NISHA DATA COM LIMITED,ROURKELA vs. INCOME TAX OFFICER WARD-3 ROURKELA, ROURKELA

In the result, both the appeals filed for AY 2011-12 and AY 2012-

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

250 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) for AYs 2011-12 and 2012- 13 dated 13.01.2025, which have been passed against the assessment I.T.A. Nos.: 173 & 174/CTK/2025 AYs: 2011-12 & 2012-13 Nisha Data Com Limited. orders u/s 144 and 143(3) of the Act, dated 15.03.2016 and 26.03.2015, respectively. 1.1. Since the issues

NISHA DATA COM LIMITED,ROURKELA vs. INCOME TAX OFFICER WARD-3 ROURKELA, ROURKELA

In the result, both the appeals filed for AY 2011-12 and AY 2012-

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

250 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) for AYs 2011-12 and 2012- 13 dated 13.01.2025, which have been passed against the assessment I.T.A. Nos.: 173 & 174/CTK/2025 AYs: 2011-12 & 2012-13 Nisha Data Com Limited. orders u/s 144 and 143(3) of the Act, dated 15.03.2016 and 26.03.2015, respectively. 1.1. Since the issues

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/-

section 14A would not apply to the facts of the assessee's case. We are also perturbed by the fact that the fact as brought on record by the AO is that the assessee has invested in the shares of the sister concern M/s. Ananta Automobiles Pvt Ltd., The balance sheet as on 31.3.2014 shows an investment in M/s. Ajanta

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

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

disallowed the exemption claim, raising a demand. A rectification application under section 154 was filed, stating the exemption was claimed under the wrong section, but it was rejected. The CIT(A) upheld the AO's order and dismissed the assessee's appeal.", "held": "The Tribunal held that the CIT(A) erred in dismissing the appeal as infructuous and not considering

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.

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 and on facts and legally untenable. 2. The order dated 28.03.2016 passed by the learned Assessing Officer u/s.143(3) r.w sec 147 of the I.T.Act

G R C GARMENTS PARTNERSHIP FIRM ,NANDI SAHI, BUXI BAZAR vs. ITO, WARD 1(1), CUTTACK , AAYAKAR BHAWAN, SHELTER CHHAK

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Rajesh Kumari.T.A. No. 383/Ctk/2025 Assessment Year: 2018-2019 Grc Garments Partnership Firm,….…….,…Appellant Cuttack Sadar, Choudhury Bazar, Cuttack-753001, Odisha [Pan:Aaefg7391N] -Vs.- Income Tax Officer,……………………….…....Respondent Ward-1(1), Cuttack, Tulasipur, Cuttack-753008, Odisha Appearances By: Shri Diganta Das, Advocate, Appeared On Behalf Of The Assessee Shri Vijay Singh, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: September 03, 2025 Date Of Pronouncing The Order: October 31, 2025 O R D E R

disallowance of interest payment on the unsecured loans of Rs.20,86,250/- which have been added under section 68 of the Act, by allowing

BASANTI AUTOMOBILES,JANUGANJ GOLAI vs. ITO WARD-2, BALASORE

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

Bench: Before S/Shri George Mathan, Judicial & And Rajesh Kumarassessment Year : 2014-15 Basanti Basanti Automobiles, Automobiles, 1, 1, Vs. Income Tax Officer, Ward Income Tax Officer, Ward-2, Januganj Januganj Golai, Golai, Po/Ps: Po/Ps: Balasore Januganj, Dist: Balasore Januganj, Dist: Balasore Pan/Gir No. Pan/Gir No.Aaifb 8729 K (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri P.K.Mishra, Ar P.K.Mishra, Ar Revenue By : Shri S.C.Mohanty, Sr Dr S.C.Mohanty, Sr Dr Date Of Hearing : 23/08 8/2023 Date Of Pronouncement : 23/0 /08/2023 O R D E R Per Bench This Is An Appeal Filed By The Assessee Against The Order Of The Ld This Is An Appeal Filed By The Assessee Against The Order Of The Ld This Is An Appeal Filed By The Assessee Against The Order Of The Ld Cit(A), , Nfac, Nfac, Delhi, Delhi, Dated 25.5.2023 25.5.2023 In In Appeal Appeal No.Itba/Nfac/S/250/2023 /Nfac/S/250/2023-24/1053160486(1) For The Assessment Year For The Assessment Year 2014-15. 2. Shri P.K.Mishra, Ld Ar Appeared For The Assessee & Shri Shri P.K.Mishra, Ld Ar Appeared For The Assessee & Shri Shri P.K.Mishra, Ld Ar Appeared For The Assessee & Shri S.C.Mohanty, Ld Sr Dr Appeared For The Revenue. S.C.Mohanty, Ld Sr Dr Appeared For The Revenue.

disallowance by observing that the assessee failed to furnish any written submissions in support of the grounds taken in appeal and the appeal was disposed of exparte without considering the facts on merits. It was the submission that if one more opportunity is granted to the assessee, the assessee will cooperate with the ld CIT(A) by filing the written

DCIT, CORPORATE CIRCLE-1(1), BHUBANESWAR vs. M/S. GRIDCO LIMITED, BHUBANESWAR

In the result, appeal of the revenue stands dismissed

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaassessment Year :2010-2011 2011 Dcit, Corporate Circle Dcit, Corporate Circle-1(1), Vs. Grid Corporation Of Orissa Grid Corporation Of Orissa Bhubaneswar Bhubaneswar Ltd., Ltd., Gridco Gridco House, House, Janapath, Bhubaneswar Janapath, Bhubaneswar. Pan/Gir No. Pan/Gir No.Aabcg 5398 P (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : S/Shri Ved Jain/P.Venugopal Rao /P.Venugopal Rao, Ars Revenue By : Shri M.K.Gautam, M.K.Gautam, Cit Dr Date Of Hearing : 20/0 02/2023 Date Of Pronouncement : 20/0 /02/2023 O R D E R Per Bench This Is An Appeal Filed By The Revenue Against The Order Of The Ld Against The Order Of The Ld Cit(A)-1, Bhubaneswar, 1, Bhubaneswar, Dated 9.5.2016 In Appeal No. In Appeal No.0493/14-15 For The Assessment Year Assessment Year 2010-2011. 2. S/Shri Ved Jain & P.Venugopal Rao, S/Shri Ved Jain & P.Venugopal Rao, Ld Ar Ld Ars Appeared For The Assessee & Shri M.K.Gautam, Ld Cit Dr Appeared For The Revenue. Assessee & Shri M.K.Gautam, Ld Cit Dr Appeared For The Revenue. Assessee & Shri M.K.Gautam, Ld Cit Dr Appeared For The Revenue.

disallowance made by the Assessing Officer on account of non Assessing Officer on account of non-deduction of TDS u/s.194J of the Act deduction of TDS u/s.194J of the Act and consequently section 40(a)(ia) of the Act. It was the submission that and consequently section 40(a)(ia) of the Act. It was the submission that and consequently

ODISHA INDUSTRIAL INFRASTRUCTURE DEVELOPMENT CORPORATION(IDCO),BHUBANESWAR vs. DY COMMISSIONER OF INCOME TAX, CIRCLE-4(1), BHUBANESWAR, BHUBANESWAR

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

Bench: Shri George Mathan & Shri Manish Agarwalआयकर अपील सं/Ita No.365/Ctk/2024 (िनधा"रण वष" / Assessment Year : 2015-2016) M/S Odisha Industrial Infrastructure Vs Dcit, Circle-4(1), Bhubaneswar Development Corporation, Idco Tower, Janpath, Bhubaneswar Pan No. : Aaaat 2619 K (अपीलाथ" /Appellant) .. (""यथ" / Respondent) िनधा"रती क" ओर से /Assessee By : Shri Bibekananda Mohanty, Ca राज"व क" ओर से /Revenue By : Dr. Abani Kanta Nayak, Cit-Dr सुनवाई क" तारीख / Date Of Hearing : 12/11/2024 घोषणा क" तारीख/Date Of Pronouncement : 12/11/2024 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 25.05.2023, Passed In Appeal No.Cit(A), Bhubaneswar-2/10971/2017-18 Vide Din & Order No.Itba/Nfac/S/250/2023-24/1053183739(1) For The Assessment Year 2015-2016. 2. On Perusal Of The Appeal Record, We Found That The Appeal Of The Assessee Has Been Filed Belatedly By 409 Days. In This Regard, The Assessee Has Filed Condonation Application Along With Affidavit Stating Sufficient Reasons For Delay In Filing The Present Appeal. The Contents Of The Affidavit Filed By The Assessee Are As Under :-

250 of the Income Tax Act, 1961 is against law, weight of evidences and probabilities of the case. 2. The appellant being a Public Sector Enterprise spend every year for public purposes as per decision of the Board / State Government for various social development activities. However, IDCO not being a company registered under Companies Act provisions of restrictions on such

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 :-

250 issued by the Ld. CIT (Appeal) is arbitrary, illegal and bad in law. 3 & CO No.04/CTK/2024 JURISDICTIONAL GROUNDS 3. On the facts and circumstance of case and in law, the Ld. CIT(A)/ NFAC has erred in exceeding it's Jurisdiction as provided under section 251(1)(a) of the Income-tax Act, 1961 while enhancing the income

PRAFULLA KUMAR ROUTRAY,BHUBANESWAR vs. ACIT, INTERNATIONAL TAXATION, BHUBANESWAR, BHUBANESWAR

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

250 of the I.T. Act, 1961 by the Commissioner of Income Tax (Appeals) Kolkata-22 hereinafter referred to as the ‘learned CIT(Appeals)’ dismissing the appeal is not just and legal on the facts and in the circumstances of the case. 2. For that the learned CIT(Appeals) without properly appreciating the facts and submissions of the appellant from

WOMEN ORGANISATION FOR SOCIO CULTURAL AWARNESS,KEONJHAR vs. ITO,EXEMPTIONS, CUTTACK

In the result, the appeal of the assessee is allowed for statistical purposes

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

disallowed deduction of the whole of the amount of Rs. 9,58,96,328 applied in various projects and computed the total income of the assessee at Rs. 10,13,15,635 and raised a demand in the total amount of Rs. 6,99,70,607 in the Intimation under section 143(1) of the Act vide DIN: CPC/2223/B7/410451517 dated

LAXMINARAYAN DASH,BHUBANESWAR vs. INCOME TAX OFFICER, WARD-3(3), BHUBANESWAR, BHUBANESWAR

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

Bench: Before Shri George Mathanmember & Manish Agarwal Manish Agarwalita No.521 /Ctk/2024 Assessment Year : 2016-17 Laxminarayan Das Laxminarayan Das Vs. Income Tax Officer, Ward- Income Tax Officer, Ward Plot No.575-C, C, 3(3), Bhubaneswar Hubaneswar Behera Sahi Nayapali Bhubaneswar, 751012 , 751012 Pan/Gir No. No.Accpd 0726 E (Appellant (Appellant) .. ( Respondent Respondent) Assessee By Assessee By : S/Shri P.K.Misahra & B.N.Behera B.N.Behera, Adv Revenue By : Shri S.C.Mohanty, Sr Dr : Shri S.C.Mohanty, Sr Dr Date Of Hearing : 30/12/20 2024 Date Of Pronouncement : 30/12/20 024 O R D E R Per Bench This Is An This Is An Appeal Filed By The Assessee Against The Order Of The Ld Appeal Filed By The Assessee Against The Order Of The Ld Cit(A), Nfac, Delhi Dated Cit(A), Nfac, Delhi Dated 22/03/2024 In Appeal No.Cit(A),Bhuban Cit(A),Bhubaneswar- 2/10236/2018-19 19 For The Assessment Year 2016-17. 2. Shri B.N.Behera B.N.Behera & P.K.Mishra, Ld Ars Appeared For Appeared For The Assessee & Shri S.C.Mohanty S.C.Mohanty, Sr. Dr Appeared For The Revenue.

disallowance of exemption claimed u/s.54F of the Act to the tune of Rs.4,69,23,231.00 and addition of the same to the total income of the Appellant, being illegal and contrary to the statutory provisions of law is not sustainable, hence needs to be deleted in the interest of justice.” 4. The appeal is time barred by 189 days

MANORANJAN DASH,BHUBANESWAR vs. ITO WARD 3(1), BHUBANESWAR

250 of the Income Tax Act,\n1961 (hereinafter “the Act”), passed by the Ld. Commissioner of Income Tax\n(Appeals), National Faceless Appeal Centre (NFAC), Delhi [hereafter “the Ld.\nCIT(A)"] vide order dated 29.10.2024 for AY 2016-17.\n1.1 In this case, the Ld. AO made an addition of Rs. 84,70,055/- as\nundisclosed income

SIDDARTHINI NANDA,NAYASARAK, CUTTACK vs. ASST. CIT( CIRCLE-1), BHUBANESWAR

In the result, appeals of both the assessees are allowed

Bench: Shri George Mathan & Shri Arun Khodpiaआयकर अऩीऱ सं/Ita No.196/Ctk/2022 (ननधाारण वषा / Assessment Year :2012-2013) Indu Devi Tibarewal, Vs Acit, Central Circle-1, At/Po: Nayasarak, Bhubaneswar Cuttack-753002 Pan No. :Acxpt 4424 E (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. & आयकर अऩीऱ सं/Ita Nos.197/Ctk/2022 (ननधाारण वषा / Assessment Year :2012-2013) Siddarthini Nanda, Vs Acit, Central Circle-1, Nayasarak, Bhubaneswar Cuttack-753002 Pan No. :Abapn 0104 F (अऩीऱाथी /Appellant) .. (प्रत्यथी / Respondent)

disallowed agricultural income and had treated the same as income from other sources. In the assessment order the AO has initiated penalty particulars. It was submitted that in the show cause notice issued u/s.271/274 of the Act, the AO has not struck off inappropriate portion of furnishing of inaccurate particulars or concealment of income. It was also submitted that

INDU DEVI TIBAREWAL,CUTTACK vs. ASST.CIT, CENTRAL CIRCLE-1, BHUBANESWAR

In the result, appeals of both the assessees are allowed

Bench: Shri George Mathan & Shri Arun Khodpiaआयकर अऩीऱ सं/Ita No.196/Ctk/2022 (ननधाारण वषा / Assessment Year :2012-2013) Indu Devi Tibarewal, Vs Acit, Central Circle-1, At/Po: Nayasarak, Bhubaneswar Cuttack-753002 Pan No. :Acxpt 4424 E (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. & आयकर अऩीऱ सं/Ita Nos.197/Ctk/2022 (ननधाारण वषा / Assessment Year :2012-2013) Siddarthini Nanda, Vs Acit, Central Circle-1, Nayasarak, Bhubaneswar Cuttack-753002 Pan No. :Abapn 0104 F (अऩीऱाथी /Appellant) .. (प्रत्यथी / Respondent)

disallowed agricultural income and had treated the same as income from other sources. In the assessment order the AO has initiated penalty particulars. It was submitted that in the show cause notice issued u/s.271/274 of the Act, the AO has not struck off inappropriate portion of furnishing of inaccurate particulars or concealment of income. It was also submitted that

SARASWATI SISHU MANDIR,DHENKANAL vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENTDEPARTMENT, BHUBANESWAR

In the result, the appeal of the assessee is allowed for statistical purposes

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

250 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) for AY 2020-21 dated 04.11.2024, I.T.A. No.: 17/CTK/2025 Assessment Year: 2020-21 Saraswati Sishu Mandir. which has been passed against the assessment order u/s 144 of the Act, dated 09.09.2022. 2. The assessee is in appeal before the Tribunal raising the following grounds of appeal

JEEVAN KALYANA SADHANA KENDRA,KOLKATA vs. INCOME TAX OFFICER, EXEMPTION, SAMBALPUR

In the result, the appeal of the assessee is allowed for statistical purposes

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

250 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) for AY 2023-24 dated 30.01.2025, which has been passed against the intimation order u/s 143(1) of the Act, dated 13.12.2024. I.T.A. No.: 195/CTK/2025 Assessment Year: 2023-24 Jeevan Kalyana Sadhana Kendra. 2. The assessee is in appeal before the Tribunal raising the following grounds