DCIT CENTRAL CIRCLE-2, BHUBANESWAR vs. M/S. HOTEL SUKHAMAYA PVT. LTD, BHUBANESWAR

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

3 December, 2014. (Ref. page no. 95 to 95 of Paper Book) In this context, it has been considered by the CIT (A) in CIT vs. Rugmini Ram Ragav Spinners (P) Limited., 304 ITR 0417. The Hon'ble jurisdictional Madras High Court held in this case (304 ITR 0417) that share application money is neither deposit nor loan and section

DCIT CENTRAL CIRCLE-2, BHUBANESWAR vs. M/S. HOTEL SUKHAMAYA PVT. LTD, BHUBANESWAR

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

3 December, 2014. (Ref. page no. 95 to 95 of Paper Book) In this context, it has been considered by the CIT (A) in CIT vs. Rugmini Ram Ragav Spinners (P) Limited., 304 ITR 0417. The Hon'ble jurisdictional Madras High Court held in this case (304 ITR 0417) that share application money is neither deposit nor loan and section

SHRI MAHESH KUMAR AGARWAL,SUNDARGARH vs. DCIT, CENTRAL CIRCLE-2, BHUBANESWAR

In the result, assessee’s appeal in the case of Mahesh

Bench: Shri C.M. Garg, Jm & Shri Manish Borad, Am It(Ss)A No.117-119/Ctk/2018 ( Assessment Years :2011-2012 To 2013-2014) Mahesh Kumar Agarwal, Vs Dcit, Central Circle-2, Plot No.O-10, Civil Township, Bhubaneswar Rourkela, Sundargarh-769004 Pan No. : Abdpa 8307 Q & It(Ss)A No.146&147/Ctk/2018 (Assessment Years :2011-2012 & 2012-2013) Dcit, Central Circle-2, Vs Mahesh Kumar Agarwal, Bhubaneswar Plot No.O-10, Civil Township, Rourkela, Sundargarh-769004 Pan No. : Abdpa 8307 Q & It(Ss)A No.44/Ctk/2018 (नििाारण वषा / Assessment Year :2011-2012) Smt. Sanju Agarwal, Vs Dcit, Central Circle-2, Plot No.O-10, Civil Township, Bhubaneswar Rourkela, Sundargarh-769004 Pan No. : Aavpa 4328 C (अऩीलाथी /Appellant) (प्रत्यथी / Respondent) .. ननधाारिती की ओर से /Assessee By : Shri S.M.Surana, Ar िाजस्व की ओर से /Revenue By : Shri M.K.Gautam, Citdr सुनवाई की तािीख / Date Of Hearing : 22/10/2021 घोषणा की तािीख/Date Of Pronouncement : 10/01/2022 आदेश / O R D E R Per Bench: In The Above Captioned Seven Appeals, Five Appeals Have Been Filed By Two Different Assessees & Two Appeals Have 2 It(Ss)A Nos.44/Ctk/2018 It(Ss)A Nos.117-119/Ctk/2018 It(Ss)A Nos.146&147/Ctk/2018 & Ita No.382/Ctk/2018 Been Filed By The Department Which Are Directed Against The Separate Orders Of Cit(A)-2, Bhubaneswar, All Dated 31.01.2018 For The Assessment Years 2011-2012, 2012-2013, 2013-2014 & 2014-2015, Respectively.

ii) to section 153B. Hence the judgements rendered in context of section 142(2A). shall not be applicable to the section 142A of the Act. Without prejudice to the above, even otherwise, the Hon'ble Delhi High Court in the case of CIT vs. Ulike Promoters (P.) Ltd. (19 taxmann.com 8) held that benefit of period of 60 days

RAJ KISHORE PRUSTY,KENDRAPARA vs. PR. CIT-1, BHUBANESWAR

In the result, appeal of the assessee is allowed

Bench: S/ S/Shri Chandra Mohan Garg, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaassessment Year : 2016-17 Raj Kishore Prusty,At: Nuapatna, Raj Kishore Prusty,At: Nuapatna, Vs. Pr. Cit, Bhubaneswar Pr. Cit, Bhubaneswar-1 Po: Chandol, Dist: Kendrapara Po: Chandol, Dist: Kendrapara Pan/Gir No. No.Atdpp 8328 E (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri D.Parida, Ca D.Parida, Ca Revenue By : Shri Manoj Kumar Goutam, Manoj Kumar Goutam, Cit (Dr) Date Of Hearing : 8 /3/ 20 / 2022 Date Of Pronouncement : 05/ /4/2022 O R D E R Per C.M.Garg G, Jm This Is An Appeal Filed By The Assessee Against The Order Of The This Is An Appeal Filed By The Assessee Against The Order Of The This Is An Appeal Filed By The Assessee Against The Order Of The Pr. Cit-1, Bhubaneswar 1, Bhubaneswar U/S.263 Of The Act Dated 26.3.2021 U/S.263 Of The Act Dated 26.3.2021 For The Assessment Year .2016-17. 17. 2. The Assessee Has Raised The Following Grounds: The Assessee Has Raised The Following Grounds:

143(3) of the Act. It is well settled that revision cannot be undertaken for re-examining and directing fresh inquiry due to change of opinion.” 2. Facts of the case are that the assessee was engaged in trading in commodities like Aluminium, Soyabean and Copper through Karvy Comtrade Ltd. The assessee filed the return of income declaring total income

JAY KISHORE CHOUBEY,RAIRANGPUR vs. ACIT, CIRCLE-1, ASANSOL

In the result, appeal of the assessee stands allowed

Bench: Before S/Shri George Mathan, Judicial & Girish Agrawalassessment Year : 2010-2011 2011 Jay Jay Kishore Kishore Choubey, Choubey, Vs. Acit, Circle Acit, Circle-1, Asansol. Rairangpur Bazar, Rairangpur, Rairangpur Bazar, Rairangpur, Mayurbhanj. Pan/Gir No. Pan/Gir No.Acmpc 1759 N (Appellant) .. ( Respondent Respondent) Assessee By : Shri P.R.Mohanty P.R.Mohanty, Adv Revenue By : Shri Charan Das, Sr. Das, Sr. Dr Date Of Hearing : 29/11 11/2023 Date Of Pronouncement : 29/11 /11/2023 O R D E R Per Bench

House Property under section 24(a) Rs. 1,48,031 3. Depreciation under section 32 Rs.1,89,824 The condition precedent to the exercise of the jurisdiction under section 147 is the formation of a reason to believe by the Assessing P a g e 3 | 15 Assessment Year : 2010-2011 Officer. Upon the formation of the reason to believe

ROLAND EDUCATIONAL & CHARITABLE TRUST,BERHAMPUR vs. DCIT, BERHAMPUR CIRCLE, BERHAMPUR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

143(3)/147 dated 23/10/2019, IT Appeal No. 0424/13-14. 16 470/CTK/2019 2006-07 CIT(A) – 1, -do- Bhubaneswar, dated 18/10/2019, IT Appeal No. 0425/13-14. 17 471/CTK/2019 2007-08 CIT(A) – 1, -do- Bhubaneswar, dated 26/11/2019, IT Appeal No. 0426/13-14. 2. On perusal of case(s) record(s), we find that there is delay in filing of the following appeals

ROLAND EDUCATIONAL & CHARITABLE TRUST,GANJAM vs. CHEIF CIT, BHUBANESWAR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

143(3)/147 dated 23/10/2019, IT Appeal No. 0424/13-14. 16 470/CTK/2019 2006-07 CIT(A) – 1, -do- Bhubaneswar, dated 18/10/2019, IT Appeal No. 0425/13-14. 17 471/CTK/2019 2007-08 CIT(A) – 1, -do- Bhubaneswar, dated 26/11/2019, IT Appeal No. 0426/13-14. 2. On perusal of case(s) record(s), we find that there is delay in filing of the following appeals

ROLAND EDUCATIONAL & CHARITABLE TRUST,GANJAM vs. CHEIF CIT, BHUBANESWAR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

143(3)/147 dated 23/10/2019, IT Appeal No. 0424/13-14. 16 470/CTK/2019 2006-07 CIT(A) – 1, -do- Bhubaneswar, dated 18/10/2019, IT Appeal No. 0425/13-14. 17 471/CTK/2019 2007-08 CIT(A) – 1, -do- Bhubaneswar, dated 26/11/2019, IT Appeal No. 0426/13-14. 2. On perusal of case(s) record(s), we find that there is delay in filing of the following appeals

ROLAND EDUCATIONAL & CHARITABLE TRUST,GANJAM vs. CHEIF CIT, BHUBANESWAR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

143(3)/147 dated 23/10/2019, IT Appeal No. 0424/13-14. 16 470/CTK/2019 2006-07 CIT(A) – 1, -do- Bhubaneswar, dated 18/10/2019, IT Appeal No. 0425/13-14. 17 471/CTK/2019 2007-08 CIT(A) – 1, -do- Bhubaneswar, dated 26/11/2019, IT Appeal No. 0426/13-14. 2. On perusal of case(s) record(s), we find that there is delay in filing of the following appeals

ROLAND EDUCATIONAL & CHARITABLE TRUST,GANJAM vs. CHEIF CIT, BHUBANESWAR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

143(3)/147 dated 23/10/2019, IT Appeal No. 0424/13-14. 16 470/CTK/2019 2006-07 CIT(A) – 1, -do- Bhubaneswar, dated 18/10/2019, IT Appeal No. 0425/13-14. 17 471/CTK/2019 2007-08 CIT(A) – 1, -do- Bhubaneswar, dated 26/11/2019, IT Appeal No. 0426/13-14. 2. On perusal of case(s) record(s), we find that there is delay in filing of the following appeals

ROLAND INSTITUTE OF PHARMACEUTICAL SCIENCES,GANJAM vs. CHEIF CIT, BHUBANESWAR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

143(3)/147 dated 23/10/2019, IT Appeal No. 0424/13-14. 16 470/CTK/2019 2006-07 CIT(A) – 1, -do- Bhubaneswar, dated 18/10/2019, IT Appeal No. 0425/13-14. 17 471/CTK/2019 2007-08 CIT(A) – 1, -do- Bhubaneswar, dated 26/11/2019, IT Appeal No. 0426/13-14. 2. On perusal of case(s) record(s), we find that there is delay in filing of the following appeals

ROLAND INSTITUTE OF PHARMACEUTICAL SCIENCES,GANJAM vs. CHEIF CIT, BHUBANESWAR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

143(3)/147 dated 23/10/2019, IT Appeal No. 0424/13-14. 16 470/CTK/2019 2006-07 CIT(A) – 1, -do- Bhubaneswar, dated 18/10/2019, IT Appeal No. 0425/13-14. 17 471/CTK/2019 2007-08 CIT(A) – 1, -do- Bhubaneswar, dated 26/11/2019, IT Appeal No. 0426/13-14. 2. On perusal of case(s) record(s), we find that there is delay in filing of the following appeals

ROLAND INSTITUTE OF PHARMACEUTICAL SCIENCES,GANJAM vs. CHEIF CIT, BHUBANESWAR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

143(3)/147 dated 23/10/2019, IT Appeal No. 0424/13-14. 16 470/CTK/2019 2006-07 CIT(A) – 1, -do- Bhubaneswar, dated 18/10/2019, IT Appeal No. 0425/13-14. 17 471/CTK/2019 2007-08 CIT(A) – 1, -do- Bhubaneswar, dated 26/11/2019, IT Appeal No. 0426/13-14. 2. On perusal of case(s) record(s), we find that there is delay in filing of the following appeals

ROLAND INSTITUTE OF PHARMACEUTICAL SCIENCES,GANJAM vs. CHEIF CIT, BHUBANESWAR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

143(3)/147 dated 23/10/2019, IT Appeal No. 0424/13-14. 16 470/CTK/2019 2006-07 CIT(A) – 1, -do- Bhubaneswar, dated 18/10/2019, IT Appeal No. 0425/13-14. 17 471/CTK/2019 2007-08 CIT(A) – 1, -do- Bhubaneswar, dated 26/11/2019, IT Appeal No. 0426/13-14. 2. On perusal of case(s) record(s), we find that there is delay in filing of the following appeals

ROLAND INSTITUTE OF PHARMACEUTICAL SCIENCES,GANJAM vs. CHEIF CIT, BHUBANESWAR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

143(3)/147 dated 23/10/2019, IT Appeal No. 0424/13-14. 16 470/CTK/2019 2006-07 CIT(A) – 1, -do- Bhubaneswar, dated 18/10/2019, IT Appeal No. 0425/13-14. 17 471/CTK/2019 2007-08 CIT(A) – 1, -do- Bhubaneswar, dated 26/11/2019, IT Appeal No. 0426/13-14. 2. On perusal of case(s) record(s), we find that there is delay in filing of the following appeals

RONALD EDUCATIONAL & CHARITABLE TRUST,GANJAM vs. CHEIF CIT, BHUBANESWAR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

143(3)/147 dated 23/10/2019, IT Appeal No. 0424/13-14. 16 470/CTK/2019 2006-07 CIT(A) – 1, -do- Bhubaneswar, dated 18/10/2019, IT Appeal No. 0425/13-14. 17 471/CTK/2019 2007-08 CIT(A) – 1, -do- Bhubaneswar, dated 26/11/2019, IT Appeal No. 0426/13-14. 2. On perusal of case(s) record(s), we find that there is delay in filing of the following appeals

ROLAND EDUCATIONAL & CHARITABLE TRUST,BERHAMPUR vs. DCIT, BERHAMPUR CIRCLE, BERHAMPUR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

143(3)/147 dated 23/10/2019, IT Appeal No. 0424/13-14. 16 470/CTK/2019 2006-07 CIT(A) – 1, -do- Bhubaneswar, dated 18/10/2019, IT Appeal No. 0425/13-14. 17 471/CTK/2019 2007-08 CIT(A) – 1, -do- Bhubaneswar, dated 26/11/2019, IT Appeal No. 0426/13-14. 2. On perusal of case(s) record(s), we find that there is delay in filing of the following appeals

ROLAND EDUCATIONAL & CHARITABLE TRUST,GANJAM vs. CHEIF CIT, BHUBANESWAR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

143(3)/147 dated 23/10/2019, IT Appeal No. 0424/13-14. 16 470/CTK/2019 2006-07 CIT(A) – 1, -do- Bhubaneswar, dated 18/10/2019, IT Appeal No. 0425/13-14. 17 471/CTK/2019 2007-08 CIT(A) – 1, -do- Bhubaneswar, dated 26/11/2019, IT Appeal No. 0426/13-14. 2. On perusal of case(s) record(s), we find that there is delay in filing of the following appeals

ROLAND EDUCATIONAL & CHARITABLE TRUST,BERHAMPUR vs. DCIT, BERHAMPUR CIRCLE, BERHAMPUR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

143(3)/147 dated 23/10/2019, IT Appeal No. 0424/13-14. 16 470/CTK/2019 2006-07 CIT(A) – 1, -do- Bhubaneswar, dated 18/10/2019, IT Appeal No. 0425/13-14. 17 471/CTK/2019 2007-08 CIT(A) – 1, -do- Bhubaneswar, dated 26/11/2019, IT Appeal No. 0426/13-14. 2. On perusal of case(s) record(s), we find that there is delay in filing of the following appeals