M/S. PASUPATI BREEDING FARM PVT. LTD.,CUTTACK vs. ACIT, CENTRAL CIRCLE, CUTTACK

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

c) , i.e., whether it is for concealment of income or for furnishing of incorrect particulars of income. Sending printed form where all the grounds mentioned in section 271 are mentioned would not satisfy the requirement of law; The assessee should know the grounds which he has to meet specifically. Otherwise, the principles of natural justice are offended. On the basis

M/S. PRAKASH KUMAR ROUT,CUTTACK vs. ACIT, CENTRAL CIRCLE, CUTTACK

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

c) , i.e., whether it is for concealment of income or for furnishing of incorrect particulars of income. Sending printed form where all the grounds mentioned in section 271 are mentioned would not satisfy the requirement of law; The assessee should know the grounds which he has to meet specifically. Otherwise, the principles of natural justice are offended. On the basis

M/S. PRAKASH KUMAR ROUT,CUTTACK vs. ACIT, CENTRAL CIRCLE, CUTTACK

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

c) , i.e., whether it is for concealment of income or for furnishing of incorrect particulars of income. Sending printed form where all the grounds mentioned in section 271 are mentioned would not satisfy the requirement of law; The assessee should know the grounds which he has to meet specifically. Otherwise, the principles of natural justice are offended. On the basis

PANDA INFRATECH LIMITED,BHUBANESWAR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, BHUBANESWAR

In the result, appeal of the assessee is allowed

Bench: Before Shri George Mathanmember & Manish Agarwal Manish Agarwalassessment Year : 2015-16 Panda Panda Infratech Infratech Limited, Limited, Vs. Dy. Dy. Commissioner Commissioner Of Of Plot Plot No.620, No.620, Janpath, Janpath, Income Tax, Central Circle- Income Tax, Central Circle Saheed Saheed Nagar, Nagar, 2, Bhubaneswar. 2, Bhubaneswar. Bhubaneswar Pan/Gir No. No.Aafcp7216 D (Appellant (Appellant) .. ( Respondent Respondent) Assessee By Assessee By : Shri D.Parida, Ca & C.A.Parida & C.A.Parida, Adv Revenue By : Shri S.C.Mohanty, Sr Dr : Shri S.C.Mohanty, Sr Dr Date Of Hearing : 16/12/20 2024 Date Of Pronouncement : 16/12/20 024 O R D E R Per Bench This Is An This Is An Appeal Filed By The Assessee Against The Orde Appeal Filed By The Assessee Against The Order Of The Ld Cit(A), Bhubaneswar Cit(A), Bhubaneswar-2 Dated 10.8.2024 In Appeal No. In Appeal No.Cit(A), Bhubaneswar-2/10013/2018 2/10013/2018-19 Against Against The The Penalty Penalty Order Order Passed Passed U/S.271Aab Of The Act U/S.271Aab Of The Act For The Assessment Year 2015-16. 2. The Assessee Has Raised The Following Grounds In This Appeal: The Assessee Has Raised The Following Grounds In This Appeal: The Assessee Has Raised The Following Grounds In This Appeal:

1)(c) , i.e., whether it is for concealment of income or for furnishing of incorrect particulars of income. Sending printed form where all the grounds mentioned in section 271 are mentioned would not satisfy the requirement of law; The assessee should know the grounds which he has to meet specifically. Otherwise, the principles of natural justice are offended

DCIT, BHUBANESWAR vs. M/S. G.V.V.CONSTRUCTIONS PVT. LTD., BHUBANESWAR

Appeal of the revenue are dismissed and the appeal of the revenue is dismissed

Bench: Shri N.S.Saini, Am & Shri Pavan Kumar Gadale, Jm आयकर अपील सं./Ita No.297/Ctk/2015 (धनधाारण वषा / Assessment Year :2010-2011) Dcit, Corporate Circle-1(1), Vs. M/S G.V.V. Constructions Bhubaneswar Pvt. Ltd., Plot No.358, Saheed Nagar, Bhubaneswar-751007 स्थायी लेखा सं./जीआइआर सं./ Pan/Gir No. : Aaccg 3649 Q (अपीलाथी /Appellant) .. (प्रत्यथी / Respondent) & Cross Objection No.36/Ctk/2015 (निर्धारण वर्ा / Assessment Year :2010-2011) M/S G.V.V.Constructions Vs. Dcit, Corporate Circle-1(1), Pvt. Ltd., Plot No.358, Bhubaneswar Saheed Nagar, Bhubaneswar-751007 स्थायी लेखा सं./जीआइआर सं./ Pan/Gir No. : Aaccg 3649 Q (अपीलाथी /Appellant) (प्रत्यथी / Respondent) .. राजस्व की ओर से /Revenue By : Shri D.K.Pradhan, Citdr धनधााररती की ओर से /Assessee By : None सुनवाई की तारीख / Date Of Hearing : 03/08/2017 घोषणा की तारीख/Date Of Pronouncement 09/08/2017 आदेश / O R D E R Per Shri Pavan Kumar Gadale, Jm: The Revenue Has Filed An Appeal & The Assessee Has Filed Cross Objection Against The Order Of Cit(A)-2, Bhubaneswar In I.T.Appeal No.0593/2013-14, Dated 9-3-2015, Passed U/S.271(1)(C) & 250 Of The Act. 2. None Appeared On Behalf Of The Assessee When The Matter Was Called For Hearing. Hence, We Proceed To Dispose Off The Appeal On The Basis Of Material Available On Record & The Submissions Of Ld. Dr. 3. We Take Up The Revenue’S Appeal In Ita No.297/Ctk/2015, Wherein The Revenue Has Raised The Following Grounds :-

1)(c), i.e., whether it is for concealment of income or for furnishing of incorrect particulars of income. Sending printed form where all the ground mentioned in Section 271 are mentioned would not satisfy requirement of law. The assessee should know the grounds which he has to meet specifically. Otherwise, principles of natural justice is offended. On the basis

DEPUTY COMMISSIONER OF INCOME TAX, ODISHA vs. ODISHA STATE BEVERAGES CORPORATION LIMITED, ODISHA

In the result, appeal of the revenue stands dismissed

Bench: Before Shri George Mathan, Judicial & Manish Agarwal Manish Agarwalassessment Year : 2020-2021 2021 Dcit, Aayakar Bhavan, Main Dcit, Aayakar Bhavan, Main Vs. Odisha Odisha State State Beverages Beverages 2Nd Building, Building, Rajaswas Rajaswas Vihar, Vihar, Corporation Corporation Limited., Limited., 2 Vani Vihar, Bhubaneswar. Vani Vihar, Bhubaneswar. Floor, Floor, Fortune Fortune Towers, Towers, S.E.Rly S.E.Rly Proj. Proj. Complex, Complex, Bhubaneswar. Bhubaneswar. Pan/Gir No Pan/Gir No. (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri Satyajit Mishra, Ca Satyajit Mishra, Ca Revenue By : Shri Sanjay Kumar, Cit : Shri Sanjay Kumar, Cit Dr Date Of Hearing : 11/0 06/2024 Date Of Pronouncement : 11/0 /06/2024 O R D E R Per Bench This Is An Appeal Filed By The Revenue Against The Order Of The Ld Against The Order Of The Ld Cit(A), Nfac, Delhi Dated Cit(A), Nfac, Delhi Dated 21.9.2023 Deleting The Penalty Levied U/S.270A Of 21.9.2023 Deleting The Penalty Levied U/S.270A Of The Act For The Assessment Year For The Assessment Year 2020-2021. 2. Brief Facts Of The Case Are That The Assessment In This Case Was Brief Facts Of The Case Are That The Assessment In This Case Was Brief Facts Of The Case Are That The Assessment In This Case Was Passed U/S.143(3) Of The Act On 23.9.2 Passed U/S.143(3) Of The Act On 23.9.2022 By Disallowing A Sum Of 022 By Disallowing A Sum Of Rs.3,00,00,000/ Rs.3,00,00,000/- Out Of Expenses Claimed By The Assessee On Account Of Out Of Expenses Claimed By The Assessee On Account Of License Fees U/S.40(A)(Iib) Of The Act. Simultaneously, Penalty Proceedings License Fees U/S.40(A)(Iib) Of The Act. Simultaneously, Penalty Proceedings License Fees U/S.40(A)(Iib) Of The Act. Simultaneously, Penalty Proceedings

1)(c) of the Income-tax Act. In order to rationalise and bring objectivity, certainty and clarity in the penalty provisions, it is proposed that section 271 shall not apply to and in relation to any assessment for the assessment year commencing on or after the 1st day of April, 2017 and subsequent assessment years and penalty be levied under

SANTOSH KUMAR KHANDELWAL,BARIPADA vs. ACIT, BALASORE, BALASORE

In the result, appeal of the assessee is allowed

Bench: Shri George Mathan & Shri Manish Agarwalआयकर अपील संसंसंसं/Ita No.449/Ctk/2024 (िनधा"रण िनधा"रण िनधा"रण वष" िनधा"रण वष" वष" / Assessment Year : 2017-2018) वष"

1)(c) of the Income-tax Act. In order to rationalise and bring objectivity, certainty and clarity in the penalty provisions, it is proposed that section 271 shall not apply to and in relation to any assessment for the assessment year commencing on or after the 1st day of April, 2017 and subsequent assessment years and penalty be levied under

MIRA DEVI DASRAPURIA,KHURDA vs. ITO, KHURDA WARD, KHURDA

In the result, appeal of the assessee is allowed

Bench: Shri N.S.Saini, Am & Shri Pavan Kumar Gadale, Jm आयकर अपील सं./Ita No.363/Ctk/2016 ("नधा"रण वष" / Assessment Year :2011-2012) Smt. Mira Devi Dasrapuria, Vs. Ito, Khurda Main Road, Khurda-752055 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Abkpm 8607 J (अपीलाथ" /Appellant) (""यथ" / Respondent) .. "नधा"रती क" ओर से /Assessee By : Shri Mahesh Kumar Agarwalla,Ar राज"व क" ओर से /Revenue By : Shri D.K.Pradhan,Citdr सुनवाई क" तार"ख / Date Of Hearing : 24/08/2017 घोषणा क" तार"ख/Date Of Pronouncement 31/08/2017 आदेश / O R D E R Per Shri Pavan Kumar Gadale, Jm: The Assessee Has Filed An Appeal Against The Order Of Cit(A)-1, Bhubaneswar, Dated 15.7.2016, Passed In I.T.Appeal No.0317/15-16, U/S.271(1)(C) Of The Income Tax Act, 1961 For The Assessment Year 2011- 2012. 2. The Assessee Has Challenged The Action Of Cit(A) In Confirming The Penalty Levied U/S.271(1)(C) Of The Act, Though The Assessee Has Furnished Information & Accepted The Income In The Course Of Assessment Proceedings. 3. Brief Facts Of The Case Are That The Assessee Is In The Business Of Retail Trading In Cement & Iron Materials & Wholesale Distributor Of Airtel Rcv & Filed The Return Of Income Electronically For The Assessment Year 2010-2011 On 29.09.2011 With Total Income Of Rs.1,81,000/- & The Return Of Income Was Processed U/S.143(1) Of The Act. Subsequently

1)(c), i.e., whether it is for concealment of income or for furnishing of incorrect particulars of income. Sending printed form where all the ground mentioned in Section 271 are mentioned would not satisfy requirement of law. The assessee should know the grounds which he has to meet specifically. Otherwise, principles of natural justice is offended. On the basis

M/S. ALTRADE MINERALS PVT. LIMITED,ROURKELA vs. ACIT,CENTRAL CIRCLE, SAMBALPUR, SAMBALPUR

In the result, appeal of the assessee is partly allowed

Bench: Before Shri George Mathanmember & Manish Agarwal Manish Agarwalassessment Year : 2011-12 M/S. Altrade Minerals Pvt /S. Altrade Minerals Pvt Vs. Asst. Asst. Commissioner Commissioner Of Of Ltd., C/O. Kadmawala & Co., C/O. Kadmawala & Co., Income Tax, Central Circle, Income Tax, Central Circle, C.A., C.A., Budhram Budhram Oram Oram Sambalpur Market, Market, Kachery Kachery Road, Road, Rourkela. Pan/Gir No. No.Aafca 7136 F (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri M.R.Sahu, Ca Revenue By : Shri S.C.Mohanty, Sr Dr : Shri S.C.Mohanty, Sr Dr Date Of Hearing : 16/12/20 2024 Date Of Pronouncement : 16/12/20 024

reassessment was bad in law for failure to issue notice to the Assessee under section 143(2) of the Act?” The Hon’ble Orissa High Court is answering the question, held as follows: “”3. As far as Question No.(iii) is concerned , Mr. Satapathy, learned Senior Standing Counsel for the Department raises preliminary objection that this issue was not raised

MARUTI TRADING CO,JAGAATSINGHPUR vs. ITO WARD PARADEEP, PARADEEP

In the result, appeal of the assessee stands allowed

Bench: Before Shri George Mathan, Judicialassessment Year : 2015-16 Maruti Trading Co., Maruti Trading Co., Panisalia, Vs. Ito, Ward, Paradeep. Ito, Ward, Paradeep. Jagatsinghpur. Jagatsinghpur. Pan/Gir No. Pan/Gir No.Aalfm 3677 L (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri P.R.Mohanty P.R.Mohanty, Ar Revenue By : Shri S.C.Mohanty : Shri S.C.Mohanty, Sr Dr Date Of Hearing : 16/08 8/2023 Date Of Pronouncement : 16/0 /08/2023 O R D E R

reassessment no more survive, the original assessment comes into effect and so also the penalty order u/s.271(1)(c) of the Act. It was the submission that the Assessing Officer in page 2 of his order levying the penalty u/s.271(1)(c) himself has recognized that it is not proper to impose penalty in respect of addition of Rs.97

M/S. VISION HABITATE & SERVICES PVT. LTD.,SAMBALPUR vs. PR. CIT, SAMBALPUR

In the result, the appeal of assessee is allowed

Bench: Shri C.M. Garg, Jm & Shri L.P. Sahu, Am आयकर अऩीऱ सं./Ita No.214/Ctk/2019 (नििाारण वषा / Assessment Year :2014-2015) M/S Vision Habitate & Services Vs. Pr. Cit, Sambalpur-768004 Private Limited, Kadambari Complex, Gole Bazar, Sambalpur-768001 Pan No. : Aadcn 4768 J (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. ननधााररती की ओर से /Assessee By : Shri B.N.Agrawal/Binod Agrawal, Ars राजस्व की ओर से /Revenue By : Shri M.K.Gautam, Citdr सुनवाई की तारीख / Date Of Hearing : 25/08/2020 घोषणा की तारीख/Date Of Pronouncement : 31/08/2020 आदेश / O R D E R Per L.P.Sahu, Am: This Is An Appeal Filed By The Assessee Against The Order Passed By The Pr.Cit, Sambalpur, Dated 30.03.2019 For The A.Y.2014-2015 On The Following Grounds :- 1. That The Order U/S. 263 Is Bad In Law As Well As In Facts. 2. That The Order U/S. 263, Stated To Have Been Passed On 30.03.2019, Is Ante Dated & Barred By Limitation, Being Issued & Served Upon The Appellant On 30.04.2019, Which Is After The Expiry Of Period Of Limitation On 31.03.2019. 3. That The Assessment Order Dt.29.12.2016 Making An Addition Of Rs.27,51,100 To The Returned Income U/S.56(2)(Viib) Consequent Upon Valuation Of Book Value Of 4,510 Nos. Of Equity Shares @ Rs.739 Per Share As On 31.03.2013 Allotted On 31.03.2014 @ Rs.1,349 Per Share. Thus, The Difference Of Rs.610 Per Share Multiplied By 4,510 Nos. Of Shares Allotted Coming To Rs.27,51,100 Has Been Added As Above By The Id. Ao. The Said Valuation & The Consequential Addition Has Been Disputed By The Appellant In The Appeal In Form No.35 E-Filed Before The Id.

c. ACXT v Orissa Stevedores ltd, ITA Nos. 409 to 411/CTK/2011 and CO Nos 30 to 32/201 1, Order dated 22,12.2011. (Page 14 to19) d. ACIT v. Dn Tulsi Prasad Mohapatra & Dr. (Smt.) Debadutta Mallick ITA NOS. 412 & 413/CTK/2011 and CO. Nos. 27 & 2B/CTK/2011, Order dated 17.02.2012. (Page 20 to 24) e. Sri Trinath Chowdary & Others v» ACIT

ASHA DIDWANIA,BHADRAK vs. ASSESSMENT UNIT, NATIONAL FACELESS ASSESSMENT CENTRE, 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

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

BISWA RANJAN PATTNAIL,ANGUL vs. ITO, DHENKANAL

In the result, the appeal filed by the assessee is allowed

Bench: S/Shri N.S Saini & Pavan Kumar Gadaleassessment Year : 2006-07

section 271(1)(c) of Rs.29,280/- by an order dated 28.6.2010. 7. On appeal, the CIT(A) confirmed the order of the Assessing Officer levying penalty. Aggrieved by the order of the CIT(A), the assessee has filed appeal before the Tribunal. 8. Ld A.R. of the assessee argued that the CIT(A) erred in confirming the penalty irrespective

KOTHAKOTA RAMA RAO,RAYAGADA vs. ACIT, CENTRAL CIRCLE-1, BHUBANESWAR

In the result, appeals of the assessee i

Bench: Shri C.M. Garg, Jm & Shri L.P. Sahu, Am आयकर अऩीऱ (तऱाशियाां और अशिग्रहण)सं./Ita No.132/Ctk/2018 (नििाारण वषा / Assessment Year :2013-2014) Kothakota Rama Rao, Vs. Acit, Central Circle-1, Kothapeta, Rayagada, Bhubaneswar District-Rayagada Pan No. : Aeppk 1600 P & आयकर अऩीऱ सं./Ita Nos.19&20/Ctk/2019 & Ita No.386/Ctk/2018 (नििाारण वषा / Assessment Year :2014-15, 2015-16 & 2016-17) Kothakota Rama Rao, Vs. Acit, Central Circle-1, Kothapeta, Rayagada, Bhubaneswar District-Rayagada Pan No. : Aeppk 1600 P (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. ननधााररती की ओर से /Assessee By : Shri P.K.Mishra, Advocate राजस्व की ओर से /Revenue By : Shri M.K.Gautam, Citdr सुनवाई की तारीख / Date Of Hearing : 15/07/2020 घोषणा की तारीख/Date Of Pronouncement : 31/08/2020 आदेश / O R D E R Per L.P.Sahu, Am: These Are The Appeals Filed By The Assessee Against The Separate Orders Of Cit(A)-2, Bhubaneswar, Dated 11.09.2018 & 29.08.2018 For Assessment Years 2013-2014, 2014-2015, 2015-2016 & 2016-2017. 2. Since, Similar Issues Have Been Raised In All The Appeals, Therefore, For The Sake Of Convenience & Brevity, We Shall Decide The Appeal Of The Assessee For A.Y.2013-2014 In It(Ss)A No.132/Ctk/2018 After Taking Into Consideration The Grounds & Facts Mentioned

271(l)(a)(i). If we find that language to be ambiguous or capable of more meanings than one, then we have to adopt that interpretation which favours the assessee, more particularly so because the provision relates to imposition of penalty. " The proposition which was laid down by this Court was that if two reasonable constructions of taxing statute

KOTHAKOTA RAMA RAO,RAYAGADA vs. ACIT, CENTRAL CIRCLE-1, BHUBANESWAR

In the result, appeals of the assessee i

Bench: Shri C.M. Garg, Jm & Shri L.P. Sahu, Am आयकर अऩीऱ (तऱाशियाां और अशिग्रहण)सं./Ita No.132/Ctk/2018 (नििाारण वषा / Assessment Year :2013-2014) Kothakota Rama Rao, Vs. Acit, Central Circle-1, Kothapeta, Rayagada, Bhubaneswar District-Rayagada Pan No. : Aeppk 1600 P & आयकर अऩीऱ सं./Ita Nos.19&20/Ctk/2019 & Ita No.386/Ctk/2018 (नििाारण वषा / Assessment Year :2014-15, 2015-16 & 2016-17) Kothakota Rama Rao, Vs. Acit, Central Circle-1, Kothapeta, Rayagada, Bhubaneswar District-Rayagada Pan No. : Aeppk 1600 P (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. ननधााररती की ओर से /Assessee By : Shri P.K.Mishra, Advocate राजस्व की ओर से /Revenue By : Shri M.K.Gautam, Citdr सुनवाई की तारीख / Date Of Hearing : 15/07/2020 घोषणा की तारीख/Date Of Pronouncement : 31/08/2020 आदेश / O R D E R Per L.P.Sahu, Am: These Are The Appeals Filed By The Assessee Against The Separate Orders Of Cit(A)-2, Bhubaneswar, Dated 11.09.2018 & 29.08.2018 For Assessment Years 2013-2014, 2014-2015, 2015-2016 & 2016-2017. 2. Since, Similar Issues Have Been Raised In All The Appeals, Therefore, For The Sake Of Convenience & Brevity, We Shall Decide The Appeal Of The Assessee For A.Y.2013-2014 In It(Ss)A No.132/Ctk/2018 After Taking Into Consideration The Grounds & Facts Mentioned

271(l)(a)(i). If we find that language to be ambiguous or capable of more meanings than one, then we have to adopt that interpretation which favours the assessee, more particularly so because the provision relates to imposition of penalty. " The proposition which was laid down by this Court was that if two reasonable constructions of taxing statute

KOTHAKOTA RAMA RAO,RAYAGADA vs. ACIT, CENTRAL CIRCLE-1, BHUBANESWAR

In the result, appeals of the assessee i

Bench: Shri C.M. Garg, Jm & Shri L.P. Sahu, Am आयकर अऩीऱ (तऱाशियाां और अशिग्रहण)सं./Ita No.132/Ctk/2018 (नििाारण वषा / Assessment Year :2013-2014) Kothakota Rama Rao, Vs. Acit, Central Circle-1, Kothapeta, Rayagada, Bhubaneswar District-Rayagada Pan No. : Aeppk 1600 P & आयकर अऩीऱ सं./Ita Nos.19&20/Ctk/2019 & Ita No.386/Ctk/2018 (नििाारण वषा / Assessment Year :2014-15, 2015-16 & 2016-17) Kothakota Rama Rao, Vs. Acit, Central Circle-1, Kothapeta, Rayagada, Bhubaneswar District-Rayagada Pan No. : Aeppk 1600 P (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. ननधााररती की ओर से /Assessee By : Shri P.K.Mishra, Advocate राजस्व की ओर से /Revenue By : Shri M.K.Gautam, Citdr सुनवाई की तारीख / Date Of Hearing : 15/07/2020 घोषणा की तारीख/Date Of Pronouncement : 31/08/2020 आदेश / O R D E R Per L.P.Sahu, Am: These Are The Appeals Filed By The Assessee Against The Separate Orders Of Cit(A)-2, Bhubaneswar, Dated 11.09.2018 & 29.08.2018 For Assessment Years 2013-2014, 2014-2015, 2015-2016 & 2016-2017. 2. Since, Similar Issues Have Been Raised In All The Appeals, Therefore, For The Sake Of Convenience & Brevity, We Shall Decide The Appeal Of The Assessee For A.Y.2013-2014 In It(Ss)A No.132/Ctk/2018 After Taking Into Consideration The Grounds & Facts Mentioned

271(l)(a)(i). If we find that language to be ambiguous or capable of more meanings than one, then we have to adopt that interpretation which favours the assessee, more particularly so because the provision relates to imposition of penalty. " The proposition which was laid down by this Court was that if two reasonable constructions of taxing statute

SAI SIMRAN INFRATECH PRIVATE LIMITED,BHUBANESWAR,ODISHA vs. INCOME TAX OFFICER,WARD-1(1), BHUBANESWAR

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

c) & 271F of the Act, respectively. The assessment year under consideration in the above four appeals is A.Y.2015-2016. 2. First, we shall take up the appeal of the assessee in ITA No.87/CTK/2024, wherein the assessee has raised the following grounds:- 1. That, the reopening of the assessment beyond four years after obtaining the approval of the Ld. Addl