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:

money u/s 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

SHRI MAHESH KUMAR AGARWAL,SUNDARGARH vs. DCIT, CENTRAL CIRCLE-2, BHUBANESWAR

In the result, assessee’s appeal in the case of Mahesh

Bench: Shri C.M. Garg, Jm & Shri Manish Borad, Am It(Ss)A No.117-119/Ctk/2018 ( Assessment Years :2011-2012 To 2013-2014) Mahesh Kumar Agarwal, Vs Dcit, Central Circle-2, Plot No.O-10, Civil Township, Bhubaneswar Rourkela, Sundargarh-769004 Pan No. : Abdpa 8307 Q & It(Ss)A No.146&147/Ctk/2018 (Assessment Years :2011-2012 & 2012-2013) Dcit, Central Circle-2, Vs Mahesh Kumar Agarwal, Bhubaneswar Plot No.O-10, Civil Township, Rourkela, Sundargarh-769004 Pan No. : Abdpa 8307 Q & It(Ss)A No.44/Ctk/2018 (नििाारण वषा / Assessment Year :2011-2012) Smt. Sanju Agarwal, Vs Dcit, Central Circle-2, Plot No.O-10, Civil Township, Bhubaneswar Rourkela, Sundargarh-769004 Pan No. : Aavpa 4328 C (अऩीलाथी /Appellant) (प्रत्यथी / Respondent) .. ननधाारिती की ओर से /Assessee By : Shri S.M.Surana, Ar िाजस्व की ओर से /Revenue By : Shri M.K.Gautam, Citdr सुनवाई की तािीख / Date Of Hearing : 22/10/2021 घोषणा की तािीख/Date Of Pronouncement : 10/01/2022 आदेश / O R D E R Per Bench: In The Above Captioned Seven Appeals, Five Appeals Have Been Filed By Two Different Assessees & Two Appeals Have 2 It(Ss)A Nos.44/Ctk/2018 It(Ss)A Nos.117-119/Ctk/2018 It(Ss)A Nos.146&147/Ctk/2018 & Ita No.382/Ctk/2018 Been Filed By The Department Which Are Directed Against The Separate Orders Of Cit(A)-2, Bhubaneswar, All Dated 31.01.2018 For The Assessment Years 2011-2012, 2012-2013, 2013-2014 & 2014-2015, Respectively.

money and cost of material) as the same was made on the basis of seized document MAR-09 which is an agreement for cancellation of MOU. (2) That in facts and circumstances, the Ld. CIT (Appeals) has erred in accepting the explanation of assessee that investment of Rs. 9,30,00,000/- were made through group companies/concerns of the assessee

GULLIPALLI RAM PRASAD,VISAKHAPATNAM vs. INCOME TAX OFFICER WARD 1, BERHAMPUR

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

Bench: Before Shri George Mathanmember & Manish Agarwal Manish Agarwalassessment Year : 2018-19 Gullipalli Gullipalli Ram Ram Prasad, Prasad, Vs. Income Tax Officer, Ward-1, Income Tax Offi 1/218/34, 1/218/34, Sri Sri Simhadri S Berhampur Residency, Residency, Chandanpur Chandanp Colony, Colony, Flat Flat No.703, No.703, Gopalapatam, Gopalapatam, Visakhapatnam Visakhapatnam Pan/Gir No. No.Aucoo 7479 A (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri N.Trinath Rao, Ca N.Trinath Rao, Ca Revenue By : Shri S.C.Mohanty, Sr Dr : Shri S.C.Mohanty, Sr Dr Date Of Hearing : 08/01/20 2025 Date Of Pronouncement : 08/01/20 025 O R D E R

reassessment proceedings u/s.147 of the Act, the assessee could not furnish the return of income and furnish submission regarding the credit entries in the bank accounts. Therefore, the Assessing Officer proceeded to pass the assessment order u/s.147 r.w.s 144 of the Act, making addition of Rs.87,99,924/- as unexplained money

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.

unexplained money by applying provisions of section 69A of the Act, ignoring the fact that, the total deposits made in the bank account are nothing but the trading receipts received by the Appellant, as such, the impugned addition made by the learned A.O. and confirmed by the learned CIT(A), being not sustainable in the eye of law, needs

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

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

unexplained money u/s 69A of the Act as these cash deposits are from the earlier withdrawals and therefore the additions on 11,50,000 is liable to be deleted. 5. That, the appellant craves to alter, amend, modify or add any other ground that may be considered necessary in the course of appeal proceeding. 3. In grounds of appeal

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

unexplained money u/s 69A of the Act as these cash deposits are from the earlier withdrawals and therefore the additions on 11,50,000 is liable to be deleted. 5. That, the appellant craves to alter, amend, modify or add any other ground that may be considered necessary in the course of appeal proceeding. 3. In grounds of appeal

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

unexplained money u/s 69A of the Act as these cash deposits are from the earlier withdrawals and therefore the additions on 11,50,000 is liable to be deleted. 5. That, the appellant craves to alter, amend, modify or add any other ground that may be considered necessary in the course of appeal proceeding. 3. In grounds of appeal

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

unexplained money u/s 69A of the Act as these cash deposits are from the earlier withdrawals and therefore the additions on 11,50,000 is liable to be deleted. 5. That, the appellant craves to alter, amend, modify or add any other ground that may be considered necessary in the course of appeal proceeding. 3. In grounds of appeal

M/S. JAYA MANGALA CONSTRUCTION,KORAPUT vs. ITO, WARD-1, JEYPORE

In the result, appeal filed by the assessee is allowed

Bench: Shri N.S Sainiassessment Year :2005-06

unexplained money. The impugned addition thus is liable to be deleted in the interest of justice. 7. For that, when nature of business and the gross turnover of the Assessee qualify the necessary condition of section 44AE of the Act, the learned A.O. as well as the learned C.I.T(A) has committed error in not applying section 44AE

M/S. ORISSA MINING CORPORATION LIMITED,BHUBANESWAR vs. ACIT, CIRCLE-2(1), BHUBANESWAR

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

Bench: Shri George Mathan & Shri Arun Khodpiam/S Orissa Mining Corporation Ltd., Omc House, Post Box No.34, Bhubaneswar-01 Pan No.Aaaco 3324 L …………….. Assessee Versus Acit, Circle-2(1), Bhubaneswar ………………Revenue

reassessment within four years was permissible. It was also held that said case was not based on change of opinion. It was based on 5 the Assessing Officer overlooking the meaning of the word "profit" in section 80HHC(3)(c) of the Act. In the present case, the AO had overlooked the fact of receipt of share application money

BHAVENDRA HASMUKHLAL PATADIA. LEGAL HEIR OF HASMUKHLAL PATADIA.,CUTTACK vs. ITO WARD-!(1), CUTTACK

In the result, appeal of the assessee is allowed

Bench: Shri George Mathan & Shri Arun Khodpiaआयकर अऩीऱ सं/Ita No.125/Ctk/2022 (ननधाारण वषा / Assessment Year :2015-2016) Bhavendra Hasmukhlal Patadia, Vs Ito, Ward-1(1), Cuttack Legal Heir Of Hasmukhlal Patadia, Nayabazar, Chauliaganj, Cuttack-753004 Pan No. :Adapp 6256 G (अऩीऱाथी /Appellant) .. (प्रत्यथी / Respondent) ननधााररती की ओर से /Assessee By : Shri Deepak Shah, Ar राजस्व की ओर से /Revenue By : Shri M.K.Gautam, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 26/12/2022 घोषणा की तारीख/Date Of Pronouncement : 26/12/2022 आदेश / O R D E R Per Bench : This Is An Appeal Filed By The Assessee Against The Order Of The Ld Pr.Cit, Cuttack, Passed In Itba/Com/F/17/2019-20/1026790827(1), Dated 19.03.2020, For The Assessment Year 2015-2016. Head On The Question Of Condonation Of Delay 2. On Perusal Of The Appeal Record, It Is Found That The Appeal Of The Assessee Is Barred By 784 Days. In This Regard, The Assessee Has Filed An Application For Condonation Of Delay Dated 11.07.2022 Along With Affidavit Stating Therein That Due To Continuous Lockdown On Account Of Spread Of Covid-19, The Assessee Could Not File The Present Appeal In Time, Therefore, He Prayed That Delay Of 784 Days In Filing The Present Appeal May Kindly Be Condoned. On The Other Hand, Ld. Cit-Dr Did Not Object To The Above Submission Of The Ld. Ar. Considering The Above, We Condone

money lending business. Further, it needs to be borne in mind that the law deems the same as unexplained income for the year in which the asset (deposit) is found (made), i.e., the current year. It is only for the current year that, by virtue of the information in the possession of the Revenue of the cash deposits

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

unexplained cash credit in respect of the sales. The ld. Pr.CIT(OSD) further drew our attention to the decision of the Hon‟ble Gujarat High Court in the case of Smt. P. Sheth, reported in 356 ITR 451 (Gujarat). It was the submission that the ld. CIT(A) has extracted the relevant portion of the said citations in his order

TAPAS RANJAN BAL,BHUBANESWAR vs. ITO, WARD-3(5), BHUBANESWAR

In the result, appeal of the assessee is partly allowed

reassessment proceedings is to be judged with reference to the reasons recorded for reopening the assessment, which is done in this case. Hence, I do not find force in this ground of appeal, which is hereby dismissed. Besides the above legal ground, the assessee has also raised various grounds on merits, which are discussed as under

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

unexplained loan of R.s.75,00,000/- and on account of undisclosed interest income of Rs.6,25,000/- are confirmed and the grounds of appeal are dismissed. 6. Ground No. 4:- Charging of interest u/s.234A, 234B & 234C of the Income Tax Act, 1961, mandatory, compensatory and consequential in nature. The ground of appeal is dismissed. 7. Additional Ground: 7.1 In this

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

unexplained loan of R.s.75,00,000/- and on account of undisclosed interest income of Rs.6,25,000/- are confirmed and the grounds of appeal are dismissed. 6. Ground No. 4:- Charging of interest u/s.234A, 234B & 234C of the Income Tax Act, 1961, mandatory, compensatory and consequential in nature. The ground of appeal is dismissed. 7. Additional Ground: 7.1 In this

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

unexplained loan of R.s.75,00,000/- and on account of undisclosed interest income of Rs.6,25,000/- are confirmed and the grounds of appeal are dismissed. 6. Ground No. 4:- Charging of interest u/s.234A, 234B & 234C of the Income Tax Act, 1961, mandatory, compensatory and consequential in nature. The ground of appeal is dismissed. 7. Additional Ground: 7.1 In this

BASUKINATH ROADWAYS PVT. LTD.,SUNDARGARH vs. PRINCIPAL CIT(CENTRAL), VISAKHAPATNAM

In the result, appeal of the assessee is allowed

money which is not disputed in the present appeal by the department. The Pr. CIT has observed that the assessee has no eligibility for the claim of expenditure. We are of the opinion on the subject matter of shortage of expenses envisaged by the ld. AR as per the questionnaire in the original assessment proceedings, where the assessee has satisfied

L N FINANCE COOPERATIVE SOCIETY LIMITED,TARAPUR vs. ITO, WARD PARADEEP, PARADEEP

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

Bench: Shri George Mathan & Shri Manish Agarwalassessment Year: 2014-15 L.N.Finance Vs. Income Tax Officer, Cooperative Society Paradeep Ward, Limited, Tarapur, Paradeep, Orissa Raghunathpur, Jagatsinghpur 754132, Orissa Pan/Gir No.Aabal0759R (Appellant) .. ( Respondent) Assessee By : Shri Nihar Ranjan Biswal, Ca Revenue By: Shri. S.C Mothanty, Sr. Dr Date Of Hearing : 12/11/2024 Date Of Pronouncement : 12/11/2024

unexplained income u/s 69A without considering the fact that the detailed explanation/ submission relates to said issue were filed before the Id. AO, CIT(A) and without considering the remand report and rejoinder The Ld. CIT(A) has also not considered the submission filed physically before the Ld AO and in e- filling portal and e-mail. However