B G EXPLORATION & PRODUCTION INDIA LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME, DDIT/ ADIT (INTERNATIONAL TAXATION), CIRCLE-1, DEHRADUN, DEHRADUN

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

Bench: Sh. Kul Bharatdr. B. R. R. Kumar

1 : Reassessment proceedings are without Jurisdiction and bad in law 1.1 The learned AO erred in law and on facts as reasons recorded for reopening the case of the assessee for AY 2015-16 are invalid and cannot form the basis for reassessment. Ground No. 2: Erroneous disallowance of payment made towards intra-group services by Appellant to its Associated

BG EXPLORATION & PRODUCTION INDIA LIMITED,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX DDIT/ADIT (INTERNATIONAL TAXATION ) CIRCLE-1, DEHRADUN

In the result, the appeal of the assessee is partly allowed

Bench: Shri R.K. Panda & Shri V.P. Raoassessment Years: 2016-17

section 271(1)(c) of the Act. 16.3 The Appellant submits that each grounds of appeal are without prejudice to one another 16.4 The Appellant craves leave to add, alter, amend, substitute and / or modify in any manner whatsoever all or any of the foregoing grounds of objections at or before the hearing ofthe appeal.” 2. Ground Nos. 1

SANJAY BANSAL,DEHRADUN vs. DCIT CENTRAL CIRCLE, DEHRADUN

In the result, appeal of the assessee is allowed

Bench: Sh. Anil Chaturvedi & Sh. Challa Nagendra Prasad

disallowance made are uncalled for. 30. That the observation and the additions by the AO and by the CIT(A) made are unjust, bad in law, highly excessive and based on surmise conjecture. 31. That on the facts and circumstances of the case and in law the AO/CIT(A) has grossly erred in charging interest u/s 234A, 234B and 234C

SANJAY BANSAL,DEHRADUN vs. DCIT CENTRAL CIRCLE, DEHRADUN

In the result, appeal of the assessee is allowed

Bench: Sh. Anil Chaturvedi & Sh. Challa Nagendra Prasad

disallowance made are uncalled for. 30. That the observation and the additions by the AO and by the CIT(A) made are unjust, bad in law, highly excessive and based on surmise conjecture. 31. That on the facts and circumstances of the case and in law the AO/CIT(A) has grossly erred in charging interest u/s 234A, 234B and 234C

SANJAY BANSAL,DEHRADUN vs. DCIT CENTRAL CIRCLE, DEHRADUN

In the result, appeal of the assessee is allowed

Bench: Sh. Anil Chaturvedi & Sh. Challa Nagendra Prasad

disallowance made are uncalled for. 30. That the observation and the additions by the AO and by the CIT(A) made are unjust, bad in law, highly excessive and based on surmise conjecture. 31. That on the facts and circumstances of the case and in law the AO/CIT(A) has grossly erred in charging interest u/s 234A, 234B and 234C

SANJAY BANSAL,NEW DELHI vs. DCIT CENTRAL CIRCLE, DEHRADUN

In the result, appeal of the assessee is allowed

Bench: Sh. Anil Chaturvedi & Sh. Challa Nagendra Prasad

disallowance made are uncalled for. 30. That the observation and the additions by the AO and by the CIT(A) made are unjust, bad in law, highly excessive and based on surmise conjecture. 31. That on the facts and circumstances of the case and in law the AO/CIT(A) has grossly erred in charging interest u/s 234A, 234B and 234C

KISAN SAHKARI CHINI MILLS LIMITED, GADARPUR,GADARPUR vs. DCIT, CIRCLE-2(2)(1), KASHIPUR

Appeal is allowed

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwal

disallowance is an instance of concealment of income at the assessee’s behest attracting section 271(1)(c) in issue

ASSITANT COMMISSIONER OF INCOME TAX , DEHRADUN vs. POWER MACHINES, NEW DELHI

In the result, appeal preferred by the revenue is dismissed

Bench: SHRI SATBEER SINGH GODARA (Judicial Member), SHRI S. RIFAUR RAHMAN (Accountant Member)

271(1)(c) of the Act. 7. The Ld. AO. has erred in acknowledging the fact that the appellant has neither concealed any income nor furnished inaccurate particulars of income in respect of the addition made to warrant levy of penalty." 4. Before the Ld. CIT(A), the assessee filed a detailed submission as under: “Ground

M/S. UTTARAKHAND PURV SAINIK KALYAN NIGAM LTD.,DEHRADUN vs. ITO, DEHRADUN

In the result, the appeal of the assessee is dismissed

Bench: Shri Anubhav Sharma & Shri Brajesh Kumar Singh[Assessment Year: 2013-14] M/S Uttrakhand Purv Ito,Ward-2(5), Sainik Kalyan Nigam Ltd. Aayakar Bhawan,13-A, Subhash (Upnl) Vs Road, Dehradun Uttrakhand- Station Sub Area, Garhi 248003 Cantt, Dehradun-248003 Pan-Aaacu7129D Assessee Revenue Assessee By Shri Tarandeep Singh, Adv. Revenue By Shri Amar Pal Singh, Sr. Dr Date Of Hearing 31.01.2025 Date Of Pronouncement 19.03.2025

disallowed and assessment is completed on total income of Rs.6,79,59,986/-accordingly. Issue notice of demand. Charge interest u/s 234A/B/C. Give credit for prepaid taxes. Penalty proceedings u/s 271(1)(c) of the I.T. Act, inaccurate particulars of its income.” 5. Aggrieved with the said order, the assessee preferred an appeal before

M/S KUMAON MANDAL VIKASH NIGAM LIMITED,NAINITAL vs. ACIT, NAINITAL

In the result, both appeals of the assessee are allowed

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

section 143(3)of the Income Tax Act, 1961 (hereinafter, the ‘Act’), wherein various additions/disallowances were made. During the course of the assessment, the Assessing Officer (hereinafter, the ‘AO’) noted that the assessee had claimed interest expenditure on the said loan @ Rs.1,12,80,692/- every year. However, such interest was never paid in any year since such loan

M/S KUMAON MANDAL VIKASH NIGAM LIMIED.,NAINITAL vs. ACIT, CIRCLE-3, NAINITAL

In the result, both appeals of the assessee are allowed

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

section 143(3)of the Income Tax Act, 1961 (hereinafter, the ‘Act’), wherein various additions/disallowances were made. During the course of the assessment, the Assessing Officer (hereinafter, the ‘AO’) noted that the assessee had claimed interest expenditure on the said loan @ Rs.1,12,80,692/- every year. However, such interest was never paid in any year since such loan

DCIT (INTERNATIONAL TAXATION), DEHRADUN vs. M/S. SAMSUNG HEAVY INDUSTRIES CO. LTD., GURGAON

In the result, appeal of the assessee in ITA No

section 40(a)(ia) of the Act. It was also noticed that the AO had disallowed the said amount and the AO has calculated the income of the assessee from Inside India activity at a loss of Rs. 23,33,939/- in the following manner. Thus, the contention is that the AO in A.Y. 2007-08 had in principle accepted

SAMSUNG HEAVY INDUSTRIES CO. LTD.,GURGAON vs. DCIT (INTERNATIONAL TAXATION), DEHRADUN

In the result, appeal of the assessee in ITA No

section 40(a)(ia) of the Act. It was also noticed that the AO had disallowed the said amount and the AO has calculated the income of the assessee from Inside India activity at a loss of Rs. 23,33,939/- in the following manner. Thus, the contention is that the AO in A.Y. 2007-08 had in principle accepted

M/S. SARASWATI DYNAMICS PVT. LTD.,ROORKEE vs. ACIT, HARIDWAR

In the result, the appeal filed by the assesee is partly allowed for statistical purpose

Bench: Sh. R. K Panda & Sh. Anubhav Sharmaassessment Year: 2009-10 M/S. Saraswati Dynamics Acit Circle Pvt. Ltd. Vs Haridwar C-7, Industrial Estate, Roorkee Pan No.Aaecs6262M (Appellant) (Respondent)

271(l)(c) are being initiated separately for furnishing inaccurate particulars of income| thereby concealing his income.) (Addition 1,31,95,362/-) 5. In appeal the Ld. CIT(A) upheld the action of the AO in denying the deduction u/s. 80IC in respect of AMC and repair charges, Job work, duty draw back interest and miscellaneous income. 6. Aggrieved with