PARADIP PORT AUTHORITY,JAGATSINGHPUR vs. DCIT,CIRCLE1(1), CUTTACK

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

73,803 Total Revenue Expenditure(a+b) Capital Expenditure Application as per Schedule -3, Fixed 65,40,57,923 33,67,65,810 9,46,51,725 Assets (c) Repayment of Capital Loan (ADB) taken from Govt. of India 1,06,01,00,000 49,97,00,000 refer schedule 2 of the Accounts - (d) Total Application towards object

ITO, WARD-3(2), BHUBANESWAR, BHUBANESWAR vs. GAYA SANTARA, BHUBANESWAR

In the result, appeal filed by the revenue is dismissed and the appeal

Bench: S/Shri N.S Saini & Pavan Kumar Gadaleassessment Year :2008-09

73,003/-, Rs.6,78,571/- towards indexed cost of improvement and Rs.1,20,000/- towards expenses on transfer of capital asset. Accordingly, the net long term capital gain was arrived at Rs.60,18,026/-, which was fully claimed as exempt under section 54F of the Act. From the letter dated 21.4.2012 of the builder, it is noted by the Assessing

M/S- RAWAT BALAJI (JOINT VENTURE),JHARSUGUDA vs. PRILNCIPAL, CIT, SAMBALPUR

In the result, appeal of the assessee in ITA No

Bench: Shri C.M. Garg, Jm & Shri Manish Borad, Am आयकर अपीऱ सं./Ita Nos.193/Ctk/2019 (नििाारण वषा / Assessment Year :2014-2015) M/S Rawats-Balaji(Jv), Vs Pr.Cit, Sambalpur At/Po-Belpahar(Rs), Dist : Jharsuguda Pan No. : Aabar 9061 J Tan No. : Bbnr01647 C & आयकर अपीऱ सं./Ita Nos.194/Ctk/2019 (नििाारण वषा / Assessment Year :2014-2015) M/S Sbepl-Gril(Jv), Vs Pr.Cit, Sambalpur At/Po-Belpahar(Rs), Dist : Jharsuguda Pan No. : Aafas 2639 R Tan No. : Bbns04348 B & आयकर अपीऱ सं./Ita Nos.195/Ctk/2019 (नििाारण वषा / Assessment Year :2014-2015) Shree Balaji Engicons Pvt Ltd Vs Pr.Cit, Sambalpur At/Po-Belpahar(Rs), Dist : Jharsuguda Pan No. : Aagcs 4292 P Tan No. : Bbns00091 A (अऩीलाथी /Appellant) (प्रत्यथी / Respondent) .. ननधाारिती की ओर से /Assessee By : Shri Satyanarayan Agarwal, Ar िाजस्व की ओर से /Revenue By : Shri M.K.Gautam, Citdr सुनवाई की तािीख / Date Of Hearing : 26/10/2021 घोषणा की तािीख/Date Of Pronouncement : 23/12/2021 आदेश / O R D E R Per Bench: These Three Appeals Have Been Filed By Three Different Assessees Against The Order Passed By The Pr.Cit, Sambalpur, U/S.263 Of The Act, All Dated 30.03.2019 For The Assessment Year 2014-2015. 2

section 80-IA(4) of the Act in respect of the development of eligible infrastructural facilities. 41 ITA Nos.193-195/CTK/2019 19. Ld. AR also pointed out that the assessee was assigned full responsibility to do all acts for execution and completion of work right from the beginning till handing over of the project to the contractee. The contract

SHREE BALAJI ENGICONS PVT. LTD,JHARSUGUDA vs. PRINCIPAL CIT, SAMBALPUR

In the result, appeal of the assessee in ITA No

Bench: Shri C.M. Garg, Jm & Shri Manish Borad, Am आयकर अपीऱ सं./Ita Nos.193/Ctk/2019 (नििाारण वषा / Assessment Year :2014-2015) M/S Rawats-Balaji(Jv), Vs Pr.Cit, Sambalpur At/Po-Belpahar(Rs), Dist : Jharsuguda Pan No. : Aabar 9061 J Tan No. : Bbnr01647 C & आयकर अपीऱ सं./Ita Nos.194/Ctk/2019 (नििाारण वषा / Assessment Year :2014-2015) M/S Sbepl-Gril(Jv), Vs Pr.Cit, Sambalpur At/Po-Belpahar(Rs), Dist : Jharsuguda Pan No. : Aafas 2639 R Tan No. : Bbns04348 B & आयकर अपीऱ सं./Ita Nos.195/Ctk/2019 (नििाारण वषा / Assessment Year :2014-2015) Shree Balaji Engicons Pvt Ltd Vs Pr.Cit, Sambalpur At/Po-Belpahar(Rs), Dist : Jharsuguda Pan No. : Aagcs 4292 P Tan No. : Bbns00091 A (अऩीलाथी /Appellant) (प्रत्यथी / Respondent) .. ननधाारिती की ओर से /Assessee By : Shri Satyanarayan Agarwal, Ar िाजस्व की ओर से /Revenue By : Shri M.K.Gautam, Citdr सुनवाई की तािीख / Date Of Hearing : 26/10/2021 घोषणा की तािीख/Date Of Pronouncement : 23/12/2021 आदेश / O R D E R Per Bench: These Three Appeals Have Been Filed By Three Different Assessees Against The Order Passed By The Pr.Cit, Sambalpur, U/S.263 Of The Act, All Dated 30.03.2019 For The Assessment Year 2014-2015. 2

section 80-IA(4) of the Act in respect of the development of eligible infrastructural facilities. 41 ITA Nos.193-195/CTK/2019 19. Ld. AR also pointed out that the assessee was assigned full responsibility to do all acts for execution and completion of work right from the beginning till handing over of the project to the contractee. The contract

M/S- SBEP-GRIL(JOINT VENTURE),JHARSUGUDA vs. PRINCIPAL CIT, SAMBALPUR

In the result, appeal of the assessee in ITA No

Bench: Shri C.M. Garg, Jm & Shri Manish Borad, Am आयकर अपीऱ सं./Ita Nos.193/Ctk/2019 (नििाारण वषा / Assessment Year :2014-2015) M/S Rawats-Balaji(Jv), Vs Pr.Cit, Sambalpur At/Po-Belpahar(Rs), Dist : Jharsuguda Pan No. : Aabar 9061 J Tan No. : Bbnr01647 C & आयकर अपीऱ सं./Ita Nos.194/Ctk/2019 (नििाारण वषा / Assessment Year :2014-2015) M/S Sbepl-Gril(Jv), Vs Pr.Cit, Sambalpur At/Po-Belpahar(Rs), Dist : Jharsuguda Pan No. : Aafas 2639 R Tan No. : Bbns04348 B & आयकर अपीऱ सं./Ita Nos.195/Ctk/2019 (नििाारण वषा / Assessment Year :2014-2015) Shree Balaji Engicons Pvt Ltd Vs Pr.Cit, Sambalpur At/Po-Belpahar(Rs), Dist : Jharsuguda Pan No. : Aagcs 4292 P Tan No. : Bbns00091 A (अऩीलाथी /Appellant) (प्रत्यथी / Respondent) .. ननधाारिती की ओर से /Assessee By : Shri Satyanarayan Agarwal, Ar िाजस्व की ओर से /Revenue By : Shri M.K.Gautam, Citdr सुनवाई की तािीख / Date Of Hearing : 26/10/2021 घोषणा की तािीख/Date Of Pronouncement : 23/12/2021 आदेश / O R D E R Per Bench: These Three Appeals Have Been Filed By Three Different Assessees Against The Order Passed By The Pr.Cit, Sambalpur, U/S.263 Of The Act, All Dated 30.03.2019 For The Assessment Year 2014-2015. 2

section 80-IA(4) of the Act in respect of the development of eligible infrastructural facilities. 41 ITA Nos.193-195/CTK/2019 19. Ld. AR also pointed out that the assessee was assigned full responsibility to do all acts for execution and completion of work right from the beginning till handing over of the project to the contractee. The contract

DCIT, CIRCLE-1(1), BHUBANESWAR, BHUBANESWAR vs. M/S. PARADEEP PHOSPHATES LIMITED, BHUBANESWAR

In the result, appeal filed by the revenue is dismissed and that of

Bench: S/Shri N.S Saini & Pavan Kumar Gadaleassessment Year : 2010-2011

Transfer Pricing (TP) assessment for the AY 2010-11 has been completed on 30.01.2014 with "NIL Adjustment" after going through in detail, the transactions of imports from various parties being associated enterprises within the meaning of Section 92 (C) of the Income Tax Act, 1961. Copy of the aforesaid Order is enclosed and marked as Annexure-1 for your kind

ASHWIN KUMAR AGARWAL,CUTTACK vs. DCIT ASMNT CIRCLE-2(1)CUTTACK, CUTTACK

In the result, appeal of the assessee is allowed

73 Crore from the sale of “future” which was claimed as invested in the acquisition of shares and also as the source of capital introduction in the partnership firm. The Id Sr.DR further submits that in the case of the firm an addition of Rs.89,69,000/- was made on account of capital introduction by the assessee as unexplained credit

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

price agreed between them and JV’s and in turn JV’s has raised the bills to the principal at the rate awarded in the tender. The principal has made the payment to the JV after making TDS and then payments were released to both the constituents according to their bills. Thereafter the returns of income were filed

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

price agreed between them and JV’s and in turn JV’s has raised the bills to the principal at the rate awarded in the tender. The principal has made the payment to the JV after making TDS and then payments were released to both the constituents according to their bills. Thereafter the returns of income were filed

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

price agreed between them and JV’s and in turn JV’s has raised the bills to the principal at the rate awarded in the tender. The principal has made the payment to the JV after making TDS and then payments were released to both the constituents according to their bills. Thereafter the returns of income were filed

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

price agreed between them and JV’s and in turn JV’s has raised the bills to the principal at the rate awarded in the tender. The principal has made the payment to the JV after making TDS and then payments were released to both the constituents according to their bills. Thereafter the returns of income were filed

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

price agreed between them and JV’s and in turn JV’s has raised the bills to the principal at the rate awarded in the tender. The principal has made the payment to the JV after making TDS and then payments were released to both the constituents according to their bills. Thereafter the returns of income were filed

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

price agreed between them and JV’s and in turn JV’s has raised the bills to the principal at the rate awarded in the tender. The principal has made the payment to the JV after making TDS and then payments were released to both the constituents according to their bills. Thereafter the returns of income were filed

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

price agreed between them and JV’s and in turn JV’s has raised the bills to the principal at the rate awarded in the tender. The principal has made the payment to the JV after making TDS and then payments were released to both the constituents according to their bills. Thereafter the returns of income were filed

ACIT, SAMBALPUR vs. M/S MAHANADI COALFIELDS LTD, SAMBALPUR

In the result, appeals filed by the revenue for the assessment years

Bench: S/Shri N.S Saini & Pavan Kumar Gadale

price mines-wise; hence taking the global view for valuation of closing stock can never be justified rather the valuation of coal mines- wise gives the real cost of production for the purpose of valuation of stock in place of valuation for MCL as a whole. We considering the overall circumstances and uniform accounting policy issued by Coal India Limited

ITO, BHADRAK WARD, BHADRAK vs. HIMANSU MOHAPATRA, BHADRAK

In the result, Appeals of the revenue in in ITANos

Bench: Shri C.M. Garg, Jm & Shri Manish Borad, Am

73,845/- M/s Kailash Auto Finance Ltd. (KAFL) Kishore Kumar 2014-15 38,82,500/- M/s Kailash Auto Finance Ltd. (KAFL) Mohapatra Parbati Mohapatra 2014-15 50,83,000/- M/s Lifeline Durgs & Pharma Ltd. Kuntala Mohapatra 2014-15 50,43,545/- M/s Kailash Auto Finance Ltd. (KAFL) 4. The common grievance of revenue relates to holding of bogus Long Term

ITO, BHADRAK WARD, BHADRAK vs. HIMANSU MOHAPATRA, BHADRAK

In the result, Appeals of the revenue in in ITANos

Bench: Shri C.M. Garg, Jm & Shri Manish Borad, Am

73,845/- M/s Kailash Auto Finance Ltd. (KAFL) Kishore Kumar 2014-15 38,82,500/- M/s Kailash Auto Finance Ltd. (KAFL) Mohapatra Parbati Mohapatra 2014-15 50,83,000/- M/s Lifeline Durgs & Pharma Ltd. Kuntala Mohapatra 2014-15 50,43,545/- M/s Kailash Auto Finance Ltd. (KAFL) 4. The common grievance of revenue relates to holding of bogus Long Term

ITO, BHADRAK WARD, BHADRAK vs. DEEPANSU MOHAPATRA, BHADRAK

In the result, Appeals of the revenue in in ITANos

Bench: Shri C.M. Garg, Jm & Shri Manish Borad, Am

73,845/- M/s Kailash Auto Finance Ltd. (KAFL) Kishore Kumar 2014-15 38,82,500/- M/s Kailash Auto Finance Ltd. (KAFL) Mohapatra Parbati Mohapatra 2014-15 50,83,000/- M/s Lifeline Durgs & Pharma Ltd. Kuntala Mohapatra 2014-15 50,43,545/- M/s Kailash Auto Finance Ltd. (KAFL) 4. The common grievance of revenue relates to holding of bogus Long Term