ACIT, RORUKELA CIRCLE, ROURKELA vs. INDRANI PATNAIK, ROURKELA

In the result, appeals of the revenue for assessment years 2012-13 &

Bench: Shri Chandra Mohan Garg & Laxmi Prasad Sahu

35,61,976/- made in the preceding year . The Assessing Officer required the assessee to furnish details of expenses. In reply, assessee furnished the copy of bills raised by the commission agents. The Assessing Officer made correspondence with the commission agents and required them to furnish name and address of buyers for whom they have executed commissioning work alongwith nature

INDRANI PATNAIK,ROURKELA vs. DCIT, RORUKELA CIRCLE, ROURKELA

In the result, appeals of the revenue for assessment years 2012-13 &

Bench: Shri Chandra Mohan Garg & Laxmi Prasad Sahu

35,61,976/- made in the preceding year . The Assessing Officer required the assessee to furnish details of expenses. In reply, assessee furnished the copy of bills raised by the commission agents. The Assessing Officer made correspondence with the commission agents and required them to furnish name and address of buyers for whom they have executed commissioning work alongwith nature

ITO, BHUBANESWAR vs. ORISSA COMPUTER APPLICATION CENTRE, BHUBANESWAR

Bench: S/Shri N.S Saini & Pavan Kumar Gadale

House rent Recovered 25,582=00 vii Interest on Fixed Deposit 44,68,814=00 viii Miscellaneous Income 2,08,910=00 Total 1,82,20,688=00 SI No Particulars of Expenditure Amount (in Rs) i Staff payments 59,38,907=80 ii Admn. & General Expenses 35,38,150=82 iii Repair & Maintenance 2,58,281=98 iv Depreciation

SMT. PURNIMA DAS,BHUBANESWAR vs. PR. CIT-1,, BHUBANESWAR

Bench: S/Shri George Mathan & Arun Khodpiaassessment Year : 2017-18 Smt. Purnima Das, C/O. Vs. Pr. Cit, Bhubaneswar-1. Biswajit Das, At-9, Budha Nagar, Budheswari, Bhubaneswar. Pan/Gir No.Aazpd0112 B (Appellant) .. ( Respondent) Assessee By : Shri P.K.Mishra, Ar Revenue By : Shri M.K.Gautam, Cit Dr Date Of Hearing : 16/02/2023 Date Of Pronouncement : 16/02/2023 O R D E R Per Bench This Is An Appeal Filed By The Assessee Against The Order Of The Ld Pr.Cit Passed U./S.263 Of The Act, Dated 12.3.2022 In Appeal No. Itba/Rev/F/Reev5/2021-22/10540634159(1) For The Assessment Year 2017-18. 2. Shri P.K.Mishra, Ld Ar Appeared For The Assessee Assisted By Ms.Sugyanee Kuanr & Ms. Simran Samal, Intern From Birla School Of Law (Bgu), Bhubaneswar & Shri M.K.Gautam, Ld Cit Dr Appeared For The Revenue Assisted By Shri Dharmashoka Panda, Intern From Birla School Of Law (Bgu), Bhubaneswar. 3. It Was Submitted By Ld Ar That The Assessee Is An Individual, Who Is A Professor Of Mathematics At P.N.College, Khurda. The Assessee Had Filed Her Return Of Income For The Relevant Assessment Year On 5.8.2017

section 2(OLR) Act. The reply of the Tahasildar reads as follows: P a g e 9 | 47 Assessment Year : 2017-18 P a g e 10 | 47 Assessment Year : 2017-18 7. It was the submission that after doing necessary enquiry with the Tahasildar and after being satisfied, the Assessing Officer had accepted the claim of the assessee that

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

house and a residential institution for the students and those connected with the institution. 5. To invest, dispose of, transfer and otherwise deal with the subject-matter of the Trust in such manner as the Trustees should deem fit so as to enable the institution to carry on the objects of the Trust efficiently. 6. To accept donations, grants, presentations

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

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

house and a residential institution for the students and those connected with the institution. 5. To invest, dispose of, transfer and otherwise deal with the subject-matter of the Trust in such manner as the Trustees should deem fit so as to enable the institution to carry on the objects of the Trust efficiently. 6. To accept donations, grants, presentations

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

house and a residential institution for the students and those connected with the institution. 5. To invest, dispose of, transfer and otherwise deal with the subject-matter of the Trust in such manner as the Trustees should deem fit so as to enable the institution to carry on the objects of the Trust efficiently. 6. To accept donations, grants, presentations

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

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

house and a residential institution for the students and those connected with the institution. 5. To invest, dispose of, transfer and otherwise deal with the subject-matter of the Trust in such manner as the Trustees should deem fit so as to enable the institution to carry on the objects of the Trust efficiently. 6. To accept donations, grants, presentations

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

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

house and a residential institution for the students and those connected with the institution. 5. To invest, dispose of, transfer and otherwise deal with the subject-matter of the Trust in such manner as the Trustees should deem fit so as to enable the institution to carry on the objects of the Trust efficiently. 6. To accept donations, grants, presentations

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

house and a residential institution for the students and those connected with the institution. 5. To invest, dispose of, transfer and otherwise deal with the subject-matter of the Trust in such manner as the Trustees should deem fit so as to enable the institution to carry on the objects of the Trust efficiently. 6. To accept donations, grants, presentations

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

house and a residential institution for the students and those connected with the institution. 5. To invest, dispose of, transfer and otherwise deal with the subject-matter of the Trust in such manner as the Trustees should deem fit so as to enable the institution to carry on the objects of the Trust efficiently. 6. To accept donations, grants, presentations

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

house and a residential institution for the students and those connected with the institution. 5. To invest, dispose of, transfer and otherwise deal with the subject-matter of the Trust in such manner as the Trustees should deem fit so as to enable the institution to carry on the objects of the Trust efficiently. 6. To accept donations, grants, presentations

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

house and a residential institution for the students and those connected with the institution. 5. To invest, dispose of, transfer and otherwise deal with the subject-matter of the Trust in such manner as the Trustees should deem fit so as to enable the institution to carry on the objects of the Trust efficiently. 6. To accept donations, grants, presentations

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

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

house and a residential institution for the students and those connected with the institution. 5. To invest, dispose of, transfer and otherwise deal with the subject-matter of the Trust in such manner as the Trustees should deem fit so as to enable the institution to carry on the objects of the Trust efficiently. 6. To accept donations, grants, presentations

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

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

house and a residential institution for the students and those connected with the institution. 5. To invest, dispose of, transfer and otherwise deal with the subject-matter of the Trust in such manner as the Trustees should deem fit so as to enable the institution to carry on the objects of the Trust efficiently. 6. To accept donations, grants, presentations

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

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

house and a residential institution for the students and those connected with the institution. 5. To invest, dispose of, transfer and otherwise deal with the subject-matter of the Trust in such manner as the Trustees should deem fit so as to enable the institution to carry on the objects of the Trust efficiently. 6. To accept donations, grants, presentations

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

house and a residential institution for the students and those connected with the institution. 5. To invest, dispose of, transfer and otherwise deal with the subject-matter of the Trust in such manner as the Trustees should deem fit so as to enable the institution to carry on the objects of the Trust efficiently. 6. To accept donations, grants, presentations

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

house and a residential institution for the students and those connected with the institution. 5. To invest, dispose of, transfer and otherwise deal with the subject-matter of the Trust in such manner as the Trustees should deem fit so as to enable the institution to carry on the objects of the Trust efficiently. 6. To accept donations, grants, presentations

MJSJ COAL LIMITED,ANGUL vs. ITO, WARD-2, DHENKANAL

Appeals of the assessee are allowed

Bench: Shri N.S.Saini, Am & Shri Pavan Kumar Gadale, Jm आयकर अपील सं./Ita Nos.429/Ctk/2016, 68/Ctk/2017 & 107/Ctk/2018 ("नधा"रण वष" / A.Ys :2011-2012, 2013-2014 & 2014-2015) Mjsj Coal Limited, Vs. Ito, Ward-2, Dhenkanal / At/Po:Balanda, Talcher, Ito, Ward-1(3), Bhubaneswar Dist-Angul, Odisha-759116 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aagcm 1095 E (अपीलाथ" /Appellant) (""यथ" / Respondent) .. "नधा"रती क" ओर से /Assessee By : Shri K.K.Bal, Ar राज"व क" ओर से /Revenue By : Shri Subhendu Dutta, Citdr सुनवाई क" तार"ख / Date Of Hearing : 28/08/2018 घोषणा क" तार"ख/Date Of Pronouncement 31/08/2018 आदेश / O R D E R Per Shri Pavan Kumar Gadale, Jm: These Are The Appeals Filed By The Assessee Against The Separate Orders Of Cit(A)-1&3, Bhubaneswar, Dated 28.04.2016, 04.11.2016 & 04.12.2017 Passed In I.T.Appeal Nos.0120/2014-15, 0472/15-16 & 0254/16-17, For The Assessment Years 2011-2012, 2013-2014 & 2014- 2015. 2. Since Issues The Above Appeals Are Common, Therefore, They Are Heard Together & Disposed Off By This Consolidated Order. For The Sake Of Convenience We Shall Take Up Assessee’S Appeal I.E. Ita No.429/Ctk/2016 For Assessment Year 2011-2012 & The Grounds & Facts Mentioned Therein, Wherein The Assessee Has Raised The Following Grounds Of Appeal :- Ground Of Appeal • We Are Not Agreeing With The Computation Of Tax On Interest Earn By Company Made By Assessing Officer. • During The Assessment, The Cases We Submitted To Justify Our Claim (As Mentioned In Statement Of Facts) Has Not Been Paid Any Emphasis For Deciding The Case By The A.0 & Cit (Appeal- 3),Bhubaneswar. On The Other Hand The A.0 & Cit (Appeal-3) Finally Imposed His Decision Based On The Facts Of Alkali Tuticorin Chem. & Fertilizers Ltd. In Which It Has Earned Interest On The Funds, Were Borrowed Funds Only

35,05,670.00 (as TDS of Rs 12,72,540.00 and Tax demand paid of Rs 22,33,130.00) on interests earned is of capital nature . This is "inextricably linked" to the setting up of the business (please refer the case of Bokaro Steel Ltd. (1999) 236 ITR and the latest decision of "Pr. CIT Vs FACOR POWER