MANORANJAN MOHANTY,RAYAGADA vs. INCOME TAX OFFICER, RAYAGADA WARD, RAYAGADA, RAYAGADA

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

Bench: Before Shri George Mathanmember & Manish Agarwal Manish Agarwalassessment Year : 2015-16 Manoranjan Manoranjan Mohanty, Mohanty, At: Vs. Ito, Ward, Rayagada Ito, Ward, Rayagada B.C.Road, Ps/Ps Jaykaypur, B.C.Road, Ps/Ps Jaykaypur, Dist: Rayagada Dist: Rayagada Pan/Gir No. No.Bhcpm 7872 C (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri P.K.Mishra, 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 28.11.2024 In Appeal No. Nfac/2014 28.11.2024 In Appeal No. Nfac/2014- 15/10280648 For The For The Assessment Year 2015-16. 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 order passed by the learned A.O. is without jurisdiction and without the authority of law, as it is based on change of opinion, the learned CIT(A), has committed gross error of law in confirming the same, as such both orders being not sustainable in the eye of law is liable to be quashed in the interest of justice

MIRNAL MEHTA,CUTTACK vs. ITO WRD-2(4), , CUTTACK

In the result, appeal of the assessee is allowed

144B dt 30.03.2022, it can be seen that the reopen reason was cash deposits in State Bank of India having account No. 30926528935. As per AO the information was received from CRIU/VRU Section ( borrowed information by AO ) that heavy cash is deposited in the State Bank of India having account No. 30926528935. The said bank was duly verified

OMM DHANA LAXMI JEWELLERS,ANGUL vs. PCIT, INCOME TAX

In the result, appeal of the assessee stands allowed

Bench: Shri George Mathan & Manish Agarwalassessment Year : 2013-14 M/S. Omm Dhanalaxmi Vs. Pr. Cit, Bhubaneswar-1. Jewellers, Bazar Chowk, Main Road, Angul-759122 Pan/Gir No.Aagfd 8791 D (Appellant) .. ( Respondent) Assessee By : Shri P.K.Mishra, Adv Revenue By : Shri Sanjay Kumar, Cit Dr Date Of Hearing : 23/9/2024 Date Of Pronouncement : 23/9/2024 O R D E R Per Bench This Is An Appeal Filed By The Assessee Against The Order Passed By The Ld Pr.Cit, Bhubaneswar-1 U/S.263 Of The Act Dated 30.3.2024 For The Assessment Year 2013-14. 2. The Assessee Has Raised The Following Grounds: “1) That The Ld. Pr Cit Bhubaneswar Has Erred In Law By Utilizing Section 263 For Directing The Assessing Officer To Do Necessary Verification As Per The Order Of Hon'Ble Itat Cuttack Bench Vide Order Dated 01-10-2019 Which Was Already Barred By Limitation. Provisions Of 263 Does Not Allow To Proceed For A Matter Which Was Already Barred By Limitation. Hence, The Order Passed Us 263 Needs To Be Quashed In To.

section 147 for the reason for failure on the part of the assessee to disclose fully and truly all material facts necessary for his assessment for that assessment year. The total quantum income escaped is prima facie calculated at Rs.20,00,000/-“ 4. After that the reassessment order was passed on 29.09.2021 by making addition

MAA PAHADWALI RICE MILL,BOUDH, ODISHA vs. ITO, WARD, PHULBANI, PHULBANI

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

Bench: Before Shri George Mathanmember & Manish Agarwal Manish Agarwalassessment Year : 2017-18 Maa Pahadwali Rice Mill, Maa Pahadwali Rice Mill, Vs. Ito, Ward, Phulbani Ito, Ward, Phulbani Kamalpur, Po: Telibandha, Kamalpur, Po: Telibandha, Dist: Boudh. Pan/Gir No. No.Aaufm 3720 D (Appellant (Appellant) .. ( Respondent Respondent) Assessee By Assessee By : Shri J.M.Pattnaik & Subit Sahu, Advs J.M.Pattnaik & Subit Sahu, Advs Revenue By : Shri Sanjay Kumar, Cit Sanjay Kumar, Cit Dr Date Of Hearing : 23/9/202 24 Date Of Pronouncement : 23/9/20 024 O R D E R Per Bench

144B of the Act making addition u/s.68 of the Act of the cash deposits made in the cash credit account standing in State of Bank of India without considering the facts of the case. It was also the submission that the Assessing Officer cannot complete the reassessment order without service of the notice so issued upon the assessee in accordance

S S BRAHMA EDUCATIONAL TRUST,MAYURBHANJ vs. PRINICIPAL COMMISSIONER OF INCOME TAX, PCIT, SAMBALPUR, SAMBALPUR

In the result, appeal of the assessee is allowed

144B of the Act, by treating Rs.2,49,82,396.00 as unexplained income ujs.69 of the Act, as such, the impugned revision order passed ujs.263 of the Act, being not sustainable in the eye of law, needs to be quashed in the interest of justice. 6. For that section 69 of the Act has no application under the facts