ABCI INFRASTRUCTURES PRIVATE LIMITED,KOLKATA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUWAHATI

In the result, the appeal of the assessee is allowed, whereas the appeal of the Revenue is dismissed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

9. The ld. Counsel for the assessee while impugning the findings of both the authorities took us through section 153A, 147 and 148 of the Income T\ax Act. He contended that basically construction/ interpretation of sections 147 /148 is not in much dispute under the present question, but it is very much necessary to explain the scope of section

GREENWOOD RESORTS PRIVATE LIMITED,GUWAHATI vs. DEPUTY COMMISSIONER OF INCOME TAX, GUWAHATI

In the result, ITA No. 114/GTY/2024 for AY 2017-18 is partly allowed for statistical purposes

Bench: Shri Manomohan Das & Shri Rakesh Mishra

vii. ITA No. 116/GTY/2024: A.Y. 2019-20: “1 For that assessment order passed u/s 153C 143(3) is bad in law and liable to be quashed as no proper satisfaction has been recorded as required under the provision of I.T. Act. 2 For that additions made by the A.O. and upheld

GREENWOOD RESORTS PRIVATE LIMITED,GUWAHATI vs. DEPUTY COMMISSIONER OF INCOME TAX, GUWAHATI

In the result, ITA No. 114/GTY/2024 for AY 2017-18 is partly allowed for statistical purposes

Bench: Shri Manomohan Das & Shri Rakesh Mishra

vii. ITA No. 116/GTY/2024: A.Y. 2019-20: “1 For that assessment order passed u/s 153C 143(3) is bad in law and liable to be quashed as no proper satisfaction has been recorded as required under the provision of I.T. Act. 2 For that additions made by the A.O. and upheld

GREENWOOD RESORTS PRIVATE LIMITED,GUWAHATI vs. DEPUTY COMMISSIONER OF INCOME TAX, GUWAHATI

In the result, ITA No. 114/GTY/2024 for AY 2017-18 is partly allowed for statistical purposes

Bench: Shri Manomohan Das & Shri Rakesh Mishra

vii. ITA No. 116/GTY/2024: A.Y. 2019-20: “1 For that assessment order passed u/s 153C 143(3) is bad in law and liable to be quashed as no proper satisfaction has been recorded as required under the provision of I.T. Act. 2 For that additions made by the A.O. and upheld

GREENWOOD RESORTS PRIVATE LIMITED,GUWAHATI vs. DEPUTY COMMISSIONER OF INCOME TAX, GUWAHATI

In the result, ITA No. 114/GTY/2024 for AY 2017-18 is partly allowed for statistical purposes

Bench: Shri Manomohan Das & Shri Rakesh Mishra

vii. ITA No. 116/GTY/2024: A.Y. 2019-20: “1 For that assessment order passed u/s 153C 143(3) is bad in law and liable to be quashed as no proper satisfaction has been recorded as required under the provision of I.T. Act. 2 For that additions made by the A.O. and upheld

GREENWOOD RESORTS PRIVATE LIMITED,GUWAHATI vs. DEPUTY COMMISSIONER OF INCOME TAX, GUWAHATI

In the result, ITA No. 114/GTY/2024 for AY 2017-18 is partly allowed for statistical purposes

Bench: Shri Manomohan Das & Shri Rakesh Mishra

vii. ITA No. 116/GTY/2024: A.Y. 2019-20: “1 For that assessment order passed u/s 153C 143(3) is bad in law and liable to be quashed as no proper satisfaction has been recorded as required under the provision of I.T. Act. 2 For that additions made by the A.O. and upheld

GREENWOOD RESORTS PRIVATE LIMITED,GUWAHATI vs. DEPUTY COMMISSIONER OF INCOME TAX, GUWAHATI

In the result, ITA No. 114/GTY/2024 for AY 2017-18 is partly allowed for statistical purposes

Bench: Shri Manomohan Das & Shri Rakesh Mishra

vii. ITA No. 116/GTY/2024: A.Y. 2019-20: “1 For that assessment order passed u/s 153C 143(3) is bad in law and liable to be quashed as no proper satisfaction has been recorded as required under the provision of I.T. Act. 2 For that additions made by the A.O. and upheld

GREENWOOD RESORTS PRIVATE LIMITED,GUWAHATI vs. ACIT, CENTRAL CIRCLE-1, GUWAHATI

In the result, ITA No. 114/GTY/2024 for AY 2017-18 is partly allowed for statistical purposes

Bench: Shri Manomohan Das & Shri Rakesh Mishra

vii. ITA No. 116/GTY/2024: A.Y. 2019-20: “1 For that assessment order passed u/s 153C 143(3) is bad in law and liable to be quashed as no proper satisfaction has been recorded as required under the provision of I.T. Act. 2 For that additions made by the A.O. and upheld

GREENWOOD RESORTS PRIVATE LIMITED,GUWAHATI vs. DEPUTY COMMISSIONER OF INCOME TAX, GUWAHATI

In the result, ITA No. 114/GTY/2024 for AY 2017-18 is partly allowed for statistical purposes

Bench: Shri Manomohan Das & Shri Rakesh Mishra

vii. ITA No. 116/GTY/2024: A.Y. 2019-20: “1 For that assessment order passed u/s 153C 143(3) is bad in law and liable to be quashed as no proper satisfaction has been recorded as required under the provision of I.T. Act. 2 For that additions made by the A.O. and upheld

GREENWOOD RESORTS PRIVATE LIMITED,GUWAHATI vs. DEPUTY COMMISSIONER OF INCOME TAX, GUWAHATI

In the result, ITA No. 114/GTY/2024 for AY 2017-18 is partly allowed for statistical purposes

Bench: Shri Manomohan Das & Shri Rakesh Mishra

vii. ITA No. 116/GTY/2024: A.Y. 2019-20: “1 For that assessment order passed u/s 153C 143(3) is bad in law and liable to be quashed as no proper satisfaction has been recorded as required under the provision of I.T. Act. 2 For that additions made by the A.O. and upheld

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUWAHATI vs. ABCI INFRASTRUCTURES PRIVATE LIMITED, KOLKATA

In the result, the appeal of the assessee for Assessment Year

Bench: Sri Rajpal Yadav(Kz) & Dr. Manish Borad

9 of 114 I.T.A. No.: 43/GTY/2022 I.T.A. No.: 2/GTY/2023 Assessment Year: 2014-15 I.T.A. Nos.: 37, 38 & 39/GTY/2022 AYs: 2017-18, 2018-19 & 2019-20 ABCI Infrastructure Private Limited. genuineness of those payments. In this regard, from a very perusal of the aforesaid observation of ld. AO, it is clear that the assessee has made payments to Tribal workers. Being

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUWAHATI vs. ABCI INFRASTRUCTURES PRIVATE LIMITED, KOLKATA

In the result, the appeal of the assessee for Assessment Year

Bench: Sri Rajpal Yadav(Kz) & Dr. Manish Borad

9 of 114 I.T.A. No.: 43/GTY/2022 I.T.A. No.: 2/GTY/2023 Assessment Year: 2014-15 I.T.A. Nos.: 37, 38 & 39/GTY/2022 AYs: 2017-18, 2018-19 & 2019-20 ABCI Infrastructure Private Limited. genuineness of those payments. In this regard, from a very perusal of the aforesaid observation of ld. AO, it is clear that the assessee has made payments to Tribal workers. Being

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUWAHATI vs. ABCI INFRASTRUCTURES PRIVATE LIMITED, KOLKATA

In the result, the appeal of the assessee for Assessment Year

Bench: Sri Rajpal Yadav(Kz) & Dr. Manish Borad

9 of 114 I.T.A. No.: 43/GTY/2022 I.T.A. No.: 2/GTY/2023 Assessment Year: 2014-15 I.T.A. Nos.: 37, 38 & 39/GTY/2022 AYs: 2017-18, 2018-19 & 2019-20 ABCI Infrastructure Private Limited. genuineness of those payments. In this regard, from a very perusal of the aforesaid observation of ld. AO, it is clear that the assessee has made payments to Tribal workers. Being

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUWAHATI vs. ABCI INFRASTRUCTURES PRIVATE LIMITED, KOLKATA

In the result, the appeal of the assessee for Assessment Year

Bench: Sri Rajpal Yadav(Kz) & Dr. Manish Borad

9 of 114 I.T.A. No.: 43/GTY/2022 I.T.A. No.: 2/GTY/2023 Assessment Year: 2014-15 I.T.A. Nos.: 37, 38 & 39/GTY/2022 AYs: 2017-18, 2018-19 & 2019-20 ABCI Infrastructure Private Limited. genuineness of those payments. In this regard, from a very perusal of the aforesaid observation of ld. AO, it is clear that the assessee has made payments to Tribal workers. Being

ABCI INFRASTRUCTURES PRIVATE LIMITED,KOLKATA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUWAHATI

In the result, the appeal of the assessee for Assessment Year

Bench: Sri Rajpal Yadav(Kz) & Dr. Manish Borad

9 of 114 I.T.A. No.: 43/GTY/2022 I.T.A. No.: 2/GTY/2023 Assessment Year: 2014-15 I.T.A. Nos.: 37, 38 & 39/GTY/2022 AYs: 2017-18, 2018-19 & 2019-20 ABCI Infrastructure Private Limited. genuineness of those payments. In this regard, from a very perusal of the aforesaid observation of ld. AO, it is clear that the assessee has made payments to Tribal workers. Being

M/S. NORTH EASTERN ELECTRIC POWER CORPORATION LTD.,SHILLONG vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE - SHILLONG, SHILLONG

In the result, the appeal of the assessee in ITA

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

vii) The AO exercises quasi-judicial power vested in his and if he exercises such power in accordance with law and arrive at a conclusion, such conclusion cannot be termed to be erroneous simply because the CIT does not fee stratified with the conclusion. (viii) The CIT, before exercising his jurisdiction under s. 263 must have material on record

M/S. NORTH EASTERN ELECTRIC POWER CORPORATION LTD.,SHILLONG vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE - SHILLONG, SHILLONG

In the result, the appeal of the assessee in ITA

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

vii) The AO exercises quasi-judicial power vested in his and if he exercises such power in accordance with law and arrive at a conclusion, such conclusion cannot be termed to be erroneous simply because the CIT does not fee stratified with the conclusion. (viii) The CIT, before exercising his jurisdiction under s. 263 must have material on record

TRIPURA STATE ELECTRICITY CORPORATION LTD.,TRIPURA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - AGARTALA, AGARTALA

Bench: Sh. S.S.Godara & Dr. A.L. Saini

TDS. His case is that the assessee had not availed any technical services from its payees. The fact remains that this taxpayer has not tendered any details of the actual nature of expenditure. We therefore find no reason to disagree with the lower authorities’ conclusion quoting assessee’s failure in filing the relevant details. Coupled with this, the fact also