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/-

26,544/-, Rs.12,82,15,401/- were diverted towards interest free loans and advances to the related parties, therefore, he invoked the provisions of Section 36(1)(iii) of the Act and disallowed

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 :-

26,01,192/- was disallowed for the reason that assessee has failed to submit reasonable explanation for the same. Ld. AR further submitted that during the course of appellate proceedings the assessee has submitted the nature of expenses incurred. Though the ld. CIT(A) had not doubted the genuineness of the expenses incurred, however, by invoking the provisions of Explanation

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 can be made under section 40(a)(ia). 26. In the present case the deductee is OPTCL. It has filed

M/S. GRID CORPORATION OF ORISSA LIMITED,BHUBANESWAR vs. ACIT-(TDS), BHUBANESWAR

In the result, appeal of the assessee stands allowed

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaassessment Year : 2009-2010 2010 Grid Corporation Of Orissa Grid Corporation Of Orissa Vs. Acit (Tds), Acit (Tds), Ltd., Ltd., Gridco Gridco House, House, Bhubaneswar. Bhubaneswar. 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 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)-1, Bhubaneswar, 1, Bhubaneswar, Dated 12.7.2019 In Appeal No. In Appeal No.0035/17-18 For The Assessment Year The Assessment Year 2009-2010. 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.

section 154 of the Act. It is clear that the statutory provision having come into force with effect from 1-4-1984, the same could have been applied for the assessment year 1984-85 and thereafter. However, while applying the said provision for the assessment year 1984-85, claim or carry forward or set off, had to be considered

SANJAY KUMAR AGRAWAL,CUTTACK vs. BBN-C-(4)(8), INCOME TAX OFFICE, CUTTACK

In the result, appeal of the assessee is allowed

26(ii) has stated that the GST is not passed through profit and loss account and, therefore, provisions of Section 145A of the Act are applicable in the present case and, thus, the disallowance

KALPANA MISHRA,BHUBANESWAR vs. ITO, WARD 5(4), BHUBANESWAR, BHUBANESWAR

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

Bench: Shri George Mathan & Shri Manish Agarwalआयकर अपील संसंसंसं/Ita No.491/Ctk/2024 (िनधा"रण िनधा"रण िनधा"रण वष" िनधा"रण वष" वष" / Assessment Year : 2016-2017) वष" Kalpana Mishra, Vs Ito Ward-5(4), Bhubaneswar Plot No.B-87/A, Chandaka Industrial Estate, Patia, Bhubaneswar-751024 Pan No. :Alfpm 2864 E (अपीलाथ" अपीलाथ" अपीलाथ" /Appellant) अपीलाथ" (""यथ" ""यथ" ""यथ" / Respondent) ""यथ" .. िनधा"रती िनधा"रती क" िनधा"रती िनधा"रती क" क" ओर क" ओर ओर सेसेसेसे /Assessee By ओर : Shri B.R.Pattnaik, Ca राज"व राज"व क" राज"व राज"व क" क" ओर क" ओर ओर सेसेसेसे /Revenue By ओर : Shri S.C.Mohanty, Sr. Dr सुनवाई क" तारीख / Date Of Hearing : 28/01/2025 घोषणा क" तारीख/Date Of Pronouncement : 28/01/2025 आदेश आदेश / O R D E R आदेश आदेश Per Bench : This Is An Appeal Filed By The Assessee Against The Order Dated 07.03.2024, Passed By The Cit(A), National Faceless Appeal Centre (Nfac), Delhi In Din & Order No.Itba/Nfac/S/250/2023- 24/1062168195(1) For The Assessment Year 2016-2017, On The Following Grounds :- 1. Hon'Ble Cit(Appeals), Nfac Has Erred In Law & On Facts In Confirming The Action Of The Learned Ao Even Though The Learned Ao Has Exceeded His Jurisdiction In A Limited Scrutiny Case Selected Under Cass Only To Examine Whether The Investment & Income Relating To Securities Transactions Are Duly Disclosed Or Not & Added A Sum Of Rs.44,00,000.00 U/S 68 Of The Income Tax Act, 1961, Without Obtaining Prior Administrative Approval Of The Concerned Pr. Cit/Cit As Prescribed In Circular F. No. 225/402/2018/Ita.Ii, Dated 28- 11-2018 & Instruction No.5/2016 [F.No.225/269/2015-

26-9-2014, 29-12-2015, and 14-7-2016. These instances have been viewed very seriously by the CBDT and in one case the Central Inspection Team of the CBDT was tasked with examination of assessment records on receipt of allegations of several irregularities. Amongst other irregularities, it was found that no reasons had been recorded for expanding

ABHIMANYU SAHU,BUXIPALLI vs. PCIT-1,, BHUBANESWAR

In the result, appeal filed by the assessee is allowed

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaassessment Year : 2016-17 Abhimanyu Sahu, Buxipalli, Abhimanyu Sahu, Buxipalli, Vs. Pr. Cit-1, Gopalpur On Sea. Gopalpur On Sea. Bhubaneswar Bhubaneswar Pan/Gir No. Pan/Gir No.Aokps 4011 H (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri P.N.Dave, Ca P.N.Dave, Ca Revenue By : Shri M.K.Gautam, Pr. Cit (Osd) Pr. Cit (Osd) Date Of Hearing : 24 /0 03/2023 Date Of Pronouncement : 24 /0 /03/2023 O R D E R Per Bench This Is An Appeal Filed By The Assessee This Is An Appeal Filed By The Assessee Against The Order Against The Order Passed U/S 263 Of The Act 263 Of The Act Of The Ld Pr. Cit, Bhubaneswar-1 Dated Dated 10.3.2021 In Appeal No. Itba/Rev/ V/F/Rev5/2020-21/1031385941(1) For The Assessment Year For The Assessment Year 2016-17. 2. Shri P.N.Dave, Ld Ar Appeared For The Assessee & Shri Shri P.N.Dave, Ld Ar Appeared For The Assessee & Shri Shri P.N.Dave, Ld Ar Appeared For The Assessee & Shri M.K.Gautam, Ld Pr. Cit(Osd) Appeared For The Revenue. M.K.Gautam, Ld Pr. Cit(Osd) Appeared For The Revenue. M.K.Gautam, Ld Pr. Cit(Osd) Appeared For The Revenue.

26,h September, 2014 and Instruction No.20/15 dated 19th December, 2015. Consequently, it was not open to the Pr. CIT while exercising suo motu revisional power under Section 263 of the Act to find fault with the assessment order of the AO on the ground of its being erroneous on an issue not covered by the 'limited scrutiny' when

THE KORAPUT CENTRAL COOPERATIVE BANK LTD,JEYPORE, KORAPUT vs. ACIT,CIRCLE-1(1), SAMBALPUR

In the result, appeal of the assessee is allowed

26,401/- by disallowing the amounts of provisions for imbalance and provisions for infrastructure development of branch. On such disallowance, penalty proceedings u/s.271(1)(c) of the Act are initiated and the relevant satisfaction recorded by the AO is as under :- “Penalty proceedings u/s.271(1)(c) is initiated on this account for furnishing inaccurate particulars of income.” 7. The notice

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 | 16 ITA Nos.324 to 328/CTK/2023 Assessment Years : 202003-04 to 2007-08 7. In the case of DCIT v. Vinod Arora 137 taxmann.com 450 (Amritsar - Trib.), the Hon'ble Bench, applying the tests as propounded in the case

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 | 16 ITA Nos.324 to 328/CTK/2023 Assessment Years : 202003-04 to 2007-08 7. In the case of DCIT v. Vinod Arora 137 taxmann.com 450 (Amritsar - Trib.), the Hon'ble Bench, applying the tests as propounded in the case

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 | 16 ITA Nos.324 to 328/CTK/2023 Assessment Years : 202003-04 to 2007-08 7. In the case of DCIT v. Vinod Arora 137 taxmann.com 450 (Amritsar - Trib.), the Hon'ble Bench, applying the tests as propounded in the case

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 | 16 ITA Nos.324 to 328/CTK/2023 Assessment Years : 202003-04 to 2007-08 7. In the case of DCIT v. Vinod Arora 137 taxmann.com 450 (Amritsar - Trib.), the Hon'ble Bench, applying the tests as propounded in the case

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 | 16 ITA Nos.324 to 328/CTK/2023 Assessment Years : 202003-04 to 2007-08 7. In the case of DCIT v. Vinod Arora 137 taxmann.com 450 (Amritsar - Trib.), the Hon'ble Bench, applying the tests as propounded in the case

MAHANADI COALFIELDS LTD.,BURLA, SAMBALPUR. vs. DCIT CIRCLE2(1), SAMBALPUR

In the result, appeal filed by the revenue being ITA No

Bench: Shri George Mathan & Shri Girish Agrawalआयकर अऩीऱ सं/Ita Nos.14 To 17/Ctk/2023 & आयकर अऩीऱ सं/Ita No.41/Ctk/2023 (ननधाारण वषा / Assessment Years : 2016-2017 To 2020-2021) Mahanadi Coalfields Limited, Vs Acit/Dcit, Circle-2(1), Sambalpur Jagriti Vihar, Burla, Sambalpur-768020 Pan No. :Aabcm 5188 P & आयकर अऩीऱ सं/Ita Nos.70 To 73/Ctk/2023 & आयकर अऩीऱ सं/Ita No.147/Ctk/2023 (ननधाारण वषा / Assessment Years : 2016-2017 To 2020-2021) Acit/Dcit, Circle-2(1), Sambalpur Vs Mahanadi Coalfields Limited, Jagriti Vihar, Burla, Sambalpur-768020 Pan No. :Aabcm 5188 P & आयकर अऩीऱ सं/Ita No.69/Ctk/2023 (ननधाारण वषा / Assessment Year : 2015-2016) Acit/Dcit, Circle-2(1), Sambalpur Vs Mahanadi Coalfields Limited, Jagriti Vihar, Burla, Sambalpur-768020 Pan No. :Aabcm 5188 P (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. ननधााररती की ओर से /Assessee By : Shri S.S.Poddar, Ca राजस्व की ओर से /Revenue By : Dr. Abani Kanta Nayak, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 17/10/2023 घोषणा की तारीख/Date Of Pronouncement : 17/10/2023 आदेश / O R D E R Per Bench :

26. The next issue raised in ground No.3.3, 3.4 & 3.5 in appeal of the assessee for A.Y.2020-2021, are in regard to credit towards public distribution tax, disallowance u/s.36(1)(va) of the Act and reduction in refund. 27. It was submitted by the ld. AR that the ld. CIT(A) has decided the issue in favour of the assessee. However

MAHANADI COALFIELDS LTD.,BURLA, SAMBALPUR. vs. DCIT CIRCLE2(1), SAMBALPUR

In the result, appeal filed by the revenue being ITA No

Bench: Shri George Mathan & Shri Girish Agrawalआयकर अऩीऱ सं/Ita Nos.14 To 17/Ctk/2023 & आयकर अऩीऱ सं/Ita No.41/Ctk/2023 (ननधाारण वषा / Assessment Years : 2016-2017 To 2020-2021) Mahanadi Coalfields Limited, Vs Acit/Dcit, Circle-2(1), Sambalpur Jagriti Vihar, Burla, Sambalpur-768020 Pan No. :Aabcm 5188 P & आयकर अऩीऱ सं/Ita Nos.70 To 73/Ctk/2023 & आयकर अऩीऱ सं/Ita No.147/Ctk/2023 (ननधाारण वषा / Assessment Years : 2016-2017 To 2020-2021) Acit/Dcit, Circle-2(1), Sambalpur Vs Mahanadi Coalfields Limited, Jagriti Vihar, Burla, Sambalpur-768020 Pan No. :Aabcm 5188 P & आयकर अऩीऱ सं/Ita No.69/Ctk/2023 (ननधाारण वषा / Assessment Year : 2015-2016) Acit/Dcit, Circle-2(1), Sambalpur Vs Mahanadi Coalfields Limited, Jagriti Vihar, Burla, Sambalpur-768020 Pan No. :Aabcm 5188 P (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. ननधााररती की ओर से /Assessee By : Shri S.S.Poddar, Ca राजस्व की ओर से /Revenue By : Dr. Abani Kanta Nayak, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 17/10/2023 घोषणा की तारीख/Date Of Pronouncement : 17/10/2023 आदेश / O R D E R Per Bench :

26. The next issue raised in ground No.3.3, 3.4 & 3.5 in appeal of the assessee for A.Y.2020-2021, are in regard to credit towards public distribution tax, disallowance u/s.36(1)(va) of the Act and reduction in refund. 27. It was submitted by the ld. AR that the ld. CIT(A) has decided the issue in favour of the assessee. However

INCOME TAX OFFICER WARD-1 BARIPADA, BARIPADA vs. MAYURBHANJ CENTRAL COOPERATIVE BANK LIMITED, BARIPADA

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

Bench: Before Shri George Mathan, Judicial & Manish Agarwal Manish Agarwal

section 40A(7) of the Act. He further placed reliance on the judgment of Hon’ble Madras High Court in the case of CIT vs. Loyal Textiles Ltd., 231 ITR573 (Mad). 24. Per contra, ld AR supported the order of the ld CIT(A) and submitted that the assessee has agreement with LIC of India for gratuity fund

INCOME TAX OFFICER WARD-1, BARIPADA, BARIPADA vs. MAYURBHANJ CENTRAL COOPERATIVE BANK LIMITED, BARIPADA

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

Bench: Before Shri George Mathan, Judicial & Manish Agarwal Manish Agarwal

section 40A(7) of the Act. He further placed reliance on the judgment of Hon’ble Madras High Court in the case of CIT vs. Loyal Textiles Ltd., 231 ITR573 (Mad). 24. Per contra, ld AR supported the order of the ld CIT(A) and submitted that the assessee has agreement with LIC of India for gratuity fund

INCOME TAX OFFICER, WARD-1, BARIPADA, BARIPADA vs. MAYURBHANJ CENTRAL CO-OPERATIVE BANK LIMITED, BARIPADA

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

Bench: Before Shri George Mathan, Judicial & Manish Agarwal Manish Agarwal

section 40A(7) of the Act. He further placed reliance on the judgment of Hon’ble Madras High Court in the case of CIT vs. Loyal Textiles Ltd., 231 ITR573 (Mad). 24. Per contra, ld AR supported the order of the ld CIT(A) and submitted that the assessee has agreement with LIC of India for gratuity fund

INCOME TAX OFFICER, WARD-1, BARIPADA, BARIPADA vs. MAYURBHANJ CENTRAL CO-OPERATIVE BANK LIMITED, BARIPADA

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

Bench: Before Shri George Mathan, Judicial & Manish Agarwal Manish Agarwal

section 40A(7) of the Act. He further placed reliance on the judgment of Hon’ble Madras High Court in the case of CIT vs. Loyal Textiles Ltd., 231 ITR573 (Mad). 24. Per contra, ld AR supported the order of the ld CIT(A) and submitted that the assessee has agreement with LIC of India for gratuity fund