ITO, ANGUL WARD, , ANGUL vs. M/S. NCC SMASL JRT(JV),, ANGUL

transfer the entire sale proceeds to AE to ensure lowest sale price to MC. The assessee failed to justify the rationality of the approach since, the ultimate sale price to MCL is not linked with the cost of either assessee or AE in the entire scheme of arrangement. Further, the assessee's contention that the income of the assessee

ITO, ANGUL WARD, ANGUL vs. NCC-SMASL-JRT(JV), ANGUL

transfer the entire sale proceeds to AE to ensure lowest sale price to MC. The assessee failed to justify the rationality of the approach since, the ultimate sale price to MCL is not linked with the cost of either assessee or AE in the entire scheme of arrangement. Further, the assessee's contention that the income of the assessee

M/S. SHREE BALAJI ENGICONS PVT. LTD.,BELPAHAR, JHARSUGUDA vs. DCIT, CENTRAL CIRCLE-1(1), SAMBALPUR, SAMBALPUR

In the result, appeals of the assesee in IT(SS)A No

Bench: Shri George Mathan & Shri Manish Agarwalit(Ss)A No.77/Ctk/2023

transferred to their constituents. Therefore, the joint venture or the consortium was only a paper entity and has not executed in contract itself. They have also not offered any income out of the work 16 IT(SS)A No.77 & ITA Nos.320,296,88, 141,89,142,13/CTK/2023 &CO No.02/CTK/2023 executed by its constituents, nor did they claim any deductions

ACIT, CENTRAL CIRCLE, SAMBALPUR, SAMBALPUR vs. M/S. SHREE BALAJI ENGICONS PVT. LTD., JHARSUGUDA

In the result, appeals of the assesee in IT(SS)A No

Bench: Shri George Mathan & Shri Manish Agarwalit(Ss)A No.77/Ctk/2023

transferred to their constituents. Therefore, the joint venture or the consortium was only a paper entity and has not executed in contract itself. They have also not offered any income out of the work 16 IT(SS)A No.77 & ITA Nos.320,296,88, 141,89,142,13/CTK/2023 &CO No.02/CTK/2023 executed by its constituents, nor did they claim any deductions

ASST. CIT, CENTRAL CIRCLE, SAMBALPUR, AAYAKAR BHAWAN, SAMBALPUR vs. SHREE BALAJI ENGICON LIMITED, BELPAHAR RS

In the result, appeals of the assesee in IT(SS)A No

Bench: Shri George Mathan & Shri Manish Agarwalit(Ss)A No.77/Ctk/2023

transferred to their constituents. Therefore, the joint venture or the consortium was only a paper entity and has not executed in contract itself. They have also not offered any income out of the work 16 IT(SS)A No.77 & ITA Nos.320,296,88, 141,89,142,13/CTK/2023 &CO No.02/CTK/2023 executed by its constituents, nor did they claim any deductions

M/S. SHREE BALAJI ENGICONS PVT. LTD.,BELPAHAR, JHARSUGUDA vs. ACIT, CENTRAL CIRCLE-1(1), SAMBALPUR, SAMBALPUR

In the result, appeals of the assesee in IT(SS)A No

Bench: Shri George Mathan & Shri Manish Agarwalit(Ss)A No.77/Ctk/2023

transferred to their constituents. Therefore, the joint venture or the consortium was only a paper entity and has not executed in contract itself. They have also not offered any income out of the work 16 IT(SS)A No.77 & ITA Nos.320,296,88, 141,89,142,13/CTK/2023 &CO No.02/CTK/2023 executed by its constituents, nor did they claim any deductions

ACIT, CENTRAL CIRCLE, SAMBALPUR, SAMBALPUR vs. M/S. SHREE BALAJI ENGICONS PVT. LTD., JHARSUGUDA

In the result, appeals of the assesee in IT(SS)A No

Bench: Shri George Mathan & Shri Manish Agarwalit(Ss)A No.77/Ctk/2023

transferred to their constituents. Therefore, the joint venture or the consortium was only a paper entity and has not executed in contract itself. They have also not offered any income out of the work 16 IT(SS)A No.77 & ITA Nos.320,296,88, 141,89,142,13/CTK/2023 &CO No.02/CTK/2023 executed by its constituents, nor did they claim any deductions

ACIT, CENTRAL CIRCLE, SAMBALPUR, SAMBALPUR vs. M/S. SHREE BALAJI ENGICONS PVT. LTD., JHARSUGUDA

In the result, appeals of the assesee in IT(SS)A No

Bench: Shri George Mathan & Shri Manish Agarwalit(Ss)A No.77/Ctk/2023

transferred to their constituents. Therefore, the joint venture or the consortium was only a paper entity and has not executed in contract itself. They have also not offered any income out of the work 16 IT(SS)A No.77 & ITA Nos.320,296,88, 141,89,142,13/CTK/2023 &CO No.02/CTK/2023 executed by its constituents, nor did they claim any deductions

M/S. SHREE BAALAJI ENGICONS LIMITED,JHARSUGUDA vs. DEPUTY COMMISSIONER OF INCOME TAX ( CENTRAL CIRCLE-1(1), SAMBALPUR

In the result, appeals of the assesee in IT(SS)A No

Bench: Shri George Mathan & Shri Manish Agarwalit(Ss)A No.77/Ctk/2023

transferred to their constituents. Therefore, the joint venture or the consortium was only a paper entity and has not executed in contract itself. They have also not offered any income out of the work 16 IT(SS)A No.77 & ITA Nos.320,296,88, 141,89,142,13/CTK/2023 &CO No.02/CTK/2023 executed by its constituents, nor did they claim any deductions

KALINGA MINING CORPORATION,CUTTACK vs. A.C.I.T, CIRCLE-2(1), CUTTACK

In the result, both appeals of the assessee are allowed

142 or section 148 or to disclose fully and truly all material facts necessary for his assessment, for that assessment year:" 4. That, the revising, reopening or reconsidering the whole assessment u/s.147 by issuance of notice u/s.148 in the pretext that income has escaped assessment in absence of any credible additional material evidences is not permissible on the ground that

KALINGA MINING CORPORATION,CUTTACK vs. A.C.I.T., CIRCLE-2(1), CUTTACK

In the result, both appeals of the assessee are allowed

142 or section 148 or to disclose fully and truly all material facts necessary for his assessment, for that assessment year:" 4. That, the revising, reopening or reconsidering the whole assessment u/s.147 by issuance of notice u/s.148 in the pretext that income has escaped assessment in absence of any credible additional material evidences is not permissible on the ground that