MR. TAPAN KUMAR BHUYAN,SALEPUR vs. ITO, WARD-1(1), CUTTACK

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

Bench: Before Shri George Mathan, Judicialita Nos.120 To 123/Ctk/20 /Ctk/2023 Assessment Years : 2011-12 To 2014 12 To 2014-15 Mr Tapan Kumar Bhuyan, Mr Tapan Kumar Bhuyan, Vs. Income Ta Income Tax Officer, Ward- Chandradeipur, Chandradeipur, Salepur, Salepur, 1(1), Cuttack Cuttack Pan/Gir No. Pan/Gir No.Adopb 5206 C (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri Samir Ranjan Dash Dash, Ar Revenue By : Shri S.C.Mohanty : Shri S.C.Mohanty, Sr Dr Date Of Hearing : 07/08 8/2023 Date Of Pronouncement : 07/0 /08/2023 O R D E R These Are These Are Appeals Filed By The Assessee Against The Filed By The Assessee Against The Separate Orders Of Of The The Ld Ld Cit(A) Cit(A), Nfac, Delhi All Dated10.01.2023 10.01.2023 In Appeal No.Itba/Nfac/S/250/2022 Itba/Nfac/S/250/2022-23/1048586596(1),Itba/Nfac/S/250/2022 23/1048586596(1),Itba/Nfac/S/250/2022- 23/1048587277(1),Itba/Nfac/S/250/2022 23/1048587277(1),Itba/Nfac/S/250/2022-23/104858788161) 23/104858788161) & Itba/Nfac/S/250/2022 C/S/250/2022-23/1048588097(1) For The Assessment Years 2011 23/1048588097(1) For The Assessment Years 2011- 12 To 2014-15, Respectively. 15, Respectively.

69A, section 59B, section 59C or section 59D, at the rate of thirty per cent; and (b) the amount of income-tax with which the assessee would have been chargeable had his total income been reduced by the amount of income referred to in clause (a)- (2) Notwithstanding anything contained in this Act, no deduction in respect of any expenditure

MR. TAPAN KUMAR BHUYAN,SALEPUR vs. ITO, WARD-1(1), CUTTACK

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

Bench: Before Shri George Mathan, Judicialita Nos.120 To 123/Ctk/20 /Ctk/2023 Assessment Years : 2011-12 To 2014 12 To 2014-15 Mr Tapan Kumar Bhuyan, Mr Tapan Kumar Bhuyan, Vs. Income Ta Income Tax Officer, Ward- Chandradeipur, Chandradeipur, Salepur, Salepur, 1(1), Cuttack Cuttack Pan/Gir No. Pan/Gir No.Adopb 5206 C (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri Samir Ranjan Dash Dash, Ar Revenue By : Shri S.C.Mohanty : Shri S.C.Mohanty, Sr Dr Date Of Hearing : 07/08 8/2023 Date Of Pronouncement : 07/0 /08/2023 O R D E R These Are These Are Appeals Filed By The Assessee Against The Filed By The Assessee Against The Separate Orders Of Of The The Ld Ld Cit(A) Cit(A), Nfac, Delhi All Dated10.01.2023 10.01.2023 In Appeal No.Itba/Nfac/S/250/2022 Itba/Nfac/S/250/2022-23/1048586596(1),Itba/Nfac/S/250/2022 23/1048586596(1),Itba/Nfac/S/250/2022- 23/1048587277(1),Itba/Nfac/S/250/2022 23/1048587277(1),Itba/Nfac/S/250/2022-23/104858788161) 23/104858788161) & Itba/Nfac/S/250/2022 C/S/250/2022-23/1048588097(1) For The Assessment Years 2011 23/1048588097(1) For The Assessment Years 2011- 12 To 2014-15, Respectively. 15, Respectively.

69A, section 59B, section 59C or section 59D, at the rate of thirty per cent; and (b) the amount of income-tax with which the assessee would have been chargeable had his total income been reduced by the amount of income referred to in clause (a)- (2) Notwithstanding anything contained in this Act, no deduction in respect of any expenditure

MR. TAPAN KUMAR BHUYAN,SALEPUR vs. ITO, WARD-1(1), CUTTACK

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

Bench: Before Shri George Mathan, Judicialita Nos.120 To 123/Ctk/20 /Ctk/2023 Assessment Years : 2011-12 To 2014 12 To 2014-15 Mr Tapan Kumar Bhuyan, Mr Tapan Kumar Bhuyan, Vs. Income Ta Income Tax Officer, Ward- Chandradeipur, Chandradeipur, Salepur, Salepur, 1(1), Cuttack Cuttack Pan/Gir No. Pan/Gir No.Adopb 5206 C (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri Samir Ranjan Dash Dash, Ar Revenue By : Shri S.C.Mohanty : Shri S.C.Mohanty, Sr Dr Date Of Hearing : 07/08 8/2023 Date Of Pronouncement : 07/0 /08/2023 O R D E R These Are These Are Appeals Filed By The Assessee Against The Filed By The Assessee Against The Separate Orders Of Of The The Ld Ld Cit(A) Cit(A), Nfac, Delhi All Dated10.01.2023 10.01.2023 In Appeal No.Itba/Nfac/S/250/2022 Itba/Nfac/S/250/2022-23/1048586596(1),Itba/Nfac/S/250/2022 23/1048586596(1),Itba/Nfac/S/250/2022- 23/1048587277(1),Itba/Nfac/S/250/2022 23/1048587277(1),Itba/Nfac/S/250/2022-23/104858788161) 23/104858788161) & Itba/Nfac/S/250/2022 C/S/250/2022-23/1048588097(1) For The Assessment Years 2011 23/1048588097(1) For The Assessment Years 2011- 12 To 2014-15, Respectively. 15, Respectively.

69A, section 59B, section 59C or section 59D, at the rate of thirty per cent; and (b) the amount of income-tax with which the assessee would have been chargeable had his total income been reduced by the amount of income referred to in clause (a)- (2) Notwithstanding anything contained in this Act, no deduction in respect of any expenditure

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

69A were made without providing statements and materials, on basis of which such additions were made, to assessee, matter should be remitted back without quashing said order. The Hon'ble Madras High Court in the case of Vetrivel Minerals vs. ACIT (129 taxmann.com 126) held where assessment orders passed in case of assessee under section 153A were passed in gross

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

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.

section 69A of the Act is completely wrong, illegal, contrary to the facts on record and not sustainable in the eye of law, hence needs to be deleted in the interest of justice. 5. For that, the Appellant craves leave of this Hon'ble Tribunal to urge other grounds of appeal, if any, at the time of hearing

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

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

section 147 to 151 of the Act and therefore the reassessment order is liable to be quashed. 3. That, the Ld. Commissioner of Income Tax (Appeals) erred in facts in circumstances in confirming the additions of Rs.5,56,94,020 as short term capital gain whereas the assessee is a Real Estate developer and registered the flats valued at Rs.4

SAI SIMRAN INFRATECH PRIVATE LIMITED,BHUBANESWAR vs. INCOME TAX OFFICER,NFAC,DELHI, NFAC DELHI

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

section 147 to 151 of the Act and therefore the reassessment order is liable to be quashed. 3. That, the Ld. Commissioner of Income Tax (Appeals) erred in facts in circumstances in confirming the additions of Rs.5,56,94,020 as short term capital gain whereas the assessee is a Real Estate developer and registered the flats valued at Rs.4

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

section 147 to 151 of the Act and therefore the reassessment order is liable to be quashed. 3. That, the Ld. Commissioner of Income Tax (Appeals) erred in facts in circumstances in confirming the additions of Rs.5,56,94,020 as short term capital gain whereas the assessee is a Real Estate developer and registered the flats valued at Rs.4

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

section 147 to 151 of the Act and therefore the reassessment order is liable to be quashed. 3. That, the Ld. Commissioner of Income Tax (Appeals) erred in facts in circumstances in confirming the additions of Rs.5,56,94,020 as short term capital gain whereas the assessee is a Real Estate developer and registered the flats valued at Rs.4

MSL FISH TRADERS PRIVATE LIMITED,BHUBANESWAR vs. DY.CIT, CENTRAL CIRCLE-2, BHUBANESWAR

In the result, both the appeals of the assessee stand allowed

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita Nos.332 & 333/Ctk/2025 ("नधा"रण वष" / Assessment Years: 2017-18 & 2018-19) Msl Fish Traders Private Limited, Vs Dcit, Central Circle-2, Rooom No.14, Fish Market, Unit-4, Bhubaneswar. Bhubaneswar. Pan No. : Aajcm 1080 E (अपीलाथ" /Appellant) .. (""यथ" / Respondent) "नधा"रती क" ओर से /Assessee By : Shri D.Parida, Ca & Shri Chitrasen Parida, Adv राज"व क" ओर से /Revenue By : Shri Ashim Kumar Chakraborty, Ld Cit Dr सुनवाई क" तार"ख / Date Of Hearing : 3 /12/2025 घोषणा क" तार"ख/Date Of Pronouncement : 3 /12/2025 आदेश / O R D E R Per Bench : These Are Appeals Filed By The Assessee Against The Separate Orders Dated 31.3.2025 Passed By Ld Cit(A), Bhubaneswar-2 In Appeal No.Cit(A), Bhubaneswar-2/11252/2017-18 For The Assessment Years 2017-18 & 2018-19, Respectively. 2. Shri D.Parida & Shri Chitrasen Parida, Ld Ars Appeared For The Assessee & Shri Ashim Kumar Chakraborty, Ld Cit Dr Appeared For The Revenue. 3. It Was Submitted By Ld Ar That The Assessee Has Filed Written Submission, Which Reads As Follows:

69A of the Act without having any corroborated evidences, without considering the remand report remarks and without considering the submission made by the assessee during the appellate proceeding. a) That, the addition of alleged commission of Rs.84,67,864/- is based on the seized documents identified as MFT-34 & MFT-7. An extract of the seized documents and copies

MSL FISH TRADERS PRIVATE LIMITED,BHUBANESWAR vs. DY.CIT, CENTRAL CIRCLE-2, BHUBANESWAR

In the result, both the appeals of the assessee stand allowed

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita Nos.332 & 333/Ctk/2025 ("नधा"रण वष" / Assessment Years: 2017-18 & 2018-19) Msl Fish Traders Private Limited, Vs Dcit, Central Circle-2, Rooom No.14, Fish Market, Unit-4, Bhubaneswar. Bhubaneswar. Pan No. : Aajcm 1080 E (अपीलाथ" /Appellant) .. (""यथ" / Respondent) "नधा"रती क" ओर से /Assessee By : Shri D.Parida, Ca & Shri Chitrasen Parida, Adv राज"व क" ओर से /Revenue By : Shri Ashim Kumar Chakraborty, Ld Cit Dr सुनवाई क" तार"ख / Date Of Hearing : 3 /12/2025 घोषणा क" तार"ख/Date Of Pronouncement : 3 /12/2025 आदेश / O R D E R Per Bench : These Are Appeals Filed By The Assessee Against The Separate Orders Dated 31.3.2025 Passed By Ld Cit(A), Bhubaneswar-2 In Appeal No.Cit(A), Bhubaneswar-2/11252/2017-18 For The Assessment Years 2017-18 & 2018-19, Respectively. 2. Shri D.Parida & Shri Chitrasen Parida, Ld Ars Appeared For The Assessee & Shri Ashim Kumar Chakraborty, Ld Cit Dr Appeared For The Revenue. 3. It Was Submitted By Ld Ar That The Assessee Has Filed Written Submission, Which Reads As Follows:

69A of the Act without having any corroborated evidences, without considering the remand report remarks and without considering the submission made by the assessee during the appellate proceeding. a) That, the addition of alleged commission of Rs.84,67,864/- is based on the seized documents identified as MFT-34 & MFT-7. An extract of the seized documents and copies