M/S. MAA TARINI MINERALS PVT. LTD.,ROURKELA vs. DCIT,CENTRAL CIRCLE, SAMBALPUR

In the result, all the appeals of the assessee are allowed

Bench: Shri George Mathan & Shri Manish Agarwalआयकर अऩीऱ सं/Ita Nos.201-205/Ctk/2023 (ननधाारण वषा / Assessment Year : 2014-2015 To 2019-2020) M/S Tarini Minerals Pvt. Ltd. Vs Dcit, Central Circle, Sambalpur A-6, Commercial Estate, Civil Township, Rourkela-769004 Pan No. :Aaact 6489 P (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. ननधााररती की ओर से /Assessee By : Shri S.C.Bhadra, Ca राजस्व की ओर से /Revenue By : Shri Sanjay Kumar, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 27/05/2024 घोषणा की तारीख/Date Of Pronouncement : 27/05/2024 आदेश / O R D E R Per Bench : These Are The Appeals Filed By The Assessee Against The Separate Orders Of The Ld. Cit(A)-2, Bhubaneswar, All Dated 31.03.2023 In The Following Appeals :-

reassess taking into consideration the other material in respect of completed assessments/unabated assessments. Meaning thereby, in respect of completed/unabated assessments, no addition can be made by the AO in absence of any incriminating material found during the course of search under section 132 or requisition under section 132A of the Act, 1961. However, the completed/unabated assessments can be re-opened

M/S. MAA TARINI MINERALS PVT. LTD.,ROURKELA vs. DCIT,CENTRAL CIRCLE, SAMBALPUR

In the result, all the appeals of the assessee are allowed

Bench: Shri George Mathan & Shri Manish Agarwalआयकर अऩीऱ सं/Ita Nos.201-205/Ctk/2023 (ननधाारण वषा / Assessment Year : 2014-2015 To 2019-2020) M/S Tarini Minerals Pvt. Ltd. Vs Dcit, Central Circle, Sambalpur A-6, Commercial Estate, Civil Township, Rourkela-769004 Pan No. :Aaact 6489 P (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. ननधााररती की ओर से /Assessee By : Shri S.C.Bhadra, Ca राजस्व की ओर से /Revenue By : Shri Sanjay Kumar, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 27/05/2024 घोषणा की तारीख/Date Of Pronouncement : 27/05/2024 आदेश / O R D E R Per Bench : These Are The Appeals Filed By The Assessee Against The Separate Orders Of The Ld. Cit(A)-2, Bhubaneswar, All Dated 31.03.2023 In The Following Appeals :-

reassess taking into consideration the other material in respect of completed assessments/unabated assessments. Meaning thereby, in respect of completed/unabated assessments, no addition can be made by the AO in absence of any incriminating material found during the course of search under section 132 or requisition under section 132A of the Act, 1961. However, the completed/unabated assessments can be re-opened

M/S. MAA TARINI MINERALS PVT. LTD.,ROURKELA vs. DCIT,CENTRAL CIRCLE, SAMBALPUR

In the result, all the appeals of the assessee are allowed

Bench: Shri George Mathan & Shri Manish Agarwalआयकर अऩीऱ सं/Ita Nos.201-205/Ctk/2023 (ननधाारण वषा / Assessment Year : 2014-2015 To 2019-2020) M/S Tarini Minerals Pvt. Ltd. Vs Dcit, Central Circle, Sambalpur A-6, Commercial Estate, Civil Township, Rourkela-769004 Pan No. :Aaact 6489 P (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. ननधााररती की ओर से /Assessee By : Shri S.C.Bhadra, Ca राजस्व की ओर से /Revenue By : Shri Sanjay Kumar, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 27/05/2024 घोषणा की तारीख/Date Of Pronouncement : 27/05/2024 आदेश / O R D E R Per Bench : These Are The Appeals Filed By The Assessee Against The Separate Orders Of The Ld. Cit(A)-2, Bhubaneswar, All Dated 31.03.2023 In The Following Appeals :-

reassess taking into consideration the other material in respect of completed assessments/unabated assessments. Meaning thereby, in respect of completed/unabated assessments, no addition can be made by the AO in absence of any incriminating material found during the course of search under section 132 or requisition under section 132A of the Act, 1961. However, the completed/unabated assessments can be re-opened

BIBHUDUTTA PANDA,BHUBANESWAR vs. ASST.CIT, CORPORATE CIRCLE 1(2), BHUBANESWAR

In the result, all appeals of the assessee stand allowed

Bench: Shri George Mathan & Shri Arun Khodpiaआयकर अऩीऱ सं/Ita Nos.76 To 81/Ctk/2022 (ननधाारण वषा / Assessment Years :2007-2008 To 2012-2013) Bibhudutta Panda, Vs Acit, Corporate Circle-1(2), Plot No.73 & 74, Jayadev Vihar, Bhubaneswar Bhubaneswar-751013 Pan No. :Adapp 6398 R (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

144 of the Act, if need be. Therefore, the assessment proceedings generated by the issuance of a notice under Section 153A (1)(a) of the Act can be concluded against the interest of the assessee including making additions even without any incriminating material being available against the assessee in the search under Section 132 of the Act on the basis

BIBHUDUTTA PANDA,BHUBANESWAR vs. ASST.CIT, CORPORATE CIRCLE-1(2), BHUBANESWAR

In the result, all appeals of the assessee stand allowed

Bench: Shri George Mathan & Shri Arun Khodpiaआयकर अऩीऱ सं/Ita Nos.76 To 81/Ctk/2022 (ननधाारण वषा / Assessment Years :2007-2008 To 2012-2013) Bibhudutta Panda, Vs Acit, Corporate Circle-1(2), Plot No.73 & 74, Jayadev Vihar, Bhubaneswar Bhubaneswar-751013 Pan No. :Adapp 6398 R (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

144 of the Act, if need be. Therefore, the assessment proceedings generated by the issuance of a notice under Section 153A (1)(a) of the Act can be concluded against the interest of the assessee including making additions even without any incriminating material being available against the assessee in the search under Section 132 of the Act on the basis

BIBHUDUTTA PANDA,BHUBANESWAR vs. ASST.CIT CORPORATE CIRCLE-1(2), BHUBANESWAR

In the result, all appeals of the assessee stand allowed

Bench: Shri George Mathan & Shri Arun Khodpiaआयकर अऩीऱ सं/Ita Nos.76 To 81/Ctk/2022 (ननधाारण वषा / Assessment Years :2007-2008 To 2012-2013) Bibhudutta Panda, Vs Acit, Corporate Circle-1(2), Plot No.73 & 74, Jayadev Vihar, Bhubaneswar Bhubaneswar-751013 Pan No. :Adapp 6398 R (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

144 of the Act, if need be. Therefore, the assessment proceedings generated by the issuance of a notice under Section 153A (1)(a) of the Act can be concluded against the interest of the assessee including making additions even without any incriminating material being available against the assessee in the search under Section 132 of the Act on the basis

BIBHUDUTTA PANDA,BHUBANESWAR vs. ASST.CIT ,CORPORATE CIRCLE-1(2), BHUBANESWAR

In the result, all appeals of the assessee stand allowed

Bench: Shri George Mathan & Shri Arun Khodpiaआयकर अऩीऱ सं/Ita Nos.76 To 81/Ctk/2022 (ननधाारण वषा / Assessment Years :2007-2008 To 2012-2013) Bibhudutta Panda, Vs Acit, Corporate Circle-1(2), Plot No.73 & 74, Jayadev Vihar, Bhubaneswar Bhubaneswar-751013 Pan No. :Adapp 6398 R (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

144 of the Act, if need be. Therefore, the assessment proceedings generated by the issuance of a notice under Section 153A (1)(a) of the Act can be concluded against the interest of the assessee including making additions even without any incriminating material being available against the assessee in the search under Section 132 of the Act on the basis

BIBHUDUTTA PANDA,BHUBANESWAR vs. ASST.CIT, CORPORATE CIRCLE-1(2), BHUBANESWAR

In the result, all appeals of the assessee stand allowed

Bench: Shri George Mathan & Shri Arun Khodpiaआयकर अऩीऱ सं/Ita Nos.76 To 81/Ctk/2022 (ननधाारण वषा / Assessment Years :2007-2008 To 2012-2013) Bibhudutta Panda, Vs Acit, Corporate Circle-1(2), Plot No.73 & 74, Jayadev Vihar, Bhubaneswar Bhubaneswar-751013 Pan No. :Adapp 6398 R (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

144 of the Act, if need be. Therefore, the assessment proceedings generated by the issuance of a notice under Section 153A (1)(a) of the Act can be concluded against the interest of the assessee including making additions even without any incriminating material being available against the assessee in the search under Section 132 of the Act on the basis

BIBHUDUTTA PANDA,BHUBANESWAR vs. ASST.CIT, CORPORATE CIRCLE-1(2), BHUBANESWAR

In the result, all appeals of the assessee stand allowed

Bench: Shri George Mathan & Shri Arun Khodpiaआयकर अऩीऱ सं/Ita Nos.76 To 81/Ctk/2022 (ननधाारण वषा / Assessment Years :2007-2008 To 2012-2013) Bibhudutta Panda, Vs Acit, Corporate Circle-1(2), Plot No.73 & 74, Jayadev Vihar, Bhubaneswar Bhubaneswar-751013 Pan No. :Adapp 6398 R (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

144 of the Act, if need be. Therefore, the assessment proceedings generated by the issuance of a notice under Section 153A (1)(a) of the Act can be concluded against the interest of the assessee including making additions even without any incriminating material being available against the assessee in the search under Section 132 of the Act on the basis

M/S. BAJRANGBALI STEEL INDUSTRIES PVT. LTD,ROURKLA vs. ACIT, CENTRAL CIRCLE, SAMBALPUR

In the result, appeals of the assessee in IT(SS)A No

Bench: Shri George Mathan & Shri Arun Khodpiaआयकर अऩीऱ (तऱाशियाां और अशिग्रहण)/It(Ss)A Nos.31 To 33/Ctk/2022 (ननधाारण वषा / Assessment Year : 2016-2017 To 2018-2019) M/S Bee Pee Rollers Pvt. Ltd., Vs Acit, Central Circle, Sambalpur Lal Building, Kachery Road, Rourkela, Sundergarh, Odisha-769012 Pan No. :Aabcb 3593 P & आयकर अऩीऱ (तऱाशियाां और अशिग्रहण)/It(Ss)A Nos.34 To 39/Ctk/2022 & आयकर अऩीऱ/Ita No.109/Ctk/2022 (ननधाारण वषा / Assessment Year : 2014-2017 To 2020-2021) M/S Bajrangbali Steel Industries Pvt. Vs Acit, Central Circle, Sambalpur Ltd., Lal Building, Kachery Road, Rourkela, Sundergarh, Odisha-769012 Pan No. :Aabcb 3594 L & आयकर अऩीऱ (तऱाशियाां और अशिग्रहण)/It(Ss)A Nos.40 To 44/Ctk/2022 (ननधाारण वषा / Assessment Year : 2014-2015 To 2018-2019) M/S Bajrangbali Re-Rollers Pvt. Ltd. Vs Acit, Central Circle, Sambalpur Lal Building, Kachery Road, Rourkela, Sundergarh, Odisha-769012 Pan No. :Aaccb 6678 A (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. ननधााररती की ओर से /Assessee By : Shri S.K.Tulsiyan, Advocate With Shri B.K. Tibrewal, Ca & Ms. Nisha Rachh, Ca Shri M.K.Gautam, Pr.Cit(Osd) राजस्व की ओर से /Revenue By : सुनवाई की तारीख / Date Of Hearing : 28/03/2023 घोषणा की तारीख/Date Of Pronouncement : 28/03/2023

144 of the Act, if need be. Therefore, the assessment proceedings generated by the issuance of a notice under Section 153A (l)(a) of the Act can be concluded against the interest of the assessee including making additions even without any incriminating material being available against the assessee in the search under Section 132 of the Act on the basis

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, SAMBALPUR vs. SMT. INDRANI PATNAIK, ROURKELA

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

144, 145, 150, 165, 167, 207, 226,\n227, 777, 791 of 2016, are all cases where reassessment notices are\nissued within four years from the end of the relevant Assessment\nYears. There is no requirement or failure on the part of the assessee\nto disclose fully and truly material facts in these cases. So far as the\ninformation and belief

DEPUTY COMMISSIONER OF INCOME TAX, CENTAL CIRCLE, SAMBALPUR vs. SMT. INDRANI PATNAIK, ROURKELA

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

144, 145, 150, 165, 167, 207, 226,\n227, 777, 791 of 2016, are all cases where reassessment notices are\nissued within four years from the end of the relevant Assessment\nYears. There is no requirement or failure on the part of the assessee\nto disclose fully and truly material facts in these cases. So far as the\ninformation and belief

DEPUTY COMMISSIONER OF INCOME TAX, CENTAL CIRCLE, SAMBALPUR vs. SMT. INDRANI PATNAIK, ROURKELA

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

144, 145, 150, 165, 167, 207, 226,\n227, 777, 791 of 2016, are all cases where reassessment notices are\nissued within four years from the end of the relevant Assessment\nYears. There is no requirement or failure on the part of the assessee\nto disclose fully and truly material facts in these cases. So far as the\ninformation and belief

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, SAMBALPUR vs. SMT. INDRANI PATNAIK, ROURKELA

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

144, 145, 150, 165, 167, 207, 226,\n227, 777, 791 of 2016, are all cases where reassessment notices are\nissued within four years from the end of the relevant Assessment\nYears. There is no requirement or failure on the part of the assessee\nto disclose fully and truly material facts in these cases. So far as the\ninformation and belief

RAMESH CHANDRA CHAND,BALASORE vs. INCOME TAX OFFICER, WARD-1, BALASORE, BALASORE

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

Bench: Before Shri George Mathanmember & Manish Agarwal Manish Agarwalita No.519 /Ctk/2024 Assessment Year : 2017-18 Ramesh Chandra Chand Ramesh Chandra Chand Vs. Income Tax Officer,Ward-1, Income Tax Officer,Ward Bhurukunda, Po. Ambliatha , Po. Ambliatha Balasore Jaleswar Balasore 756032 Balasore 756032 Pan/Gir No. No.Aiuppc 5374 M (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri P.K.Mishra, Adv Revenue By : Shri S.C.Mohanty, Sr Dr 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 04/10/2024 In Appeal No. In Appeal No. Nfac/2016- 17/10301988 For The Assessment Year 2017-18. 2. Shri P.K.Mishra P.K.Mishra, Ld Ar Appeared For The Assessee & Shri The Assessee & Shri S.C.Mohanty, Sr. , Sr. Dr Appeared For The Revenue.

reassessment processing is without jurisdiction the ld CIT(A) should have quashed the assessment. It was the submission that the total deposits in the bank receipts relates to trading receipts by the assessee. Hence, this fact h as not been properly considered by the AO & the ld CIT(A). Further it was submitted that the assessment order has been passed

S.B. COMBINE,CUTTACK vs. INCOME TAX OFFICER, WARD-1(1), CUTTACK, CUTTACK

In the result, appeals of the assessee stand allowed for statistical purposes

Bench: S/Shri Duvvuru Rl Reddy(Kz) & Rajesh Kumar

144, penalty under section 271(1)(c) of the Act and penalty under section271(1)(b) of the Act. 2. At the time of hearing, ld AR of the assessee submitted that the ld CIT(A) has dismissed the appeals of the assessee on the ground of limitation as well as on merits. It was the submission that there

S.B. COMBINE,CUTTACK vs. INCOME TAX OFFICER, WARD-1(1), CUTTACK, CUTTACK

In the result, appeals of the assessee stand allowed for statistical purposes

Bench: S/Shri Duvvuru Rl Reddy(Kz) & Rajesh Kumar

144, penalty under section 271(1)(c) of the Act and penalty under section271(1)(b) of the Act. 2. At the time of hearing, ld AR of the assessee submitted that the ld CIT(A) has dismissed the appeals of the assessee on the ground of limitation as well as on merits. It was the submission that there

ASHA DIDWANIA,BHADRAK vs. ASSESSMENT UNIT, NATIONAL FACELESS ASSESSMENT CENTRE(NFAC), DELHI, DELHI

In the result, both appeals of the assessee are allowed

Bench: Shri George Mathan & Shri Manish Agarwalआयकर अऩीऱ सं/Ita No.128& 129/Ctk/2024 (ननधाारण वषा / Assessment Year : 2014-2015 & 2012-2013) Smt. Asha Didwania, Vs Assessment Unit, National Matrumandir, Near Hp Petrol Faceless Assessment Centre Pump, Charampa, Bhadrak (Nfac), Delhi Pan No. :Aoopd 2243 Q (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. ननधााररती की ओर से /Assessee By : Shri P.K.Mishra, Advocate राजस्व की ओर से /Revenue By : Shri S.C.Mohanty, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 20/05/2024 घोषणा की तारीख/Date Of Pronouncement : 20/05/2024

reassessment order was passed by applying profit rate of 2.3% on the undisclosed bank deposits by treating the same as business turnover. Against the quantum order, the assessee opted for Vivad Se Vishwas Scheme and settled the dispute. However, in the assessment order the AO has initiated the penalty proceedings u/s.271B of the Act for failure to get accounts audited