STATE POLLUTION CONTROL BOARD ODISHA,BHUBANESWAR vs. ITO, WARAD 5(2), BHUBANESWAR, BHUBANESWAR

In the result, appeal of the assessee stands allowed and stay petition stands dismissed

Bench: Before Shri George Mathanmember & Manish Agarwal Manish Agarwals.P.No.11/Ctk/2024 Assessment Year :2017-18 State Pollution Control Board State Pollution Control Board, Vs. Ito, Ward 5(2), Plot No.A-118, Paribesh Bhawan, 118, Paribesh Bhawan, Bhubaneswar Nilakantha Nagar, Agar, Nayapali, Nayapali, Unit-Vii, Bhubaneswar Neswar Pan/Gir No.Aaals 2490 J Aaals 2490 J (Appellant) (Appellant .. ( Respondent Respondent) Assessee By : Shri S.K.Agrawalla, Ca Walla, Ca Revenue By : Shri Sanjay Kumar, Cit Sanjay Kumar, Cit Dr Date Of Hearing : 24/10/20 2024 Date Of Pronouncement : 24/10/20 024 O R D E R Per Bench

disallowed the exemption u/s 10(46) Act even if the income of the assessee is exempted as per the notification issued by the Ministry of Finance, Govt. of India, therefore the exemption u/s 10(46) is to be allowed. 2.2 During the course of the instant appellate proceedings the appellant has filed on 13.09.2024 a paper book consisting

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

In the result, appeal of the assessee is allowed

disallowing the claim of the appellant regarding Long Term Capital Gains by ignoring the evidences and submissions made by the appellant. 2 3. For that under the facts and in the circumstance of the case the amount of Rs.65,55,972/- should not have been treated as unexplained cash credit u/s.68 and should have been accepted as income from Long

SUKANTI EDUCATIONAL AND CHARITABLE TRUST,SONEPUR vs. ITO,EXEMPTION WARD, SAMBALPUR

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

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

section 10(23C)(iiiad) being activity centric, the limit of Rs. 1 crore prescribed thereunder had to be seen only with reference to the fee and other receipts of the eligible activity/institution. Admittedly, those were below Rs. 1 crore. In the facts of the instant case, the eligibility condition prescribed by law was wholly met by the assessee. [Para

HANUMAN KHEDARIA HUF,ROURKELA vs. ITO WARD 2, ROURKELA, ROURKELA

In the result, appeal of the assessee stands allowed

Bench: Before S/Shri George Mathan, Judicial & Rajesh Kumarassessment Year : 2014-15 Hanuman Khedaria (Huf), Hanuman Khedaria (Huf), Vs. Ito, Ward Ito, Ward-2, Rourkela. C/O. Kadmawala & Co., Ca, C/O. Kadmawala & Co., Ca, Budhram Budhram Oram Oram Market, Market, Kachery Road, Rourkela. Kachery Road, Rourkela. Pan/Gir No. Pan/Gir No. (Appellant) ) .. ( Respondent Respondent) Assessee By : Shri M.R.Sahu, Ca .R.Sahu, Ca Revenue By : Shri Charan Dass, Sr. Shri Charan Dass, Sr. Dr Date Of Hearing : 01/12 12/2023 Date Of Pronouncement : 01/12 Date Of Pronouncement : 01/12/2023 O R D E R Per Bench

Section 10 (38) of the Income Tax Act, 1961 (Circular No.5/2005 dated 15.07.2005). 13. Mr. T.K. Satapathy, learned Senior Standing Counsel appearing for the Income Tax Department laid emphasis on the CBDT Circular No.23 of 2019 dated 06.09.2019, as the matter related to bogus Long Term Capital Gain on Penny stock. But the said circular can only be applied prospectively

SANDEEP KUMAR AGARWAL,JAGATPUR vs. ACIT,NFAC, DELHI, CUTTACK

In the result, appeal of the assessee stands allowed

Bench: Before Shri George Mathan, Judicial & Manish Agarwal Manish Agarwalassessment Year : 2014-15 Sandeep Sandeep Kumar Kumar Agarwal, Agarwal, Vs. Acit, Nfac, Delhi/Cuttack Acit, Nfac, Delhi/Cuttack C/O. Agarwal Spices & C/O. Agarwal Spices & Food Processors Pvt Ltd., Food Processors Pvt Ltd., Jagatpur. Pan/Gir No Pan/Gir No.Aarpa 8064 B (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri Mohit Sheth Mohit Sheth, Adv Revenue By : Shri Charan Dass, Ld Sr Dr , Ld Sr Dr Date Of Hearing : 28/0 05/2024 Date Of Pronouncement : 28/0 /05/2024 O R D E R Per Bench

disallowed the entire sale consideration to make the addition of Rs.81,41,052/-. It was the submission that the Assessing Officer had further made an addition of commission alleged to have been paid to intermediaries to an extent of Rs.4,07,053/- though no evidence of such expenditure was found nor it was claimed by the assessee

NESCO EMPLOYEES GRATUITY FUND TRUST,BALASORE vs. ITO, WARD-1, BALASORE, BALASORE

In the result, appeal of the assessee is allowed for statistical\npurposes

section 10(24). Therefore,\nthere is no apparent mistake in disallowing the claim u/s 143(1) of\nthe Act. Of course

MGM GREEN ENERGY LIMITED,BHUBANESWAR vs. DCIT,CIRCLE-1(1), BHUBANESWAR

In the result, appeal of the assessee is partly allowed

Bench: Shri George Mathan & Shri Manish Agarwalआयकर अऩीऱ सं/Ita No.370/Ctk/2019 (ननधाारण वषा / Assessment Year : 2014-2015) Mgm Green Energy Limited, Vs Jcit, Range Rourkela, Rourkela 5-A, Forest Park, Bhubaneswar Pan No. :Aahcm 8472 C (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. ननधााररती की ओर से /Assessee By : Sh A.K.Sabat & Sh B.K.Mahapatra, Cas राजस्व की ओर से /Revenue By : Shri Sanjay Kumar, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 22/05/2024 घोषणा की तारीख/Date Of Pronouncement : 22/05/2024 आदेश / O R D E R Per Bench : This Appeal Is Filed By The Assessee Against The Order Of The Ld. Cit(A)-1. Bhubaneswar, Dated 11.06.2019, In I.T.Appeal No.0388/16-17 For The Assessment Year 2014-2015. 2. The Assessee Has Taken As Many As Six Grounds Of Appeal, Relating To Various Additions/Disallowances Made To The Income Declared By The Assessee & Also Against The Adjustments Made In The Book Profit U/S.115Jb Of The Act. The Grounds Raised By The Assessee Are As Under :- I) The Ld. Cit(A) Is Erred In Dismissing The Appeal Of The Assessee, Which Is Arbitrary, Erroneous & Bad, Both In The Eyes Of Law. Ii) Disallowance Of Interest Expenses U/S.36(Iii) Of The Act At Rs.1,65,18,400/-; Iii) Disallowance Of Expenses U/S.14A Of The Act/Rule 8D Of It Rules At Rs.2,44,82,488/-; Iv) Addition Of Disallowance Of Expenses U/S.14A At Rs.2,44,82,488/- In The Book Profit As Computed U/S 115Jb; V) Addition/Disallowance Of Expenses U/S.115Jb Of The Act Under The Book Profits; Vi) Disallowance Of Differential Depreciation Of Rs.1,16,63,697/-

10 (other than the provisions contained in clause (38) thereof) or [***] section 11 or section 12 apply; or] 31. He thus prayed that the adjustment so made liable to be uphold and he prayed accordingly. 32. We have heard the rival contentions. In the instant case, as we have already held that provisions of section 14A cannot be invoked

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

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 and in law, CIT(A) erred in confirming disallowance of interest on TDS of Rs.66,103/- by applying Supreme Court decision in the case of 'Bharat Commerce Industries

M G MOHANTY,BHUBANESWAR vs. DCIT, CIRCLE-2(1), BHUBANESWAR

In the result, appeal of the assessee is partly allowed

Bench: Shri George Mathan & Shri Manish Agarwalआयकर अपील संसंसंसं/Ita No.402/Ctk/2024 (िनधा"रण िनधा"रण िनधा"रण वष" िनधा"रण वष" वष" / Assessment Years : 2008-2009) वष" M G Mohanty, Vs Dcit, Circle-2(1), Bhubaneswar 5A, Forest Park, Odisha Pan No. :Aaffm 2127 H (अपीलाथ" अपीलाथ" अपीलाथ" /Appellant) अपीलाथ" (""यथ" ""यथ" ""यथ" / Respondent) ""यथ" .. िनधा"रती क" िनधा"रती क" ओर ओर सेसेसेसे /Assessee By िनधा"रती िनधा"रती क" क" ओर ओर : Sh B.K.Mahapatra & Sh. A.K.Sabat, Cas राज"व राज"व क" राज"व राज"व क" क" ओर क" ओर ओर सेसेसेसे /Revenue By ओर : Dr. Abani Kanta Nayak, Cit-Dr सुनवाई क" तारीख / Date Of Hearing : 26/11/2024 घोषणा क" तारीख/Date Of Pronouncement : 26/11/2024 आदेश आदेश / O R D E R आदेश आदेश Per Bench : This Is An Appeal Filed By The Assessee Against The Order Of Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, Dated 01.08.2024, Passed In Appeal No.Cit(A), Bhubaneswar-1/10098/2016-17 Vide Din & Order No.Itba/Nfac/S/250/2024-25/1067224134(1) For The Assessment Year 2017-2018. 2. The Assessee Has Challenged The Appellate Order On The Following Grounds Of Appeal :- 1. That On The Facts & In The Circumstances Of The Case, The Order Of The Learned Commissioner Of Income Tax (Appeals), Nfac [In Short "Cit (Appeals)") Dated 01.08.2024 U/S 250 Of The Income Tax Act. 1961 [In Short "I.T.Act/ "Act] In Dismissing The Appeal Is Against The Principles Of Natural Justice, Contrary To Facts, Unjustified, Arbitrary, Erroneous, Bad, Both In The Eye Of Law & On Facts & Legally Untenable.

Section 37 of the Act is contrary to facts, unjustified, arbitrary, erroneous, bad, both in the eye of law and on facts and legally untenable. b. That in the facts and circumstances of the case, the learned CIT(Appeals) upholding the disallowance of Rs. 10

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

disallowed under section 40A(3) being protected by rule 6DD(b). [Annexure-A; Page-7-14] P a g e 10

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

disallowed under section 40A(3) being protected by rule 6DD(b). [Annexure-A; Page-7-14] P a g e 10

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

disallowed under section 40A(3) being protected by rule 6DD(b). [Annexure-A; Page-7-14] P a g e 10

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

disallowed under section 40A(3) being protected by rule 6DD(b). [Annexure-A; Page-7-14] P a g e 10

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

disallowed under section 40A(3) being protected by rule 6DD(b). [Annexure-A; Page-7-14] P a g e 10

SOFTWARE POINT,BHABA NAGAR vs. ITO, EXEMPTION, BERHAMPUR

In the result, appeal of the assessee is allowed

sections 10(23C)(iv), 10(23C)(v), 10(23C)(vi) & 10(23C)(via) of the Act. In column No.4, the computed and the difference of Rs.9697/- has been shown in column 9(c) as exemption u/s.10(23C)(iiiad) of the Act. It was the submission that the return filed by the assessee came to be processed and an intimation came

M/S. PRAGATI MILK PRODUCT PVT. LTD.,CUTTACK vs. ACIT, CENTRAL CIRCLE, CUTTACK

In the result, all the three appeals of the assessee for respective assessment years under consideration are allowed

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अऩीऱ सं/Ita Nos.143 To 145/Ctk/2022 (ननधाारण वषा / Assessment Year : 2012-2013 To 2014-2015) M/S Pragati Milk Products(P) Ltd. Vs Acit, Central Circle, Cuttack Plot No.71/A/1, New Industrial Estate, Jagatpur, Cuttack-754021 Pan No. :Aaecp 6353 J (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. ननधााररती की ओर से /Assessee By : Shri P.R.Mohanty, Advocate राजस्व की ओर से /Revenue By : Shri Dr. Abani Kanta Nayak, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 11/10/2023 घोषणा की तारीख/Date Of Pronouncement : 11/10/2023 आदेश / O R D E R Per Bench : These Are The Appeals Filed By The Assessee Against The Order Of The Ld. Cit(A)-2, Bhubaneswar, Dated 12.10.2018, Passed In I.T.Appeal No.0487/2017-18 For The Assessment Year 2012-2013. 2. It Was Submitted By The Ld. Ar That The Facts In All The Cases Are Identical. It Was The Submission That There Was Search In The Premises Of The Assessee. As A Consequence Of Search, Assessment Came To Be Completed U/S.153A Of The Act. In The Assessment U/S.153A Of The Act, The Assessee Had Been Granted The Benefit Of Deduction U/S.80Ib(11A) Of The Act. It Was The Submission That The Said Assessment Order Was The Subject Matter Of Rectification Application On Multiple Occasions & In The Third Round Of Rectification Application The Ao Has Withdrawn The Benefit Of Deduction U/S.80Ib (11A) Of The Act. It Was The Submission That The 2

10. Perusal of the order under section 154 reveals that during the rectificatory proceedings the Ld. AO required the assessee to show cause as to why its income be not recomputed as payments amounting to Rs. 23,72,40,000/- for expenditure made in violation of section 40A(3) of the Act were liable to be disallowed

M/S. PRAGATI MILK PRODUCT PVT. LTD.,CUTTACK vs. ACIT, CENTRAL CIRCLE, CUTTACK

In the result, all the three appeals of the assessee for respective assessment years under consideration are allowed

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अऩीऱ सं/Ita Nos.143 To 145/Ctk/2022 (ननधाारण वषा / Assessment Year : 2012-2013 To 2014-2015) M/S Pragati Milk Products(P) Ltd. Vs Acit, Central Circle, Cuttack Plot No.71/A/1, New Industrial Estate, Jagatpur, Cuttack-754021 Pan No. :Aaecp 6353 J (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. ननधााररती की ओर से /Assessee By : Shri P.R.Mohanty, Advocate राजस्व की ओर से /Revenue By : Shri Dr. Abani Kanta Nayak, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 11/10/2023 घोषणा की तारीख/Date Of Pronouncement : 11/10/2023 आदेश / O R D E R Per Bench : These Are The Appeals Filed By The Assessee Against The Order Of The Ld. Cit(A)-2, Bhubaneswar, Dated 12.10.2018, Passed In I.T.Appeal No.0487/2017-18 For The Assessment Year 2012-2013. 2. It Was Submitted By The Ld. Ar That The Facts In All The Cases Are Identical. It Was The Submission That There Was Search In The Premises Of The Assessee. As A Consequence Of Search, Assessment Came To Be Completed U/S.153A Of The Act. In The Assessment U/S.153A Of The Act, The Assessee Had Been Granted The Benefit Of Deduction U/S.80Ib(11A) Of The Act. It Was The Submission That The Said Assessment Order Was The Subject Matter Of Rectification Application On Multiple Occasions & In The Third Round Of Rectification Application The Ao Has Withdrawn The Benefit Of Deduction U/S.80Ib (11A) Of The Act. It Was The Submission That The 2

10. Perusal of the order under section 154 reveals that during the rectificatory proceedings the Ld. AO required the assessee to show cause as to why its income be not recomputed as payments amounting to Rs. 23,72,40,000/- for expenditure made in violation of section 40A(3) of the Act were liable to be disallowed

M/S. PRAGATI MILK PRODUCT PVT. LTD.,CUTTACK vs. ACIT, CENTRAL CIRCLE, CUTTACK

In the result, all the three appeals of the assessee for respective assessment years under consideration are allowed

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अऩीऱ सं/Ita Nos.143 To 145/Ctk/2022 (ननधाारण वषा / Assessment Year : 2012-2013 To 2014-2015) M/S Pragati Milk Products(P) Ltd. Vs Acit, Central Circle, Cuttack Plot No.71/A/1, New Industrial Estate, Jagatpur, Cuttack-754021 Pan No. :Aaecp 6353 J (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. ननधााररती की ओर से /Assessee By : Shri P.R.Mohanty, Advocate राजस्व की ओर से /Revenue By : Shri Dr. Abani Kanta Nayak, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 11/10/2023 घोषणा की तारीख/Date Of Pronouncement : 11/10/2023 आदेश / O R D E R Per Bench : These Are The Appeals Filed By The Assessee Against The Order Of The Ld. Cit(A)-2, Bhubaneswar, Dated 12.10.2018, Passed In I.T.Appeal No.0487/2017-18 For The Assessment Year 2012-2013. 2. It Was Submitted By The Ld. Ar That The Facts In All The Cases Are Identical. It Was The Submission That There Was Search In The Premises Of The Assessee. As A Consequence Of Search, Assessment Came To Be Completed U/S.153A Of The Act. In The Assessment U/S.153A Of The Act, The Assessee Had Been Granted The Benefit Of Deduction U/S.80Ib(11A) Of The Act. It Was The Submission That The Said Assessment Order Was The Subject Matter Of Rectification Application On Multiple Occasions & In The Third Round Of Rectification Application The Ao Has Withdrawn The Benefit Of Deduction U/S.80Ib (11A) Of The Act. It Was The Submission That The 2

10. Perusal of the order under section 154 reveals that during the rectificatory proceedings the Ld. AO required the assessee to show cause as to why its income be not recomputed as payments amounting to Rs. 23,72,40,000/- for expenditure made in violation of section 40A(3) of the Act were liable to be disallowed