of I.T. Rules, the impugned addition made by the learned A.O. and confirmed by the learned CIT (Appeal) thus, being not sustainable in the eye of law, needs to be deleted in the interest of justice. 5. For that, when the reassessment

SAHOO DISTRIBUTERS PRIVATE LIMITED,JAJPUR vs. ASSTT.CIT, CENTRAL CIRCLE, CUTTACK

In the result, appeals of the assessee stand partly allowed for statistical purposes

Bench: Before Shri George Mathanmember & Manish Agarwal

Section 40A(3) of the Act and in not considering the business exigency and application of Rule 6DD of I.T. Rules, the impugned addition made by the learned A.O. and confirmed by the learned CIT (Appeal) thus, being not sustainable in the eye of law, needs to be deleted in the interest of justice. 5. For that, when the reassessment

SAHOO DISTRIBUTERS PRIVATE LIMITED,JAJPUR vs. ASST.CIT,CENTRAL CIRCLE, AAYAKAR BHAWAN,SHELTER SQUARE,

In the result, appeals of the assessee stand partly allowed for statistical purposes

Bench: Before Shri George Mathanmember & Manish Agarwal

Section 40A(3) of the Act and in not considering the business exigency and application of Rule 6DD of I.T. Rules, the impugned addition made by the learned A.O. and confirmed by the learned CIT (Appeal) thus, being not sustainable in the eye of law, needs to be deleted in the interest of justice. 5. For that, when the reassessment

SAHOO DISTRIBUTERS PRIVATE LIMITED,JAJPUR vs. ASSTT. CIT, CENTRAL CIRCLE, CUTTACK

In the result, appeals of the assessee stand partly allowed for statistical purposes

Bench: Before Shri George Mathanmember & Manish Agarwal

Section 40A(3) of the Act and in not considering the business exigency and application of Rule 6DD of I.T. Rules, the impugned addition made by the learned A.O. and confirmed by the learned CIT (Appeal) thus, being not sustainable in the eye of law, needs to be deleted in the interest of justice. 5. For that, when the reassessment

DCIT,CIRCLE-1(1), CUTTACK vs. SHRI ASHO KUMAR GHANSHYAMDAS TIBAREWAL, CUTTACK

In the result, appeals filed by the revenue are dismissed

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaassessment Year : 2013-14 Dcit, Circle- -1(1) Vs. Sri Sri Ashok Ashok Kumar Kumar Cuttack Ghanshyamdas Ghanshyamdas Tebarewal, Tebarewal, Prop. Prop. Bisandayal Bisandayal Jewellers, Jewellers, Naya Sarak, Cuttack Naya Sarak, Cuttack Pan/Gir No. Pan/Gir No.Aaxpt 7747 E (Appellant (Appellant) .. ( Respondent Respondent) Assessment Year : 2013-14 Dcit, Circle- -1(1) Vs. Sri Sri Dilip Dilip Kumar Kumar Cuttack Ghanshyamdas Ghanshyamdas Tebarewal, Tebarewal, Prop. Prop. Bisandayal Bisandayal Jewellers, Jewellers, Naya Sarak, Cuttack Naya Sarak, Cuttack Pan/Gir No. Pan/Gir No.Aaxpt 7748 E (Appellant (Appellant) .. ( Respondent Respondent)

condone the delay of 250 and 234 days in filing the appeals by the revenue in the respective appeals and admit the appeals for hearing. 6. The first ground was against the action of the ld CIT(A) in deleting the addition made by the AO representing the revaluation of closing stock. 7. It was submitted

DCIT, CIRCLE-1(1), CUTTACK vs. SHRI DILIP KUMAR GHASHYAMDAS TEBREWAL, CUTTACK

In the result, appeals filed by the revenue are dismissed

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaassessment Year : 2013-14 Dcit, Circle- -1(1) Vs. Sri Sri Ashok Ashok Kumar Kumar Cuttack Ghanshyamdas Ghanshyamdas Tebarewal, Tebarewal, Prop. Prop. Bisandayal Bisandayal Jewellers, Jewellers, Naya Sarak, Cuttack Naya Sarak, Cuttack Pan/Gir No. Pan/Gir No.Aaxpt 7747 E (Appellant (Appellant) .. ( Respondent Respondent) Assessment Year : 2013-14 Dcit, Circle- -1(1) Vs. Sri Sri Dilip Dilip Kumar Kumar Cuttack Ghanshyamdas Ghanshyamdas Tebarewal, Tebarewal, Prop. Prop. Bisandayal Bisandayal Jewellers, Jewellers, Naya Sarak, Cuttack Naya Sarak, Cuttack Pan/Gir No. Pan/Gir No.Aaxpt 7748 E (Appellant (Appellant) .. ( Respondent Respondent)

condone the delay of 250 and 234 days in filing the appeals by the revenue in the respective appeals and admit the appeals for hearing. 6. The first ground was against the action of the ld CIT(A) in deleting the addition made by the AO representing the revaluation of closing stock. 7. It was submitted

INCOME TAX OFFICER, WARD-1, JHARSUGUDA, AAYAKAR BHAWAN, JHARSUGUDA vs. HIRAKHAND TRANSPORT AND MULTI PURPOSE CO-OPERATIVE SOCIETY LTD., BRAJARAJ NAGAR

Bench: Shri George Mathan & Shri Manish Agarwalआयकर अऩीऱ सं/Ita No.282/Ctk/2024 (ननधाारण वषा / Assessment Year : 2015-2016) Ito, Ward-1, Jharsuguda Vs Hirakhand Transport & Multi Purpose Cooperative Society Pvt. Ltd., At-Chingriguda, Bijapara, R Kudopali, Brajrajnagar, Jharsuguda-768216 Pan No. :Aaaah 5874 Q & प्रत्याक्षेऩ सं/Cross Objection No.04/Ctk/2024 (Arising Out Of Ita No.282/Ctk/2024) (ननधाारण वषा / Assessment Year : 2015-2016) Hirakhand Transport & Multi Vs Ito, Ward-1, Jharsuguda Purpose Cooperative Society Pvt. Ltd., At-Chingriguda, Bijapara, R Kudopali, Brajrajnagar, Jharsuguda-768216 Pan No. :Aaaah 5874 Q (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. ननधााररती की ओर से /Assessee By : Shri Anil Kumar Agrawala, Ca राजस्व की ओर से /Revenue By : Shri Sanjay Kumar, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 04/09/2024 घोषणा की तारीख/Date Of Pronouncement : 04/09/2024 आदेश / O R D E R Per Bench : This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, Dated 15.05.2024, Passed In Din & Order No.Itba/Nfac/S/250/2024- 25/1064895008(1) For The Assessment Year 2015-2016, On The Following Grounds Of Appeal :-

delay is hereby condoned and the cross objections are admitted for adjudication on merits. 4. The assessee in his cross objection has challenged the assessment order on the jurisdictional issue. Therefore, before going into the grounds 5 & CO No.04/CTK/2024 of appeal taken by the revenue, we first decide the technical/legal objections taken about the validity of reassessment order

SWASTHYA BIKASH SAMITI SCB MIDICAL COLLEGE HOSPITAL,CUTTACK vs. ITO(EXEMPTION), CUTTACK

In the result appeal of the assessee allowed

Bench: Before Shri George Mathan, Judicial & Manish Agarwal Manish Agarwalita Nos.324 To 328/Ctk/20 /Ctk/2023 Assessment Years : 2003-04 To 2007 04 To 2007-08 Swasthya Swasthya Bikash Bikash Samity, Samity, Vs. Ito (Exemption), Ito (Exemption), Scb Cb Medical Medical College College Aayakar Bhavan, Cuttack Aayakar Bhavan, Cuttack Hospital,Mangalabag, Hospital,Mangalabag, Cuttack Pan/Gir No Pan/Gir No.Aaeas 5600 H (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : None (Adjn Petition) : None (Adjn Petition) Revenue By : Shri S.C.Mohanty, Sr : Shri S.C.Mohanty, Sr Dr Date Of Hearing : 06/0 06/2024 Date Of Pronouncement : 06/0 /06/2024 O R D E R Per Bench

condonation of delay from the Hon’ble High Court of Orissa. Since the regular tax bench of the Hon’ble High Court is not functioning for summer vacation, only exceptional urgent matters which cannot wait till the reopening of High Court will be moved before the Hon’ble Vacation Judges for this reason appellant has been restricted to move towards

SWASTHYA BIKASH SAMITI, SCB MEDICAL COLLEGE,CUTTACK vs. ITO(EXEMPTION), CUTTACK

In the result appeal of the assessee allowed

Bench: Before Shri George Mathan, Judicial & Manish Agarwal Manish Agarwalita Nos.324 To 328/Ctk/20 /Ctk/2023 Assessment Years : 2003-04 To 2007 04 To 2007-08 Swasthya Swasthya Bikash Bikash Samity, Samity, Vs. Ito (Exemption), Ito (Exemption), Scb Cb Medical Medical College College Aayakar Bhavan, Cuttack Aayakar Bhavan, Cuttack Hospital,Mangalabag, Hospital,Mangalabag, Cuttack Pan/Gir No Pan/Gir No.Aaeas 5600 H (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : None (Adjn Petition) : None (Adjn Petition) Revenue By : Shri S.C.Mohanty, Sr : Shri S.C.Mohanty, Sr Dr Date Of Hearing : 06/0 06/2024 Date Of Pronouncement : 06/0 /06/2024 O R D E R Per Bench

condonation of delay from the Hon’ble High Court of Orissa. Since the regular tax bench of the Hon’ble High Court is not functioning for summer vacation, only exceptional urgent matters which cannot wait till the reopening of High Court will be moved before the Hon’ble Vacation Judges for this reason appellant has been restricted to move towards

SWASTHA BIKASH SAMITI, SCB MEDICAL COLLEGE,CUTTACK vs. ITO(EXEMPTION), CUTTACK

In the result appeal of the assessee allowed

Bench: Before Shri George Mathan, Judicial & Manish Agarwal Manish Agarwalita Nos.324 To 328/Ctk/20 /Ctk/2023 Assessment Years : 2003-04 To 2007 04 To 2007-08 Swasthya Swasthya Bikash Bikash Samity, Samity, Vs. Ito (Exemption), Ito (Exemption), Scb Cb Medical Medical College College Aayakar Bhavan, Cuttack Aayakar Bhavan, Cuttack Hospital,Mangalabag, Hospital,Mangalabag, Cuttack Pan/Gir No Pan/Gir No.Aaeas 5600 H (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : None (Adjn Petition) : None (Adjn Petition) Revenue By : Shri S.C.Mohanty, Sr : Shri S.C.Mohanty, Sr Dr Date Of Hearing : 06/0 06/2024 Date Of Pronouncement : 06/0 /06/2024 O R D E R Per Bench

condonation of delay from the Hon’ble High Court of Orissa. Since the regular tax bench of the Hon’ble High Court is not functioning for summer vacation, only exceptional urgent matters which cannot wait till the reopening of High Court will be moved before the Hon’ble Vacation Judges for this reason appellant has been restricted to move towards

SWASTHYA BIKASH SAMITI, SCB MEDICAL COLLEGE,CUTTACK vs. ITO(EXEMPTION), CUTTACK

In the result appeal of the assessee allowed

Bench: Before Shri George Mathan, Judicial & Manish Agarwal Manish Agarwalita Nos.324 To 328/Ctk/20 /Ctk/2023 Assessment Years : 2003-04 To 2007 04 To 2007-08 Swasthya Swasthya Bikash Bikash Samity, Samity, Vs. Ito (Exemption), Ito (Exemption), Scb Cb Medical Medical College College Aayakar Bhavan, Cuttack Aayakar Bhavan, Cuttack Hospital,Mangalabag, Hospital,Mangalabag, Cuttack Pan/Gir No Pan/Gir No.Aaeas 5600 H (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : None (Adjn Petition) : None (Adjn Petition) Revenue By : Shri S.C.Mohanty, Sr : Shri S.C.Mohanty, Sr Dr Date Of Hearing : 06/0 06/2024 Date Of Pronouncement : 06/0 /06/2024 O R D E R Per Bench

condonation of delay from the Hon’ble High Court of Orissa. Since the regular tax bench of the Hon’ble High Court is not functioning for summer vacation, only exceptional urgent matters which cannot wait till the reopening of High Court will be moved before the Hon’ble Vacation Judges for this reason appellant has been restricted to move towards

SWASTHYA BIKASH SAMITI, SCB MEDICAL COLLEGE,CUTTACK vs. ITO(EXEMPTION), CUTTACK

In the result appeal of the assessee allowed

Bench: Before Shri George Mathan, Judicial & Manish Agarwal Manish Agarwalita Nos.324 To 328/Ctk/20 /Ctk/2023 Assessment Years : 2003-04 To 2007 04 To 2007-08 Swasthya Swasthya Bikash Bikash Samity, Samity, Vs. Ito (Exemption), Ito (Exemption), Scb Cb Medical Medical College College Aayakar Bhavan, Cuttack Aayakar Bhavan, Cuttack Hospital,Mangalabag, Hospital,Mangalabag, Cuttack Pan/Gir No Pan/Gir No.Aaeas 5600 H (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : None (Adjn Petition) : None (Adjn Petition) Revenue By : Shri S.C.Mohanty, Sr : Shri S.C.Mohanty, Sr Dr Date Of Hearing : 06/0 06/2024 Date Of Pronouncement : 06/0 /06/2024 O R D E R Per Bench

condonation of delay from the Hon’ble High Court of Orissa. Since the regular tax bench of the Hon’ble High Court is not functioning for summer vacation, only exceptional urgent matters which cannot wait till the reopening of High Court will be moved before the Hon’ble Vacation Judges for this reason appellant has been restricted to move towards

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

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