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) ..

234) held that neither under section 132 or under section 153A, phraseology 'incriminating' is used by Parliament, therefore, any material unearthed during search operations or any statement made during course of search by assessee is a valuable piece of 20 ITA Nos.76-81/CTK/2022 evidence in order to invoke section 153A. The observations of the Hon'ble High Court in para

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) ..

234) held that neither under section 132 or under section 153A, phraseology 'incriminating' is used by Parliament, therefore, any material unearthed during search operations or any statement made during course of search by assessee is a valuable piece of 20 ITA Nos.76-81/CTK/2022 evidence in order to invoke section 153A. The observations of the Hon'ble High Court in para

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) ..

234) held that neither under section 132 or under section 153A, phraseology 'incriminating' is used by Parliament, therefore, any material unearthed during search operations or any statement made during course of search by assessee is a valuable piece of 20 ITA Nos.76-81/CTK/2022 evidence in order to invoke section 153A. The observations of the Hon'ble High Court in para

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) ..

234) held that neither under section 132 or under section 153A, phraseology 'incriminating' is used by Parliament, therefore, any material unearthed during search operations or any statement made during course of search by assessee is a valuable piece of 20 ITA Nos.76-81/CTK/2022 evidence in order to invoke section 153A. The observations of the Hon'ble High Court in para

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

234) held that neither under section 132 or under section 153A, phraseology 'incriminating' is 29 IT(SS)A No.31-44/CTK/2022 & ITA No.109/CTK/2022 used by Parliament, therefore, any material unearthed during search operations or any statement made during course of search by assessee is a valuable piece of evidence in order to invoke section 153A. The observations of the Hon'ble High

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

reassessment under Section 147(b) maybe\nmade out. There is nothing, however, in the reasons indicated by the\nAssessing Officer in the present case to suggest that any such income\nhas accrued to any person or the Assessee. The reasons do not\nindicate that the Assessing Officer has formed any belief that under-\npricing was adopted by the Assessee

ACIT, CENTRAL CIRCLE-1, BHUBANESWAR vs. M/S. SRI SAI RAMESWARA SOLVENTS PVT. LTD., KORAPUT

In the result, appeals of the revenue in IT(SS)A Nos

Bench: Shri George Mathan & Shri Arun Khodpiaआयकर (तऱाशियाां और अशिग्रहण) अऩीऱ सं/It(Ss)A Nos.04-06/Ctk/2021 (ननधाारण वषा / Assessment Year :2013-2014 To 2015-2016) Acit, Central Circle-1, Vs M/S Sri Sai Rameswara Solvents Bhubaneswar Pvt. Ltd., Bhadraya Street, Jeypore, Koraput-764001 Pan No. : Aajcs 3201 K & Cross Objection Nos.24-26/Ctk/2021 (Arising Out Of It(Ss)A Nos.04-06/Ctk/2021) (ननधाारण वषा / Assessment Year :2013-2014 To 2015-2016) M M/S Sri Sai Rameswara Solvents Vs Acit, Central Circle-1, Pvt. Ltd., Bhadraya Street, Bhubaneswar Jeypore, Koraput-764001 Pan No. : Aajcs 3201 K & आयकर अऩीऱ सं/Ita Nos.81-83/Ctk/2021 (ननधाारण वषा / Assessment Year :2013-2014 To 2015-2016) Acit, Central Circle-1, Vs M/S Sri Sai Rameswara Solvents Bhubaneswar Pvt. Ltd., Bhadraya Street, Jeypore, Koraput-764001 Pan No. : Aajcs 3201 K & Cross Objection Nos.27-29/Ctk/2021 (Arising Out Of Ita Nos.81-83/Ctk/2021) (ननधाारण वषा / Assessment Year :2013-2014 To 2015-2016) M/S Sri Sai Rameswara Solvents Vs Dcit, Corporate Circle-1(2), Pvt. Ltd., Bhadraya Street, Bhubaneswar Jeypore, Koraput-764001 Pan No. : Aabcp 3276 D (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

234) held that neither under section 132 or under section 153A, phraseology 'incriminating' is used by Parliament, therefore, any material unearthed during search operations or any statement made during course of search by assessee is a valuable piece of evidence in order to invoke section 153A. The observations of the Hon'ble High Court in para- 20 & 21 are reproduced

ACIT, CENTRAL CIRCLE-1, BHUBANESWAR vs. M/S. SRI SAI RAMESWARA SOLVENTS PVT. LTD., KORAPUT

In the result, appeals of the revenue in IT(SS)A Nos

Bench: Shri George Mathan & Shri Arun Khodpiaआयकर (तऱाशियाां और अशिग्रहण) अऩीऱ सं/It(Ss)A Nos.04-06/Ctk/2021 (ननधाारण वषा / Assessment Year :2013-2014 To 2015-2016) Acit, Central Circle-1, Vs M/S Sri Sai Rameswara Solvents Bhubaneswar Pvt. Ltd., Bhadraya Street, Jeypore, Koraput-764001 Pan No. : Aajcs 3201 K & Cross Objection Nos.24-26/Ctk/2021 (Arising Out Of It(Ss)A Nos.04-06/Ctk/2021) (ननधाारण वषा / Assessment Year :2013-2014 To 2015-2016) M M/S Sri Sai Rameswara Solvents Vs Acit, Central Circle-1, Pvt. Ltd., Bhadraya Street, Bhubaneswar Jeypore, Koraput-764001 Pan No. : Aajcs 3201 K & आयकर अऩीऱ सं/Ita Nos.81-83/Ctk/2021 (ननधाारण वषा / Assessment Year :2013-2014 To 2015-2016) Acit, Central Circle-1, Vs M/S Sri Sai Rameswara Solvents Bhubaneswar Pvt. Ltd., Bhadraya Street, Jeypore, Koraput-764001 Pan No. : Aajcs 3201 K & Cross Objection Nos.27-29/Ctk/2021 (Arising Out Of Ita Nos.81-83/Ctk/2021) (ननधाारण वषा / Assessment Year :2013-2014 To 2015-2016) M/S Sri Sai Rameswara Solvents Vs Dcit, Corporate Circle-1(2), Pvt. Ltd., Bhadraya Street, Bhubaneswar Jeypore, Koraput-764001 Pan No. : Aabcp 3276 D (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

234) held that neither under section 132 or under section 153A, phraseology 'incriminating' is used by Parliament, therefore, any material unearthed during search operations or any statement made during course of search by assessee is a valuable piece of evidence in order to invoke section 153A. The observations of the Hon'ble High Court in para- 20 & 21 are reproduced

ACIT, CENTRAL CIRCLE-1, BHUBANESWAR vs. M/S. SRI SAI RAMESWARA SOLVENTS PVT. LTD., KORAPUT

In the result, appeals of the revenue in IT(SS)A Nos

Bench: Shri George Mathan & Shri Arun Khodpiaआयकर (तऱाशियाां और अशिग्रहण) अऩीऱ सं/It(Ss)A Nos.04-06/Ctk/2021 (ननधाारण वषा / Assessment Year :2013-2014 To 2015-2016) Acit, Central Circle-1, Vs M/S Sri Sai Rameswara Solvents Bhubaneswar Pvt. Ltd., Bhadraya Street, Jeypore, Koraput-764001 Pan No. : Aajcs 3201 K & Cross Objection Nos.24-26/Ctk/2021 (Arising Out Of It(Ss)A Nos.04-06/Ctk/2021) (ननधाारण वषा / Assessment Year :2013-2014 To 2015-2016) M M/S Sri Sai Rameswara Solvents Vs Acit, Central Circle-1, Pvt. Ltd., Bhadraya Street, Bhubaneswar Jeypore, Koraput-764001 Pan No. : Aajcs 3201 K & आयकर अऩीऱ सं/Ita Nos.81-83/Ctk/2021 (ननधाारण वषा / Assessment Year :2013-2014 To 2015-2016) Acit, Central Circle-1, Vs M/S Sri Sai Rameswara Solvents Bhubaneswar Pvt. Ltd., Bhadraya Street, Jeypore, Koraput-764001 Pan No. : Aajcs 3201 K & Cross Objection Nos.27-29/Ctk/2021 (Arising Out Of Ita Nos.81-83/Ctk/2021) (ननधाारण वषा / Assessment Year :2013-2014 To 2015-2016) M/S Sri Sai Rameswara Solvents Vs Dcit, Corporate Circle-1(2), Pvt. Ltd., Bhadraya Street, Bhubaneswar Jeypore, Koraput-764001 Pan No. : Aabcp 3276 D (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

234) held that neither under section 132 or under section 153A, phraseology 'incriminating' is used by Parliament, therefore, any material unearthed during search operations or any statement made during course of search by assessee is a valuable piece of evidence in order to invoke section 153A. The observations of the Hon'ble High Court in para- 20 & 21 are reproduced

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

reassessment under Section 147(b) maybe\nmade out. There is nothing, however, in the reasons indicated by the\nAssessing Officer in the present case to suggest that any such income\nhas accrued to any person or the Assessee. The reasons do not\nindicate that the Assessing Officer has formed any belief that under-\npricing was adopted by the Assessee

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

reassessment under Section 147(b) maybe\nmade out. There is nothing, however, in the reasons indicated by the\nAssessing Officer in the present case to suggest that any such income\nhas accrued to any person or the Assessee. The reasons do not\nindicate that the Assessing Officer has formed any belief that under-\npricing was adopted by the Assessee

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

reassessment under Section 147(b) maybe\nmade out. There is nothing, however, in the reasons indicated by the\nAssessing Officer in the present case to suggest that any such income\nhas accrued to any person or the Assessee. The reasons do not\nindicate that the Assessing Officer has formed any belief that under-\npricing was adopted by the Assessee

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

234)(SC), the sense in which the word 'education' has been used in section 2(15) is systematic instruction, schooling or training given to the young for preparation for the work of life. The word 'education' has not been used in wide and extended sense according to which every acquisition of knowledge would constitute education. This decision makes it very

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

234)(SC), the sense in which the word 'education' has been used in section 2(15) is systematic instruction, schooling or training given to the young for preparation for the work of life. The word 'education' has not been used in wide and extended sense according to which every acquisition of knowledge would constitute education. This decision makes it very

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

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

234)(SC), the sense in which the word 'education' has been used in section 2(15) is systematic instruction, schooling or training given to the young for preparation for the work of life. The word 'education' has not been used in wide and extended sense according to which every acquisition of knowledge would constitute education. This decision makes it very

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

234)(SC), the sense in which the word 'education' has been used in section 2(15) is systematic instruction, schooling or training given to the young for preparation for the work of life. The word 'education' has not been used in wide and extended sense according to which every acquisition of knowledge would constitute education. This decision makes it very

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

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

234)(SC), the sense in which the word 'education' has been used in section 2(15) is systematic instruction, schooling or training given to the young for preparation for the work of life. The word 'education' has not been used in wide and extended sense according to which every acquisition of knowledge would constitute education. This decision makes it very

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

234)(SC), the sense in which the word 'education' has been used in section 2(15) is systematic instruction, schooling or training given to the young for preparation for the work of life. The word 'education' has not been used in wide and extended sense according to which every acquisition of knowledge would constitute education. This decision makes it very